In Re: Methyl Tertiary Butyl Ether ("MTBE") Products Liability Litigation

Filing 3930

DECLARATION of Michael A. Walsh in Support re: (364 in 1:07-cv-10470-SAS, 34 in 1:14-cv-01014-SAS, 3927 in 1:00-cv-01898-SAS-DCF) MOTION to Dismiss for Lack of Jurisdiction.. Document filed by Tauber Oil. (Attachments: # 1 Exhibit A, # 2 Exhibit B, # 3 Exhibit C, # 4 Exhibit D, # 5 Exhibit E, # 6 Exhibit F, # 7 Exhibit G, # 8 Exhibit H, # 9 Exhibit I)Filed In Associated Cases: 1:00-cv-01898-SAS-DCF, 1:07-cv-10470-SAS, 1:14-cv-01014-SAS(Walsh, Michael)

EXHIBIT C

Donald M. Sitton

FOR THE SOUTHERN DISTRICT OF NEW YORK
IN RE: METHYL TERTIARY
BUTYL ETHER ("MT
PRODUCTS LIABILI
LITIGATION

MASTER FI
NO. 1:00-1898
M21-88
MDL 1358(SAS)

This Document Relates to:
COMMONWEALTH OF PUERTO
RICO, ET AL.
PLAINTIFF,

CASE NO. 07-CIV-I0470
(SAS)

VS.
SHELL OIL CO., ET AL.,
DEFENDANTS.

DEPOSITION OF
DONALD M. SITTON
SEPTEMBER 5, 2013
VOLUME 1
Called as a witness by counsel for the
Plaintiffs, taken before Dorothy A. Rull, CSR, CRR,
a Certified Shorthand Reporter and Notary Public In
and for the State of Texas, on the 5th day of
September, 2013, from 9:04 a.m. to 12:34 p.m., at
the law offices of Norton Rose Fulbright, 1301
McKinney, Suite 5100, Houston, Texas 77010, pursuant
to Notice and the Federal Rules of Civil Procedure.
Golkow Technologies, Inc. - 1.877.370.DEPS

Donald

M. Sitton
Page 26

1

2

Well -- okay.

Q.

through

Well,

a couple more.
Mixed xylenes.

3
4

that was brought

5

was that a product

6

chemical

7

plant,

mixed

9

into the plant

xylenes

purchase

it.

Was that something
from off island or

that you manufactured

We could -- if we could purchase

at a good price,

we could -- we could

But in the conversion

10

also produced

11

Q.

mixed

MTBE.

12

I -- I believe,

13

manufacture

at the

Core?

Both.

A.

8

let me just go

of naphtha,

you

xylenes.
It would be a correct

that the Core facility

statement,

did not

its own MTBE?

14

A.

That's

correct.

15

Q.

SO the purchase

16

source,

was that a function

17

facility?

of MTBE from whatever
of anybody

18

A.

Not that I recall.

19

Q.

So, again,

20

A.

I think Bartlesville

at the Core

21
22
23
24

that would be Bartlesville?
had more to do with

purchasing.
Q.

Now, would

were the number
A.

Golkow

it be fair to say that you

2 guy?

Yes.
Technologies,

Inc. - 1.877.370.DEPS

Donald

M.

Sitton
Page 40

1

Q.

And then Bartlesville

2

that product

3

A.

Correct.

4

Q.

-- to wherever

5

A.

Correct.

6

Q.

arranged

to have

shipped

the eventual

purchaser

--

was?
MS. FARLEY:

7

Objection.

Form.

Correct.

8

A.

9

BY MR. DEMA:
Now, the Core facility

also had a

10

Q.

11

loading

rack; right?

12

A.

Correct.

13

Q.

And were you In charge of -- or someone

14

below you in charge

15
16

A.

maintain

17

Q.

We

of maintaining

-- my maintenance

the loading

the loading
department

rack?

would

rack.

And how did you know what trucks

18

going to come up with lift tickets

19

were

to the loading

rack?

20

A.

I didn't.

21

Q.

Who did?

22

A.

Mr .

23

Q.

Do you know if Mr. Alberto

24

Sola.
Sola

today?
Golkow

Technologies,

Inc. - 1.877.370.DEPS

lS

alive