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 I

Hector Antonio Marin Diaz

Page 205
IN THE UNITED STATES DISTRICT COURT.
FOR THE SOUTHERN DISTRICT OF NEW YORK
IN RE: METHYL TERTIARY
BUTYL ETHER ("MTBE)
PRODUCTS
LIABILITY LITIGATION

COMMONWEALTH OF PUERTO
RICO, ET AL.
PLAINTIFF,

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

CASE NO. 07-CIV-10470
(SAS)

VS.
SHELL OIL CO., ET AL.,
DEFENDANTS.
DEPOSITION OF
CONOCOPHILLIPS COMPANY AND CHEVRON PHILLIPS CHEMICAL
PUERTO RICO CORE, LLC THROUGH
HECTOR ANTONIO MARIN DIAZ
AUGUST 22, 2013
VOLUME 2
Called as a witness by counsel for the
Plaintiffs, taken before Dorothy A. Rull, Certified
Realtime Reporter and Notary Public in and for the
State of Texas, on the 22nd day of August, 2013,
from 9:13 a.m. to 5:29 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

Hector

Antonio

Marin

Diaz
Page

1

transaction,

2

there

3

no.

and this
Q.

I have

seen

that

reference

one.

Okay.

And the reference

4

see, are you aware

5

Oil and Phillips

that

of any agreement

Puerto

6

A.

In general

7

Q.

Well,

8

A.

At least

Q.

Okay.

9

only

357

Rico

start

here,

between

Tauber

Core?

or what

let's

you do

is referenced
with

here?

here.

it doesn't

reference

that.

10

And

are you aware

11

agreement

between

-- any agreement

12

agreement

between

Phillips

13

generally

of an

Tauber?
A.

14
15

don't

17

In the documents

have
Q.

16
Page

Puerto

that

Rico

Core

and

I've reviewed,

4, Response

If we could

go Exhibit

12,

7.
Between

the years

19

A.

Excuse

20

Q.

Exhibit

12, Page

21

A.

Page

Response

7.

22

Q.

Okay.

1990 and 2000

4.

23
24

2000.

me one second.

4,

Between

On Exhibit

the years

Golkow

Correct.
Technologies,

Yes.
Inc.

- 1.877.370.DEPS

--

12?

of 1990 and

Do you see that?
A.

I

information.

Okay.

18

that

-- supply

Hector

Antonio

Marin

Diaz
Page

1
2

Q.
involving

3
4

Are

you aware

Tauber

during

of any transactions

that time period?

In that period

A.

358

of time,

their

name

lS

not here.

5

Okay.

Q.

6

different

7

That's

-- that's

not -- that's

question.

8
9

Are
between

Phillips

A.

10

you aware

and Tauber

Yes.

Thank

Q.

that

time period?

now.
have

any knowledge

of

you.

MR. WALSH:

14

Nothing

further.

EXAMINATION

15
BY MR.

DILLARD:

Q.

17
18

during

I don't

my

that.

13

16

answering

of any transactions

I understood
No.

11
12

not exactly

a

you,

Mr. Marin,

I have

a few questions

for

Slr.
Yesterday

19
20

about

a gasoline

21

documents

made

as house

you were

at Core

brand

23

A.

Yes.

24

Q.

Have

Golkow

referred

questions

to in

gasoline.

Do you recall

22

asked

that?

Correct.
you done

Technologies,

additional

Inc.

work,

as the

- 1.877.370.DEPS