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

Filing 4647

DECLARATION of Stephen Wolfe in Support re: 4644 MOTION to Dismiss the Second Amended Complaint.. Document filed by Lukoil Pan Americas, LLC..(Sorkin, Joseph)

UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF NEW YORK
___________________________________
In Re: Methyl Tertiary Butyl Ether (“MTBE”)
Products Liability Litigation

Master File No. 1:00 – 1898
MDL 1358
M21-88

____________________________________
This Document Relates To:
Commonwealth of Pennsylvania, et al. v. Exxon
Mobil Corp., et al.,
No. 1:14-CV-06228-VSB-DCF
____________________________________
DECLARATION OF STEPHEN WOLFE IN SUPPORT OF LUKOIL PAN AMERICAS
LLC’S MOTION TO DISMISS FOR LACK OF PERSONAL JURISDICTION
I, Stephen Wolfe, on oath, do depose and say as follows:
1.

My name is Stephen Wolfe and I submit this declaration in support of LUKOIL

Pan Americas LLC’s Motion to Dismiss for lack of personal jurisdiction. Unless otherwise
stated, I make the following statements based upon my own personal knowledge and review of
company records.
2.

My office address is 3200 Kirby Drive, Suite 900, Houston, Texas 77098.

3.

I have been employed by LUKOIL Pan Americas LLC (“LPA”) since August 3,

2020 and I am a Managing Director.
4.

LPA is a limited liability company organized under the laws of Delaware and has

its headquarters in Houston, Texas. LPA was formed in 2002.

5.

LPA is a trading company whose core business is buying and selling crude oil and

petroleum products such as heating oil, naphtha, gasoline, and gasoline components, typically in
large-volume or cargo-load transactions.
6.

In conducting its business, LPA does not itself use the product it buys and sells.

After LPA makes a sale, it does not control, and does not participate in, the buyer’s disposition of
the purchased crude oil or petroleum products. LPA typically does not know where the products
is sells are ultimately delivered, used, or consumed.
7.

I understand that the gasoline industry in the United States largely stopped using

methyl tertiary butyl ether (“MTBE”) in or around 2006.
8.

LPA has never owned or operated a refinery in Pennsylvania.

9.

To the best of my knowledge, at all relevant times, LPA did not own, operate, or

lease a petroleum products terminal in Pennsylvania.
10.

LPA has never owned, operated, leased, or branded any retail service stations in

Pennsylvania or anywhere else in the United States.
11.

LPA has never manufactured MTBE in Pennsylvania or anywhere in the United

12.

To the best of my knowledge, at all relevant times, LPA did not buy or sell pure

States.

(“neat”) MTBE in Pennsylvania, nor did LPA blend MTBE into gasoline in Pennsylvania.
13.

LPA does not maintain offices, employees, or agents in Pennsylvania.

14.

LPA does not own property in Pennsylvania.

15.

LPA is a subsidiary of LITASCO SA. LPA has never held any interest in and does

not control any other LUKOIL entity, including but not limited to PJSC LUKOIL (fka “OAO
LUKOIL”), LUKOIL Americas Corporation (“LAC”), LUKOIL North America LLC (“LNA”),

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