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The Plaintiffs’ Steering Committee initially sought to depose Lord Browne during the Summer of 2006. In August 2006, the Trial Court ruled that Plaintiff’s were entitled to take the deposition of Lord Browne and John Manzoni (BP’s head of refining) because they had met the “Apex” Standard required in Texas for deposing the CEO of a corporation. On the eve of trial, BP and the Steering Committee struck a deal to depose John Manzoni before trial and revisit the issue of deposing Lord Browne after the deposition.

The trial setting was eventually continued to a November setting and the issue of deposing Lord Browne was once again put before the Court in Oct. 2006. In October, the Court ruled once again that the Plaintiffs’ Steering Committee should be allowed to take the deposition of Lord Browne. This decision was immediately appealed by BP.

In February 2007, the First Court of Appeals ruled (without comment) that the deposition of Lord Browne could go forward. The Plaintiffs’ Steering Committee re-noticed Lord Browne’s deposition in order to take his deposition prior to the next BP trial setting. Once again BP promptly appealed this decision, this time asking for protection for the Texas Supreme Court.

8/28/2006–Hearing Transcript Concerning the Deposition of Lord Browne
Pages 52 through 64 cover the argument for the Court’s initial ruling that the Plaintiffs should be allowed to depose Lord Browne
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10/11/2006–Hearing Transcript Concerning the Deposition of Lord Browne
Pages 13 through 33 cover the argument for the Court’s reiteration of its ruling that the Plaintiffs should be allowed to depose Lord Browne
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10/11/2006–ORDER: Denying BP’s Motion for Protection
The Court orders the Deposition of Lord Browne to proceed.
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2/9/2007–Memorandum Opinion from the First District Court of Appeals
The First District Court of Appeals ruled (without comment) to deny the BP’s petition for mandamus and vacated their prior order staying the deposition of Lord Browne.
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2/13/2007 Plaintiffs’ Notice of Intention to Take the Deposition of Lord Browne of Madingley Plaintiffs set the deposition of Lord Browne for February 23, 2007.
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BP’s Petition for Writ of Mandamus protecting Lord Browne from deposition also included a request that the Court stay the deposition until they issues had been reviewed by the Court. BP filed numerous documents attempting to prevent or delay Lord Browne’s deposition until after the February 26 trial setting. In addition to BP’s filings, an amicus brief was filed on behalf of several other oil and gas companies, including Exxon Mobil, which supported BP’s position that their CEO should not be deposed.

On February 22, 2007, the Texas Supreme Court stayed the deposition of Lord Browne at literally the 11th hour (London time) the night before it was to go forward. The Court also requested an expedited briefing schedule and BP has already filed their brief on the issues.

The Plaintiffs’ Steering Committees Brief on the Issues is due on March 12, 2007. After that BP will have one final opportunity to respond in writing on March 15, 2007. Once all of the briefs have been filed Supreme Court may make their decision based on the merits of the briefs or they may request oral arguments.

2/14/2007—BP’s Petition for Writ of Mandamus and Emergency Motion to Stay the Deposition
BP asks the Texas Supreme Court to deny the Plaintiff’s an opportunity to depose Lord Browne. BP also asked the Supreme Court to delay the deposition until after the next trial setting.
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2/15/2007—Plaintiffs’ Response to Petition for Writ of Mandamus
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2/15/2007—Plaintiffs’ Response to BP’s Emergency Motion to Stay the Deposition
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2/16/2007—BP’s Reply to Plaintiffs’ Response to Petition for Writ of Mandamus
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2/16/2007—BP’s Reply to Plaintiffs’ Response to BP’s Emergency Motion to Stay the Deposition
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2/14/2007—Brief of Amici Curiae Texas Chemical Council, Texas Oil and Gas Association, Texas Association of Manufacturers, Texas Association of Business, and Exxon Mobil Corporation in Support of Petition for Writ of Mandamus filed by Bp Products North America, Inc.
Exxon Mobil and several corporate associations file a friend of the court brief in support of BP’s position.
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2/22/2007—ORDER: Granting BP’s Request for an Emergency Stay of the Deposition
The Supreme Court grants a stay of the deposition just hours before it was to go forward.
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3/5/2007—BP’s Brief on the Merits
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The Plaintiffs’ Steering Committees Brief on the Issues is due on March 12, 2007. That Brief will be posted here when it has been filed along with further evidence supporting Plaintiffs’ contention that Lord Browne’s role causing and covering up the Texas City Explosion give him “unique and superior knowledge” of the facts as required by Texas “Apex” rules.

There are several areas major topic areas which are vital to the Plaintiffs’ case against BP…

The first and most important of these issues is his role in the cost cuttings that eventually led to the explosion. Secondly, it appears that Lord Browne recognized the safety problems at Texas City long before the explosion because he reviewed their safety data independent of the other 17 BP refineries worldwide. Finally, even after the steering committee agreed to wait and take a abridged deposition of Lord Browne, he began to further inject himself into the case by commenting about the specific causes of the explosion at Texas City.

10/1/1999– Texas City Business Unit Business Strategy
In 1999, Lord Browne and his senior management team ordered a 25% cost cut at all BP refineries worldwide. The remaining members of his senior management team have been replaced leaving Lord Browne as the only person who can explain the rational behind these cuts.
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2/25/2003– E-mail with Quote from Rick Hale (former Texas City Plant Manager)
Buried among the millions of pages BP produced, the Plaintiffs’ Attorneys uncovered a document that says, “Lord Browne looks at the [Texas City Refinery Safety] data separately each and every month.”
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1/16/2007– Baker Panel Conference Call
Lord Browne has finally said that “BP gets it” and he “gets it too” The question is, “What exactly does BP get?” and “Why did it take nearly two years for them to ‘get it’?”
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