Party Statement: PLEASANT, CHRISTOPHER vs. TRANSOCEAN DRILLING (U S A) INC

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                                MASTER FILE NO. 2022-36264

  E    URRICANE   ETA     ITIGATION
                                                                          HE   ISTRICT    OURT
                22-0300
                                                                            UDICIAL      ISTRICT
HIS    OCUMENT         ELATES    TO     LL
ASES                                                                   ARRIS   OUNTY       EXAS



                                         CAUSE NO. 2020-79221

HRISTOPHER LEASANT                               §                        HE   ISTRICT    OURT
                                                 §
RANSOCEAN      FFSHORE          EEPWATER         §                          UDICIAL      ISTRICT
RILLING        T AL                              §
                                                                       ARRIS   OUNTY       EXAS



                     DECLARATION OF SHAHMEER HALEPOTA
                         IN SUPPORT OF TRANSOCEAN’S
                    MOTION FOR PARTIAL SUMMARY JUDGMENT
                  REGARDING PLAINTIFF CHRISTOPHER PLEASANT’S
                         DEEPWATER HORIZON RELEASE


        My name is Shahmeer Halepota. My work address is 1221 McKinney St., Suite 2500,

        Houston, Texas 77010. I am over the age of 18 years, of sound mind, have never been

        convicted of a felony, and competent to make this declaration. I aver under oath and

        threat of perjury that the statements made in this Declaration are true and correct and

        within my personal knowledge.

        I am attorney licensed to practice law in the State of Texas. I am a counsel of record

        for Defendants Transocean Offshore Deepwater Drilling Inc., Triton Voyager Asset Leasing

        GmbH, and Triton Voyager asset Leasing GmbH, Asgard US (collectively “Transocean”) in

        this matter.

        Exhibit A attached to Transocean’s Motion for Partial Summary Judgment Regarding
           Plaintiff Christopher Pleasant’s Deepwater Horizon Release (“the Motion”) is a true

           and correct copy of the Release Agreement signed by Mr. Pleasant as maintained in

           Transocean’s files.

           Exhibit B attached to Transocean’s Motion is a true and correct copy of excerpts from

           the deposition transcript of Christopher Pleasant taken on November 30, 2021.

           Exhibit C attached to Transocean’s Motion is a true and correct copy of Exhibit 6 to

           Christopher Pleasant’s Deposition taken on November 30, 2021.



I declare under penalty of perjury that the foregoing is true and correct.

EXECUTED this the 12th day of October, 2023.



                                              _/s/ Shahmeer Halepota
                                              Shahmeer Halepota




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