Pearson v. Colt Oilfield Services, LLC et al

Western District of Texas, txwd-5:2018-cv-01029

Exhibit D-1

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IN THE UNITED STATES DISTRICT COURT FOR THE WESTERN DISTRICT OF TEXAS SAN ANTONIO DIVISION DOUGLAS PEARSON, JAMES ADKINS, S and on all others similarly situated, PLAINTIFFS, V. con con con una concom CIVIL ACTION 5: 18 - CV - 01029 - OLG JURY TRIAL DEMANDED COLT OILFIELD SERVICES, LLC, AND ROY (EDDIE AGUILAR, DEFENDANTS. DECLARATION OF EDDIE AGUILAR I, Eddie Aguilar, declare as follows: I have personal knowledge of the following facts and, if called as a witness, I would testify competently thereto under oath. O Wer am 2. I was the owner and managing member of Colt Oilfield Services, LLC ("Colt") . I am familiar with and have access to employee information and employee files for Colt. 3. Generally, Colt's business consists of providing customers with the delivery and operation of various oilfield equipment at customer well sites. 4. Operations are concentrated in a number of states including, but not limited to Louisiana, New Mexico and Texas. Colt's operations are managed locally by managers and supervisors, in the various locations in which Colt conducts business, who have autonomy in running operations. 6. Due to the various needs of Colt's customers, workers ' hours vary depending on the geographic location. 7. I have reviewed the relevant information and / or records for Douglas Pearson and James Adkins. EXHIBIT exhibitsticker. com D - 1 Douglas Pearson and James Adkins worked at well sites in the following locations in Louisiana: • Bienville Parish, Louisiana; • Bossier Parish, Louisiana; • Caddo Parish, Louisiana; • De Soto Parish, Louisiana; • Red River Parish, Louisiana; and • Webster Parish, Louisiana. These were the only sites where Colt provided services in Louisiana. James Adkins worked at a well site in New Mexico. That was the only location where Colt provided services in New Mexico. 10. Douglas Pearson and James Adkins worked at well sites in East Texas and / or West " SO Texas. Colt provided services in other parts of the State of Texas as well. 11. I declare under penalty of perjury that the foregoing is true and correct (28U.S. C. 1746) . Stela e EDDIE AGUILAR 12 - 20 - 18 DATE