H. A. Barclay being duly sworn reposes and says:

I have resided in Los Angeles County since about October 1873. I am an attorney at law, engages in the practice of my profession in the City of Los Angeles. I was engaged in the oil business in Pennsylvania in the vicinity of Parkers, Lansing, Armstrong Run, Millerstown, Foxburg, and the Clarion District, from about 1866 to the latter part of 1871.

During that time, I had under my charge as superintendent from two to five wells, all producing, and was also interested in drilling several wells, in which I was part owner. I was also engaged during the greater portion of that time in gauging oil – gauging the greater portion of the oil produced in that vicinity – for about two years and a half.

In working our own wells, we considered it absolutely necessary to keep them free from water and pumped clean, and to that end, were obliged to pump them constantly, as we found that water standing in the well injures their production and that those wells which had a small production had to be pumped frequently to produce to their full capacity. We pumped our wells constantly day and night which was the usual practice among the oil producers as it was found that those wells which requires pumping produced most when the oil was kept well pumped out. A great many small wells collected the oil in heads and the oil would only rise to a certain point in the well. When that point was reached, the pressure of the column of oil prevented the collection of any more oil until the head was pumped up.

In the case of flowing wells, it was considered very detrimental, if not absolutely destructive, to cap them or stop the flow in any way. It was so considered among oil experts. I am acquainted with the San Fernando Oil Regions in this county. I am interested to some extent there myself in various claims and have given some attention to the geological formation of that region extending from the Pico wells for about six miles south easterly, and from the general character of that region, the character of the rock and position of the strata, I should consider the presence of water in any wells there very detrimental, more so possible than in the Pennsylvania oil regions for the reason that the character of the rock in this oil region is more friable and softer than that of Pennsylvania.

I have gauged the most of the tanks of the Cal. Star Oil Works Co. at their wells and works and have examined the character of the oil. In my opinion, this oil can be kept in the crude state in tanks for a longer period than the Pennsylvania oil without much loss by evaporation for the reason that this oil is a great deal heavier and has less volatile properties than the Pennsylvania oil.

The usual custom in Pennsylvania among oil producers was to pump their tanks full and then have it pumped into large storage tanks of the various pipe line companies until such time as they were prepared to sell it.

H. A. Barclay

June 19, 1878