M. S. Finnall being duly sworn deposes and says:

I have resided in California since 1874 and in Los Angeles County about eighteen months. About 1863 I went to the oil regions of Pennsylvania and remained there most of the time until I came to California in 1874. I have had large experience in the oil business in superintending the boring and drilling of wells, and producing of oil. When I first went to the oil region, I had charge of about twenty wells, and we increased the number to about eighty.

I know how an oil well should be worked. Wells that are pumped should be pumped regularly and constantly day and night. If a well is shut down for a short time, even in order to change tubing or change the valves say for two or three hours, it is an injury to the well and if continued for any length of time, would result in a serious and permanent injury. For this reason with us, even when oil was so low that it would not pay the expenses of pumping, we continued to pump our wells constantly to prevent destroying the wells.

If a well is constantly pumped, it will be kept free of water and the flow of oil will be unobstructed, whereas if you fail to pump, the water accumulates and forces the oil back into other outlets, and the flow of the oil is directed to other channels and often entirely lost to the well. If a flowing well is plugged, or capped, it necessarily works a permanent and serious injury to the well.

In Pennsylvania, I have seen the oil from flowing wells running to waste where there was not sufficient tankage because the oil men preferred to let the oil go to waste than to plug the wells. I know that in Pennsylvania, crude oil is very frequently stored in tanks and kept in that way for a long time awaiting the action of the market. The keeping of crude oil in this manner does not result in any loss in the quality of the oil.

M. S. Finnall

June 18, 1878