Sanford Lyon, being duly sworn, deposes and says:

I reside in the vicinity of the Pico oil wells. In this county, have lived there for six or seven years last past. I am now, and have been for more than two years last past, operating an oil well on the Pico claim No 1. Within the last year, I have frequently seen oil running to waste from what is known as the Pico wells, have several times seen it running it to waste as far as three and a half miles below the wells, and on one or more occasions, have seen it running to waste as far as seven miles below. During the time the California Star Oil Works Co. has had possession and control of the Pico wells. I have frequently seen the oil from those wells running to waste in considerable quantities. I have been at the Pico wells very often and in about the month of January of this year, was there when the oil was running to waste and into the creek. At that time C.A. Mentry and L.C. Bently, who were in the employ of the California Star Oil Works Co, told me that they had to let it run to waste because they did not have sufficient tankage to hold it. I know that the wells were not pumped constantly and said Bently, about the latter part of December last, told me that they did not pump them regularly because they did not have sufficient tanks to hold their oil. I know from my own experience received from working my own well on Pico claim No 1, that for the proper working of the wells, it is essential that they should be constantly pumped and that water should not be allowed to accumulate in them. If water is allowed to accumulate in the wells, it, being heavier than oil, necessarily forces the oil back and drives it elsewhere and works a permanent injury to the well. I know from my own experience that if crude oil is properly tanked and kept covered, it can be kept for a long time without any deterioration or injury.

I know J.B. Morrison. He is and at the time next herein after stated, was in charge of the refinery of the Cal. Star Oil Works Co. at Andrew’s Station. About ten months ago I had a conversation with Morrison in which he told me that he thought that the Pico well No 4 was then yielding about sixty barrels of oil per day, but that if it was properly worked, he thought it would produce at least one hundred barrels per day. That, in his opinion, by tubing and working said well to its full capacity, it would produce at least that amount. Something over one year ago, I was at the Pico wells in the house of Mentry and heard a noise, something like an explosion. I asked Mentry what it was. He said it was well No 1. She is flowing again. We went out and the oil was running over and running away into the creek. The well was plugged up and the plug was forced out. On another occasion about two years ago, I went up to the wells with F.B. Taylor, and others, and Pico well No 2 was plugged up. Mr. Taylor said he wanted to see some oil. One of the employees of the Co, I think Mentry, knocked the plug out, and a column of oil rushed up twenty feet above the ground between five and six inches in diameter, and flowed off into the creek. They afterwards plugged it up again while still flowing.

Mentry was absent in San Francisco some eight or ten days. While he was gone, there was no one at the wells but Bently, except a Chinese cook. Bently had sole charge of the wells during Mentry’s absence.

Sanford Lyon

June 17, 1878