This affiant Michael Brannan being duly sworn says:

I have resided in the Pico Canyon and below the Pico oil wells about a quarter of a mile for three years past. I have worked some on the four wells operated by the California Star Oil Works Company and also on Sanford Lyon’s well and also on the roads leading up the canyon and I have never seen any large amount of oil wasting in the creek and believe that Mr. Mentry has taken the best possible care of the four wells under his charge and that avoidable waste of oil or any injury to the wells has been permitted, in fact, although I have seen in my life a number of superintendants over different kinds of work, I have never seen one more careful or more attentive or more competent than Mentry.

I have seen the plugs mentioned by Lyon and A.L. McPherson and also the plug with a strap mentioned by Loomis in their affidavits filed in this case for plaintiffs. The plug had a large pipe passing through it as an outlet and the thing Loomis speaks of in his affidavit was an oil saver having two outlets, any greenhorn with sense enough to keep out of the fire could see that the plug and oil saver had plenty of outlets for all the gas and oil, and in no way obstructed their flow.

I know that during the last rainy season the roads leading to the tanks constructed to hold the oil from the wells were rendered impassable for loaded teams and on several occasions, in fact, once or twice it was impassable for man to ride on horseback up the canyon in some places and I know that said company made unusual efforts to keep the roads in repair and to have the oil hauled away as it was produced.

Michael Brannan

July 11, 1878