George Fessler being duly sworn deposes and says:

I reside in Ventura. I first went in the oil business in Pennsylvania in December 1859 and there drilled the third well ever put down in Pennsylvania. From that time, I was almost constantly actively engaged in drilling and operating oil wells and handling and tanking oil in Pennsylvania, Ohio, and Canada until 1874. I then quit the business and commenced drilling artesian wells until October 1877 when I came to California and commenced drilling wells in Ventura County on Sulpher Mountain.

I doubt much if there is a man in the country who has personally drilled as many feet of oil wells as I have I consider my self an expert in the business of drilling, pumping, and operating of oil wells and handling oil and tanking the same. I think that, at this time, that at least nine out of ten wells in Pennsylvania are pumped by heads or at intervals. Since it has been customary to use casing to shut off surface water, the practice of pumping continually and upon a vacuum has been abandoned and the rule now is simply to pump at intervals ranging according to the nature of the well, until the flow is exhausted or as it is called, a vacuum is produced and in various instances my experience has taught me that it is injurious to pump wells upon a vacuum and that less oil is obtained than when pumped by heads. Pumping on a vacuum in some wells creates what is known as B. S. oil, which is a heavy thick substance and clogs the walls of a well impeding the flow of oil through the cavities and also, as I believe, in other instances causes paraffin or other foreign substances to form in the rock. Adams, Thayer, and company’s wells in Ventura County, are pumped by heads as is every pumping well I know of in California.

Oil savers are now universally used where first class machinery is employed, in drilling or deepening wells, where a flow is expected, and the idea that such a device would obstruct the flow of oil is more than absurd and wooden plugs driven in the casing with pipe outlets are also used. No one acquainted with the business or possessing any knowledge on the subject would ever imagine that these devices obstructed, hindered, or impeded the flow of a well or in any way injured it.

Since I have been in California, I have most of the time been working for Adams, Thayer, and Company, and had charge of their wells. The evaporation of the California oil as compared with the Pennsylvania oil is very great, and from actual tests made in tanking oil as produced at the wells on Sulphur Mountain I state positively that in the principal wells of Adams, Thayer and Company which produced twenty-eight barrels per week, the evaporation was seven barrels, or twenty-five per cent, in the first week after being tanked. This evaporation seemed almost incredible, but I tested it so often that I know I am not mistaken.

It would be difficult for a man whose experience was limited to Pennsylvania to credit these statements and I would scarcely have believed it without actual tests. I would not from what I know of the business furnish tankage for any oil produced in California if I had to hold it tanked for six months, as the oil at the expiration of six months would not be worth the cost of tankage.

I am not interested in this litigation and have never been employed by any of the parties hereto.

George Fessler

July 15, 1878