This affiant John Howe being duly sworn says:
I reside on my farm between the Pico wells and Andrew Station about four and a half miles from the wells. I am a constable and deputy sheriff. I made a contract and put my team and teamsters hauling oil for the California Star Oil Works Company from the tanks in the canyon at the end of the pipe line, in January last, and have hauled regularly when hauling was needed since that time. From January until March the rains were unusually heavy and as the wagon road to the refinery crosses the creek in the canyon very often, the high water would frequently wash out the crossings and render the road absolutely impassable for loaded wagons until the waters would recede and repairs could be made. There were also other places where by reason of the mire and mud a loaded wagon could not pass. During a part of said time it was impossible to haul loads.
I know that said company used every effort to get the oil hauled and sometimes at their urgent request my team would go up when less than half a load could be brought down. On one occasion I broke my wagon in trying to get through. I saw oil in the canyon in February and March last when it is claimed as I understand so much was wasted. I do not think there was more than a few barrels running away and at this time I saw a man whose name I understand was Smith, who had dammed the creek and was dipping the oil from the pool. He had two barrels and from all appearances I think he got about all that could have been gathered.
I have been at the Pico wells a number of times since C.A. Mentry has been in charge. I believe him to be an unusually careful and competent manager of oil wells. I have never seen anything indicating any waster or inattention. I know that he has a good reputation and he has certainly been much more successful in producing oil than any other man we have ever had in this district.
John Howe
July 13, 1878