This affiant Charles McTagart being first duly sworn says:

I have been in the oil regions at Pennsylvania working at and assisting in drilling wells, handling oil, and business connected therewith for about five years. I commenced work for said defendant corporation at the Pico oil wells in May, 1876, and continued to November, 1877, and have also worked there some of the time this year.

I lived on the premises while working there and remained during the time almost constantly on the same assisting in working and operating the wells and doing other work on the premises. I knew the manner in which the wells were used and operated and at no time was the flow from the wells checked or obstructed or suppressed, nor have I ever seen anything done with them which I think would in the slightest degree injure such wells or lessen the flow of oil. On the other hand, all and each of the wells were used, handled, and operated in the proper skillful and workmanlike manner.

I never heard any complaints by anyone with respect to the management and operation of said wells. The pumping of the wells which required pumping was done by heads or at intervals. My experience in Pennsylvania and with the Pico wells has demonstrated that this is the proper course with wells of capacity of these and I know that this course was adopted in Pennsylvania. After pumping a while in the Pico pumping wells, they would become dry and but little oil could be obtained until after an interval when the oil would accumulate, ready to be pumped out. The wells were always during the time I was there sufficiently pumped.

Mr. Mentry, the superintendant, is unusually skillful and competent in the drilling and operation of oil wells and I do not think there is anyone in California better qualified to drill or operate wells. He was during all the time I worked there attentive to his business and, I am satisfied, has done all in his power to improve and enhance the value of the property, and I feel no hesitation in stating that the property has, in my opinion, been managed as well as it could under the circumstances.

Charles McTagart

June 10, 1878