W. H. Pedlar being duly sworn deposes and says:

I reside in Ventura. I commenced pumping oil wells in Pennsylvania in 1867 and worked there in drilling and pumping oil wells until in 1874. I came to California in 1874. I have also worked in the drilling of oil wells in California from May 1877 until January 1878. I know that a large proportion of the wells in Pennsylvania are pumped by heads and not continually and the idea that it is necessary to pump wells continuously has been abandoned. Long before I left Pennsylvania “oil savers” were universally used when drilling or deepening wells where a flow was expected, and the idea that an oil saver would obstruct or prevent the flow of oil or gas, is preposterous, and could have only been stated by some one who was grossly ignorant of the business, or who intended to willfully misrepresent the facts.

I know the C. A. Mentry has the reputation of being a first class driller and operator of oil wells. I have no interest in this suit, and am not the employ of any of the parties thereto.

W. H. Pedlar

July 15, 1878