C.G. Barclay being duly sworn deposes and says:

I reside in Los Angeles County and have resided here for four years. I have been engaged in the oil business in Pennsylvania for about four or five years. During that time, I had the control of at least thirty five producing wells.

To properly work a producing well that does not flow, it must be constantly pumped. Pumping keeps out the water and keeps the well free from oil, which increases the production. If oil is allowed to accumulate in wells, it will rise to a certain height and as long as it stands there, other oil which would flow into the well, if kept free, is forced out and flows off into other channels and is forever lost. Water in a well has a very injurious effect. Being heavier than the oil, it forces it off into other channels. Among oil experts, it is considered very obstructive, if not absolutely so, to cap or in any manner stop the flow of a flowing well.

It is the common practice among oil men to hold crude oil in tanks, sometimes for a long period, even for years, waiting for a market Crude oil can be so held, if properly tanked, for a long time without any material depreciation or loss.

At one time during my residence at the PA oil district, I was the superintendent of twenty nine (29) wells (producing wells). At other time owned and controlled both pumping and drilling wells to the number above mentioned.

Charles Barclay

June 19, 1878