A.L. McPherson being duly sworn deposes and says:

I reside in the vicinity of the Pico oil wells in Los Angeles County and have resided there for two years and a half last past. In 1865, I first went to the oil regions of Pennsylvania, stayed there for several months, then went back again in 1868, and was there in the oil business till 1873, operating oil wells and as superintendant of oil companies. My experience in the oil business was extensive.

I know how an oil well should be operated. An oil well should be pumped steadily in a new territory, especially where there is water accompanying the oil. If water is allowed to accumulate in a well, being heavier than the oil, it will drive the oil back, and work a permanent injury to the well. This would be so more especially in the Pico oil wells, for the reason that the rocks in said district are standing on their edges and filled with seams, thus allowing numerous outlets to any given vein.

In the case of a flowing well, if the well is plugged or capped, it necessarily works material injury to the well, and is apt to destroy it. The flow of the oil being suppressed, the oil will find an outlet elsewhere. In Pennsylvania, I have known flowing wells to be capped and when the caps were taken off, the oil would not flow, nor could any be pumped from said well. There was no oil in the well, it having found outlets elsewhere, and even after drilling and torpedoing the well, no oil could be found.

I know that in Pennsylvania, a great many oil men tank their crude oil and keep it in a crude state in tanks awaiting the favorable action of the market, and that it is the common custom of the oil men to so hold their oil over sometimes for two or three years. This course works no material injury to the oil.

I have been frequently to the Pico oil wells and to their vicinity for two years past. I have been engaged at the McPherson well, which is located about 2000 feet from the Pico wells. During that time I have frequently been to the top of the mountain from which I could plainly see the Pico wells in order to see whether they pumped them regularly. I never but once saw them pumping and on that occasion well no 1.

I have frequently seen the oil running to waste from the Pico well, and have seen it running off as far as seven miles below the wells. This oil was running off in the creek and could have come from no other source than the Pico oil wells. I have also seen it running out of the Star Oil Co’s receiving tank across the road, into the creek, on one occasion.

About two years ago I saw well No 2 plugged with a pine plug. I know that the California Star Oil Works Co. has not sufficient tankage to hold the oil produced by the Pico wells, and at one time we let them have a two hundred and fifty barrel tank of ours, which they used for about two months.

In my judgment, the Pico wells, by being properly worked, could have been made to yield double the quantity of oil that they have produced, but from the fact that the wells have not been properly worked, I do not thing they can now be made to yield what they would have yielded if they had been properly worked.

A well should be pumped day and night in order to keep it clear of water, for the accumulation of water will injure and really destroy an oil well. I am informed, and believe and so state, that the California Star Oil Works Company have during the time they have held possession of the Pico wells, shipped crude oil from those wells to Ventura by wagon. In Pennsylvania, the most experienced oil men consider that when a well is not pumped, it is worse than so much time lost, for it is a permanent injury to the well, the oil being forced elsewhere. I never knew or heard of the Pico wells being worked or pumped at night during the time the California Star Oil Works Company has had control of them. I knew nearly all of the large oil companies and oil men in Pennsylvania. I never heard that C. A. Mentry was on operator or oil wells there and from my observation of the working of the Pico oil wells, I state that in my opinion, he does not understand how to operate a producing oil well. Drilling and operating wells are two entirely different things. A man may understand drilling a well thoroughly and know nothing about operating one, and vice versa.

A.L. McPherson

June 18, 1878