William Rapp being duly sworn deposes and says:

I live in Los Angeles County and have lived here for two years last past. I have been in the oil business most of the time since 1866. I know that for the proper working of oil wells it is essential that they should be pumped constantly and that no water should be allowed to accumulate in them. If water is allowed to remain in an oil well, it forces the oil back, and works a permanent injury to the well.

I know that oil can be kept in its crude state in tanks for a long time, ever two or three years, without material injury, and that it is the common practice in Pennsylvania to store oil in its crude state in large tanks and keep it waiting for the favorable action of the markets.

On several occasions, I have seen oil running down the creek to waste from the Pico wells and have seen it as far down as one mile below the wells. This was while the wells have been held by the California Star Oil Works Company.

William Rapp

June 17, 1878