E. F. Weed being duly sworn deposes and says:

I reside in Los Angeles County near the Pico oil claim, and have done so since March 5th 1877. I resided in Pennsylvania from 1864, up to the time I came to California. Since 1864, I have been engaged exclusively in drilling and operating oil wells. I have pumped and drilled over twenty wells and have operated over thirty, and nearer fifty than thirty.

I have observed the operation of the Pico oil wells at different times since last March. I noticed particularly well No 4, which is not tubed. Had it been tubed, as it should be, it would, in my judgment, have produced twice as much as it has been producing since I have known it. I state this as an expert from my observation of like wells in the state of Pennsylvania. Wells there which not tubed, produced very little, or nothing. After tubing, have become good wells.

The wells which are pumped as I have observed, have not been pumped regularly or constantly. This by the most experienced oil men, is considered bad management for the reason that when idle water collects in the wells and drives the oil to other and different outlets, and sometimes destroys the flow altogether. The wells must be kept free from water and the allowing of water to collect forces the oil back and injures and sometimes destroys the well as an oil producing well. It is the universal rule among oil men to keep the wells exhausted of water regardless of the quantity of oil being pumped in order to make the well profitable as an oil producing well. When the well fails to produce sufficient oil, to compensate for its continuous work, in exhausting the water, oil operators torpedo the well and then if it fails to produce sufficiently to compensate for its continuous work, the well is generally abandoned.

All the Pico oil wells show a sufficient supply, in my estimation, to justify their continuous pumping and such pumping, in my judgment, is necessary for the full production of oil there from. I think all of those wells with proper work as I have above described, that is by continuous pumping, would produce double the quantity they are now producing. With constant working and pumping, the oil produced would be of a lighter and therefore of a more valuable quality than when it is allowed to accumulate in the heads and pumped at intervals with days intervening.

In Pennsylvania, oil operators frequently accumulate oil in tanks and keep it in that state for years, waiting for the condition of the market. I have known from two to three million barrels of crude kept in tanks for periods of from two to three years, and so held for the market. During that time it would not decrease more than ten per cent, in my judgment, in quantity. In quality, it would be as valuable, per barrel, at the end of that, as when tanked, if properly tanked. I have been informed, and believe to be true, that there are now about 4,000,000 barrels in the crude state in tanks in the state of Pennsylvania. I do not think that the difference in climate between California and that state would make much, if any, difference in the value of the oil when so tanked, and that difference is not in the quality, but in the quantity of the oil.

I have seen the oil running to waste about a quarter of a mile below the wells held by the California Star Oil Works Co., and I do not think that that oil could have come from any other wells than those held by that company. The soil through which it came was sandy and a large quantity of oil must have seeped through before any of it got to where I saw it.

In Pennsylvania in 1872, the oil men shut down their wells for thirty days, and stopped producing for that time, because for the want of a market for their oil, which action, on their part, proved a very great damage to wells and always after that they worked the wells to their full capacity and tanked the crude oil and thus kept it until there was a market.

E. F. Weed

June 17, 1878