Isaac E. Blake being first duly sworn deposes and says:

I am now a resident of the City and County of San Francisco and have been for about one year last past. During the year 1865 commenced operating in oil and oil wells in the state of Pennsylvania and have been engaged in the oil business ever since. I have been interested in wells ever since 1865 and have had much to do with the drilling and working of many oil wells, being a practical driller and also being foreman in charge of operating wells, both flowing and pumping. A large number of wells have been drilled under my personal supervision numbering several hundred and in this way, as well as in locating and operating oil wells, I have had very extensive experience and regard myself as an expert in the business. I have operated and had charge of wells of every kind from small pumping wells to the largest flowing wells and, in fact, was foreman for one year of the company at the time having the largest number producing wells in Pennsylvania.

In the month of November 1877, I made a number of visits to the Pico claim mentioned in the complaint in this action. I went down from San Francisco to these claims for the purpose of examining them as an expert and ascertaining the value and character of the oil lands in California, and their mode of operation.

I made during this trip a number of visits to the oil wells in question, and gave the premises and each of the wells, their character and the manner and mode in which they were operated, special and very particular attention, and I am convinced and feel no hesitation in saying that said wells, and each of them, were then being, and had every appearance of having been before, operated in a workmanlike and proper manner, and that at that time all the machinery that was necessary was being used in a proper and workmanlike manner for, and in respect to, said wells, and I am satisfied that no injury of any kind could result, or had resulted, to the wells from the mode and manner in which they were, and had been, worked and operated, but think that they had been worked in the very best manner possible under all the circumstances.

I have known Mr. C. A. Mentry by reputation for 8 or 9 years last past, having heard of him as a practical driller and operator in wells often in Pennsylvania, and I know that his reputation there was first class, and that he was considered an unusually skillful driller and operator of oil wells and I have great confidence in his judgment as to the proper management and operation of wells and think that he and his judgment are to be trusted with respect to such matters.

I have also in the operation of oil and oil wells, had great experience in the preservation and tanking of oils, as well as the refining.

I am largely engaged and have been ever since my arrival in California in the oil business being General Superintendent, west of the Missouri River of the Continental Oil and Transportation Company and I know the state of the market for refined oil and crude petroleum on the Pacific Coast and especially in the state of California.

I don’t believe that the demand for crude petroleum exceeds 50 barrels per month for all purposes except the purposes of a refinery, and there are no parties engaged in the refinery business west of the Rocky Mountains except the California Star Oil Works Company and their refineries are two in number, one being situated near Andrew’s Station in Los Angeles Country and the other in Ventura County.

I am satisfied that after the local market of say, 50 barrels per month being the consumption on this Coast, is supplied, that outside of the refineries the balance of the oil would be of no actual value, as the actual cost of transporting crude petroleum from the Pico wells to a market where a sale could be found would be greatly more than the value of the crude petroleum at such market.

The only practical way of preserving the oil after it leaves the wells, before refining it, would be tanking it in the vicinity of the wells. I don’t think this tankage could be done for less than 75 cents to a dollar per barrel.

Oil, by reason of its peculiar nature, deteriorates rapidly when tanked, especially in a dry climate, the volatile portions of it being the most valuable, and this especially so with reference to the production of the Pico wells, as the oils are naturally heavy and the portions which would evaporate are the most valuable from the character of the oil. I think that if tanked, the crude oil would be reduced in value fully from 15 to 20 percent the first 30 days, and that it would continue to decrease in value until within 6 or 8 months it would not be worth anything for an illuminating oil, but could only be used for a lubricating oil, or for gas works, and in fact would not be of much value for such purposes, and as the demand for lubricating and gas oil is exceedingly limited on this Coast. I don’t think that the petroleum, after being tanked for six months, would be worth in the market 10 percent of what it was when it came out of the well; in fact, in the present state of the market and from the prospects ahead, I wouldn’t tank said oil and undertake to keep it in six months if it were given to me as a free gift. In addition to al this, there is a great risk of fire where oil is stored in large quantities.

I have no interest or connection with the Pico oil property or any issues in this suit, but in fact the corporation defendant is to some extent a competitor in trade on the Pacific Coast with the companies that I represent.

Isaac E. Blake

June 8, 1878