J. J. Groves being duly sworn deposes and says:

That he has been engaged in the business of drilling and operation oil wells for the last 12 years in the Pennsylvania oil regions. That he has visited and inspected the San Fernando oil region. That he is now holding and operation certain oil lands and leases in the county of Ventura. That in February 1878 he visited and inspected the Pico oil claim and its wells. That well No 4 could not be plugged up and held plugged, the pressure being so great, unless the oil be allowed to escape through the lead pipes in the side. That the incident stated by Lyon in his affidavit as to well No 2 must have been the knocking out of the plug in the “oil saver” as stated in the affidavit of D.C. Scott.

That the oils of California, and particularly San Fernando and other Southern California oils, are much heavier than the Eastern oils. That Pennsylvania oils run from 45 to 48 degrees in gravity while the Southern California oils run from 28 to 41 degrees, the maximum of profit being from 43 to 45 degrees. An oil which is below 43 degrees loses every day in gravity and consequently in value that it is tanked. Thence the California oils, when 41 degrees is the maximum of gravity tankage for a day, impairs the value and tankage for 6 months, renders the oil as an illuminating oil almost valueless. That proper and profitable way to work the oils being to refine as soon as produced.

J. J. Groves

July 2, 1878