George C Higgins being first duly sworn deposes and says:

In the year 1865, I was operating in oil wells in Pennsylvania and was engaged in that business for over nine years; that during said time I was interested in a number of wells, both pumping and flowing and also drilled a number of wells and operated these; that I devoted much time and attention to drilling oil wells and the operation of the same, and to oil property generally; and consider myself thoroughly posted with regards to drilling oil wells and working and operating the same and the management of oil generally; that I have visited the oil wells and the premises described in the complaint known as the Pico oil wells and have seen the mode and manner in which they were being operated and worked by the superintendent C. A. Mentry; and that the same were being worked and operated in a workmanlike and skillful manner.

I know C. A. Mentry and that he had an unusually good reputation in Pennsylvania as a skillful driller and operator of oil wells, and from what I know of him and have observed of his works, I believe him to be the most competent man to have charge of the drilling and working and operation of oil wells now in the State of California or on the coast, and should have the greatest confidence in his judgment of oil wells and oil property.

I have no interest in any of the matters in issue in this suit.

George C. Higgins
June 8, 1878