Joseph S. Taylor being first duly sworn deposes and says:

I am, and have been since the organization of the defendant corporation, secretary thereof and have attended every meeting held by the board of directors except one, and I have carefully examined the minutes of that meeting. No demand of any kind whatever has been made upon me personally or as secretary of said company of said Beale and Baker, and no demand has been made upon said board of directors of said company nor, so far as I have personal knowledge, upon anyone, and no paper or notice ever served on affiant except the notice hereto attached, which was sent on the _ day of _ 187_ [not filled out on affidavit].

I know that it has been the intention of the managers of said company to work said wells in good faith and in a workmanlike and proper manner and not their intention to check or interfere with the flow of oil there from, or to injure said wells, and do not believe the same has been done and I never heard any complaint by anyone or any indication that the said wells were not being worked in a workmanlike manner or that there was any way that the company, or its agents, had been derelict in any aspect in regard to said wells until the service of said notice upon me.

Joseph S. Taylor

June 8, 1878