xt70zp3vt865_275 https://exploreuk.uky.edu/dips/xt70zp3vt865/data/mets.xml https://exploreuk.uky.edu/dips/xt70zp3vt865/data/63m46.dao.xml unknown 14 Cubic Feet 31 boxes archival material 63m46 English University of Kentucky Copyright has not been assigned to the University of Kentucky.  Contact the Special Collections Research Center for information regarding rights and use of this collection. Harkins Family papers Mineral rights -- Kentucky -- Floyd County -- History. Law reports, digests, etc. -- Kentucky. Mining leases -- Kentucky -- Floyd County -- History. Practice of law -- Kentucky. Bankers -- Kentucky. Banks and banking -- Kentucky -- Prestonsburg. Coal trade -- Kentucky -- Floyd County -- History. Lawyers -- Kentucky. Moore, Kendall and Jay L. v. Pennegrade Oil and Gas Company and Louisville Gas and Electric Company [Part III] text Moore, Kendall and Jay L. v. Pennegrade Oil and Gas Company and Louisville Gas and Electric Company [Part III] 2016 https://exploreuk.uky.edu/dips/xt70zp3vt865/data/63m46/Box_25/Folder_7/6752.pdf 1920-1924 1924 1920-1924 section false xt70zp3vt865_275 xt70zp3vt865 of ninety pounds, on the question of iirhether or not ,
it would force the gas i‘rom the well into the plant

‘ oi the Louisvilie U-as s.- iilectrie Company at haytovmi .
and you said that you believes it would not 0'; 11:8 elf ‘

I with the present equipment they hate there? 1 WiBh r,
you “would explain what you meant. by that? ,
(Mei'endants obj acted

BY 32:-ti. nsi‘idilhb; 11' meter made any such query as to j‘

the Louisville Gas is '.sleetric {Jomranyo

f ‘ 151‘ ii: LAY: ‘i‘he Liiermagrade nil s: Gas -.)ompany6 than»
whatever it was. Go and take the Louisville Gas it:
electric Company's nrmie 01")? of it then-

nY Stu-ii haiiKINb': “ii/e are running our business. E
’ n. ‘she odxiipressors as 1 understand are too high to ‘
' take in the low pressure.

' how, is there a method known to modern operators ,
by which gas on a preseure of ninety pounds could be E;
.‘ drawn from the well. and eaten less, by the preper E
equipment? E' .
. In Yes. A.
3 Explain to the Jury what it is? ' E
. A lower compressor would take it. I ,
S: ii. how low a rock pressure would it take out of the E
v w 61 1? f
A- s‘ven ten pounds. ' . E‘ii

 . Ii" drawn or. that amount: of pressure, would it: be
regarded as marketable gas, ii drawn that way?
it would say so, ”fies. . ”
Before you were engaged in the. business of con-
i treating, :t’ori: "the drilling; oi‘ wells, were you also i
on actual driller and ”smoker at the wells yours eli‘?
I was -
How Iziany years? ,
be}? ten years.
t,» Then you Later part of your experien cc of twenty
y' years you have. been engaged in contracting?
[,.. Yea. ,
I. 'x' nursing; that. time have you also drilled?
fie Yet}.
Jamaal?» bXaNL-§.LL-L '
W Lr. Duncan, there. 18 no substantial change in ‘
the contract between you and Eir. White that was en-x
, tnoduced last. night and the one that was introduced
I’ byLr.1£ay this morning; was the re, except the price
‘. increased from $2.56 to $3.10 and some other little 2
things? ' ll
.11. I dont just mind now what. I think possibly i .
L had. to tube these wells in that first. contract at my _
'V own edpense, and there was one other thing as I re- .
" member was changed too. When I was to and through i

 L . the wand my contract, was completes} and 1219 well Was IV
“cubed at 1:931; expense, me furnishing-V: my equipmen? L
'.‘ at“ («I Specified price per day: ,Li
‘ ':L’ill yam please refer t9 this contract and.
V read that provigion relative "m “the? tubing 01" the
V well ’i‘i} the jury.

3315 5-5,. ‘1 Let the Jury hear it all.
' (‘.E‘he‘reupon the 3011111581 read to' the jury the entire
,VL cantractfi @0101 ed. in this $51.11 on pages 138~143 hereof)
V 3339's}, in yuncem, that is fine mmdified contract:
you rai‘m'red to last night as brewing been execu‘; ed ;IV':
b’fi‘ftwaefl the 'gjgzrties, and that is the same confract. _ ‘V
‘ and but-on “the same terizm and canditionzs flux-'3‘: you
drilled finesse two wells 0n the 1.. hours: tract?
a; V“. ;E; believe so.
LL I'VE; 'Xou fully complied yourself with all the terms
covenants and agreemental which you made and which 0 R
were set out in that wri t'ten contract which V‘V r. May
has read to the Jury.
L Yes . '
iv NOW. in Speaking of marketable gas, fell the Jury
whether or not the term ”marketable" as 50 applied,
doesn't refer and have reference to the (31 fferent.
uSes whi ch can he made 01' the gas by the people who
I hme drilled arid devalo-ed it, and the manner of
w V L . I» VI I r 4 I» I9 .

 . tranSpox-tatian m? the same:- which they have gvl’widad,
' dcesm‘ t that affect the marketability of ”the @128? '
lz'e‘hxrally so, Ties.
' 1321.6. if 2.: contract in 22:15:18 based upon ’rhs: cams»
ditioms relyztiv a lo the we 1min}; the producer of ' .‘.,
the‘: gas “mull; have for in mid ‘:Irzsr'rt was was #3th ‘
, i‘imt gas with :3: pressure under Iain ety pounds Could
‘ :.m’t L-:,- 11.5 ed with the facilities fhay "hm: previ‘r‘ged V v
”that gaS would Men not be: marketable. to the-i=1? wmliui it? I
f {321.3 in‘i‘i fi‘s obj eci' ed, the coups? 0v er~rul ed t.:
objectiona and plaintiffs except)
3301‘“ from “their point 93; vi 81?, of course. They f
‘ would 31 we- to make difi'egl‘en“; arrangements .
I 7. You have never been engaged in the transportafion
.. of gas at high pressure and for long distancea?
.1 - lief to any great extent.
- ‘ ”Io txrhzst extent, just tell us. .
- I put in about four or fiVe years in the production _
. end of the business and of course handled some gas
during; that time. It has been :2 number of years ago.
4,. how about the transportation end of the business?
.5 I“ I naver did from a practical point of View have
..: any experience in transportaticn. I
‘ '192‘ L . . 7
3;»..V' J~:_','.;.' . 4,, 13“.; _ . . gyms“. , ””2'” L 1 :.,_g:,“__».;:,:: W.“ .. .,. . V ‘4,; _ , V . , . W. 7‘ . . .V .V . .. ,

 iou don‘t know about the 71932113133. ems incident to the
treneoortotion of gas: for two or three hundred mil es,
and at high pres-sure?
.11» Juet only an idem 3:5 ' '
aheiwaupon the plaintiff introdeeed the Witeeee, V
4:. 33,, HELL; who being; firet duly sworn-3'3, testified as ,
follows, tan-wit:
13.32.919.11. Atile'tidY .1" 5.2-..L,,.§f;s.¥i¥l; _
1 1.. Your name is i: . 1i. Dyre’?
‘ 1‘1- “fess eir.
. 14° “that is your age, 12535.3;yre? ‘ '
I U i’ifty-six-v ashamed: to tell it.
‘.:het bueinese are you engaged in? .
‘ .' . in the 5215 business- not individuellya employee
of the corzrpanyh
- ‘~«..- With what company are you employed at the present
' time?
Tides iii]. and Gas Company.
. how long have you been engaged in the business of
devaloping; for oil and gas?
V .11.. “Hell, I couldn't Say orfhand. itineteen years I
‘ off and on, part of that line in the pipe line end,
last fiVe years in the field. '
f .‘3-93. . . ‘.

 ‘5’» ‘.th-‘i’ is your present fi‘C-S it ion vi t1: the. Lines 4311. (I
one. L.:-23:3 oommny‘!
Z ‘ n‘i elci :.:‘u'perin i and en t a ,,
; ' in whet i’i aid? 2
in the waxwer Creek: 32."); ”3,”, “right Essex/er»- also on ,
g .3; oi"? i“:v er , .
o .w oil. or gas 1‘3; aide oi" this country noise you >
eng:g reel. in wig-orgies; in? '
it i; work ed. ii tice ‘.::nez ii e1 (.3; for the Triple at; top ,-
:mzi ‘ir'nen 1 some me: ; Hie-i, mid wen i; t 9 work 1'01“ 4.3% ‘7‘
uizzmi a}: in 1.9.: i: t I
have you worked. in any {finer ii e163 oeSioes the
.‘: arr-ate oi 1:.entucky‘z"
e 1538 .
‘_' , . no 1: other i‘i ems? :
f, . eggs? virginie, . Louisiana, Texas, Oklahoma :
You Home lied actual “practical experience oi about
twenty five ye are in the 011 1’1 elde?
K . Y es .
no Ki eld Superintendent for the tides Oil and
’L;-as oompany in the neaver field, how long have you hem
actually engaged in met 1": eld. for than?
n- oinoo. the organization oi" the company.
q. About how long ago was that?

 I A. Well, 1 :.fi ret- urorked for the }:-..€:vyi:‘f‘o}‘;o {lee 11031377453337,
'. then the keystone Carbon Cor-many wee organieeé,
_ then if wee ofmgmg ed to Hie; hides Company, file-3f coho»
'V eolideted "the Keyfitone "3311“,}; the hides, out: tor the |
last 1' should say apyroximaiely six years l lime her; .‘
, entire airbe of the. field. " ,
V_ ;, NW, prior to the owning; oL' the carbon aozr'rz'oeuies
‘: into- the Beev er Field were you connected with some
: other oil company that operated in that field? 1
:1. ”Lies“
5 a“. “.;'J:‘.LO Wee that?
A. lieu Domain. ‘ :-
A l :,. Did you know fir. C- 13... 3113211201: in his lifetime? :3
I ' a. A' 3; euro did. I y
£1}. lDid you know tr. 3’ . Ii. Gel-Inlay?
A. Yes sir.
I believe you know lir. Tom Dimmick‘? fl
1’ A. Personally acquainted. '-
1 ‘5;- Preeent manager of the I._.ides Oil & Gas Company? '
Yea. - ' ,
How long have you been working or rather how many
years back was it when you first commenced your em-
ployment in the Beaver field vi th eithc one of these ,.
c ompani es? ' 1
.i A. 1900. That was the old gentleman himself, the
‘ +195“, _ - . o. .,.,

 { original pionaer in this country. ‘

L; a. As field manager $0? the Eidafi Gil and Gas SGMw

many, hwe you mar-+6.16 yourself i‘svmiliar with firm: new 91' _
‘ Creek iiala generally in tam community where fiendall

1 ioore‘a property is loaated? ,
1’ H we haVG wells all argumd there. 1 have to be i

acquainted with it. ' :4

.1 w. flow many wells haVe they in fhai Sectian a: the }f
:‘ country and in that field there? '
1‘ A. Yam MEfin adjacent to the Kendall Laure tract? }
13 %° In the courSe of a cauple cf miles aroumd?
:ff A. I couldn'f say offhand, becauae we managed fhe J
11 two cum?anieS¢ I kould have to count 3 liftle bit. 1v
1- g. I mean well$ that belong to fhe two companies?

g} A’ fie naVe about thirty four vroducing wells, I :*
Cf beliewe to the best 0f my knowledge, offfiand. I could J"
“ count up in gust a mument and tell exactly, but I think I?
{5' about thirty-four. . ,  -
‘é a. Are you acquainted with the different 61 producing 1
sands that is known in that field? I
Ti 3. We have no oil producing sand up there. :2
C; %. Gas producing Bands? :
1; A. Yes sir. \ :1
‘iv'hat are they?
’11; -196—
‘ ' .._ ; .-

 A. ';:;‘e haw: “the dealt sand, which under extrémely
’ guod air-amasfances if is possible 350 save some: malt
5am; gas from. That, wnich' is seldom done, becauge
I right under mm is water in the Salt sand gas. Then
1 «re have the haxon, and next- ‘the Eradley in which are
the prmiucing wells we 1122179 in this locality. There
" 51‘s ciaeper sands, but we have "no proéucing wells in
fimse sands, with the exception of the fierea 211111012
f is far below the lnjun.
.,L. I In the corrn’nunity oi the Randall kioore property
what are the gas producing; aands {hat are shown by
the present developraaxt? ‘ 9
’ we have the hiaxon sand adjacent . Wife have one '
' 'raellv I made the locatinn myself—- and I intended to
make that about a fnnt further than the line they
' had their well. I measunediitamith 9 3159331 tape and
I measured it at 108- I measured there 109 but in _
setting the rig we might henna moved just a few feet
I I further away- about 217 feet.
,. ‘ ‘4: From what well?
A. From the well known _as the Kendall Moore No. 2.
9 When was that well drilled, Lir. Eyre?
1 I belieVe that we drilled that well in April, 1921.
his: I haVe a note on it. I can refer to it. (literal-ring to
memorandum) It was drilled in April, 1921. M

 :m, ‘fixat dapth W85 it drilled?
_ n~- I couldn‘t state offinand. .
' \_° ‘."hat Strand?
A. Laxon.
a. Was it a producing well?
‘ .a. les sir.
;. Is it still producing?
A. Res sir; we put that on the lino in just a few
V ' days after the well was drilled, it has been on the
line continuously with the exception of fiVa hours
.- one day, and it baa probably been off seven or eighfi
houro in testing the well at different Times.
4. To what is it connected by pipe line, hr. Dyre?
' V b: To the Liberty carbon plant.
- ,- fibout now iar are ine3e wells of Kendall Loore
located from theimiberty Uaruon ylant?
'. 3‘ Well, I couldn't say oiihand, but I should judge
rf about 23 or 2400 feet maybe a little further. I would
I not say positiVely, becauSe I neVer measured, had no
‘ occasion to measure it. ‘ ,
%. hhat other wells, Mr. Eyre, oi‘the Keystone
‘. Gas Company are located in the some community? _
» 5' We haVe J. M. Allen N0. 1, the iirat well drilled,
known as the old Matty bent well. We hmre Jonah Webb

 £330“ I "Suck up on tile hill pessibly .12 or 1330 feet: .
1 egg. fhen was Jammy ‘:fiehh NO; 1 drilled?
L a 21122.»? .3 drilled While 3; was in Louisiana. I
M caulxin'i Lay the exact data; but it was drill ed 1
beliL‘Ve during; the 81131112133: 01‘ 1918‘ V
., 1‘23 if 5? producing well?
.’ I; ~ 9" 638 ‘53 ii.“ , "
. ,1“ . 315?; what 382191?
-‘ a ; mm?) . M‘
» . 18 it beihg 1193341 and marked”? ed 130‘»? '
.1.. Y es . i
by whom? 3,7
LL. Liberty carbon Conmtsany. It is being; used by the ”
'5 3416.918 to deliver gas to the Liberty Carbon Company. ‘
aiipeaking of the Newt Allen "well Ho. 1 I believe
' you say that was drill ed when? V _ ,
. 1896. "
{.:. 33y what company?
That was drilled by 11'. Gormley I belieVe and .
.‘ (:2:. h. Uimmiok, or G. 1%.. Dimmiok (2:: 1,. E. Gormley.
‘:’/ere they he first operators in this field?
’ 5;. 1‘0 the best of my knowledge they were. They were
' the only operators here what I came here at least.
' 499-

 233° They were later isucceeded by the 3‘59"" 4201:3311}? ‘
‘ A“ 1&5.
' 1;). 33 mm: "Well prox'luoing “0W? "
‘ ~ ’1‘! 5‘3 . V - ’
' .1,- how. have you been fairly "'335311 “Gauginted .;?-i fh
' the pgaiuduc‘tion of that well iron] the. time? ”7116” if” was '
. érilled in u}? to this Time‘s
,V .11. Part of file Time. 32 left and went to LuuiSianfi
_ in the Imamntime they I‘urniaheci some {59-3 30 E was TOld
by same of the oi’i'icgrs of the campany to the rail»
13032311 to was to drill the tunnel, ha ‘1'0 the amount
If; > 01“ (sunsmnr‘tion 1 dont know, but I do know when, we call
I {.I himpnole lé'ewtu Uncle fiewt Allen the first money he "
  got on the Well. .
" " 1“ When was théit‘k‘  
_ mat was ”to the best 01‘ my recollection it was
in 19:223., 1' had laid the line to White 19.01186. W9 Put ' . I
a. pumping; station on The Osborn place and we paid
" Uncle 1‘: ewt- $2f:0.<:0 a year for the use of the well.
34y recollection is we had a well drilled something '
along about that Time 11}? on the Lack 1,.artin prorerty.
ii; belieVe it was, at (Jarret. life had the 883 piped ’
.. ~20<§ --
x , , _ ~ ‘V. r ,, M“ ,,«*r , ,3 “EM“:

 .
Irom that well down to the haw nomain power house
at Boson, and'We also used it for danestie purphsee
among nurselves. So they sent a men out to see
Uncle lent to see if they couldn‘t get the rental
redueed on this well. do my wife and oldest boy
I who "raves then a baby«- they couldn't do anything with
heels newt- so we got in a buggy and went down to
see uncle newt. do 1 Just told him We could take
the $2eo.es we were paying him and lay the line from
,‘ Boson cvar the hill star to this pumping station ‘
Li] and probably we could get gas a little cheaper than _
paying at the rate of $200.60 here. He let us out
I for $5a.ho for each three months period.
‘ a. then was that well hitched on to the “iberty
L Carbon dompany?
7 L- I Was gone at that time. I didn't come back until
a short time afterwrrds, but the Liberty Carbon plant ,
was built during the cold winter of 1917- That well
i was put on to the Liberty Carbon plant, from our office
‘ records, and reun the Liberty Carbon plant quite a
. little while until the new well he. 2 was drilled
i which is known as the Frank Allen Well. /
“ -2oi—

 166+ :55 that Kew’t 1:119:21 x Lu. 1 fine 0211;; well Elm
libew‘ity gmfuon Somwny )7 11.351215: my my? 311 ‘rzve'il ':;-Eu. 2 "
.- w fir: L 1 :31}? ’
" {1.4 " 1' aridealts Obj eat ed “rim Quart 0V¢§I‘_.1’Ul «:::: the V
uhjectim‘10md I'iei'endautss 3243591.} 1'
i =- 121:9 a-«ccordingg to the 2351:9113 is: the: ci‘i‘imz it 1%
’i«-«'E'¥r—‘e's'1ri«.3112; mov 9&5. ta exclude rim answer, the: smart
u‘viaxwrulw; €119 mam «and z}.s«£'a31.s«:.i;‘~;m‘zi:3, axcapt. ::-
2.” :«m ,yxm 1m and 1721811 ’1 {xv-3n: 1 en :20 , 2 «mm drill 5&3:
~ a 1;“, 311'; <10 1m 1:,, »A;
.2:” Do you know appreximze‘t 9.1;; “My? flat 8‘? '
‘ . . 33:3, 1 ”’rouldn’t say, hem-511921 1!. new eer- had omasian
to inquire into it. The recm‘dE: «m in the.» Office, how- r
«av er, but It unrest 11:de mmrsiun 1' 0 bring; it up.
is: i”? now on the liberty Carbon Company plant? ' -
‘i Yes .
Is it aproducing well? ,
.. _1 (I; . 1 es . ':':
Has it been producing continuously since it was «
drilled in and hooked up? '3'-55
(Defendants obj acted, the court over—ruled same to
which defendan to except.)
‘.‘s’ith the exception of one time, the well got salt
in it and had to knows; the machine up and exean the salt *
‘ -202- - '
“ ,, ””«W/

 ‘ out of‘the tubings the sale had got in the tubing
and closed it up. 1 moved the machine in and cleaned
it out and it is producina new.
', ”. hr. fiyre, out oi the;thirty~four wells that the
' Keystone Gee Company owns in this immediate field
over which you have superiSion, now many of them
are gee producerS? .
i, All of them. Dont let me create a false im~
' prosaion there, We haVe two wells that are not
producing. I am speaking of the thirtyufour producing
wells, we have thirtynfour producing. we haVe two
that ere not producing at the present time.
p 7 not of thirty-six wells you have thirty-four pro- \
' Queers?
.51. Yes.
Q. How many of these thirty-four wells are in the V
hsxon sends if you know?
f. Well, I would have to study a little bit and
count that up. if you want me to take time i cant
‘i tell you in a few moments. Now, before I get wrong
7 here, we have one well that is producing from both .
sands. Six are in the‘haxon sand.
m' How many in the hradley?
A. All the balance with the exception of the two. ,
, ' ~2o3- ‘

 , Qua is a Smala well and tha ather 13 Berea.
5 we 53%, final 13 T36 hxst graducing sand in :54; Iifilfi ~
»7 ;M:5 gysas $33 producing Band? ’
1' A» law mean as i¢tL¢ liia 31 5h: wall 0: es fa file b
_‘ actual praductian? ‘
\ 3a gife 9i fins well find wraductian both? ‘
l fi’ I wsuld canaider 333% the gerea Smnd woulq be fige “
laggest liffi galls $6 much daepexi and the Ida} preséure .'
‘ - is much highar. gut @uy'leume is much greafer in H16 .'
Bradley. V
a. #0 you xnow how many wells in the geaver fielfl I
have been drilled in fine Ingun Sand? . .
A. No, L donf‘knmwv I dam? :ay &ny attentian to anym I
body wlfie's drilling, ram ufiher companies neVer in» a‘
fares: us at alla fie never go around their wells at allt :7
no hr. Myra, what is the cmaracter of the Laxon sand :'
with reapeet to where the Water is in that sand? :
5. fie usually get two atreaks of Maxon. Some of the El
drillers here call it the Second‘Salt sand, but we find '_
that if is on a level with the Laxon. We call it f;
waxon. ihe dalt sand we find is considerably abova. .;
we usually get our best pay in the Second streak of ' :f
the Laxon, which varies in thickness or course accord- l
ing #0 the dips and elethions, and then we usually :5
5&agswfiigfii:agc€?$amflflfifi¥?éflifiqiékfiffiiu33§n¥§3é33Tfiwv;~w¥%;.¥“i; 'fi*+éfi}%$iin3iif¥¥ififiiifiiiég
éLfi.v-\(’J\L"‘h a z ; .' . A A“; ,_» fia’

 ‘ I
g8? our best pay in the flecand streak.-
3* is there wntfir underneath the haxon Sand? ‘
: iihe :9 aura if- if‘ you drill into it
‘ a .v-z'om yam: kna‘rrl edge ran-"l mireri r1 ea in 1"},16‘ oparzation
  of that fife-151‘ 133fo is $112: fixatzcirieal and grocer thing ,
3V to do in Order to save 15m: 5 E33221 the: fi-"amn sand, .
\ ' ‘Wi {h I’vfl‘ibt to Whether you gar; 't'fimougfil it 01‘ stair: at -
the} f0}? 01" if? ’
‘ ' a. The way we alrasgys do, 1 airways stay around the!
. well :23 awn as; I 886 the sand hrs-gin ‘ro change and ‘1
get a liftlc bit of water, emu mac-279,11 down, -
would as: soon have :2 small well in a producing; sand in a *
as ‘ .
dry iml'g/‘ro hF'Ve a big well in n. wet hole. Eh??? hns ::
‘ been 2101‘: alone: my bailing], bu? Tiié“ company's frolicy all
along. *
111:. 13 that the adopted policy in that field by your
company? '21
Yes sir; assuredly.
"gazed upon your knowledge and experience as an j
’ apex-ester and handler of these questions, and gas wells,
do you regard that as a wise policy? 5"
I couldn't consider it any other way. {i
Going back to Jonah ‘yehb No. 2, I belieVe that is f
’205" 5;?
fin; a A p»: a My.”

 )jé'

his: rig-game‘s? to £3.31} £33.31}. L.‘.LL‘QI"E :30. 2‘:” _

'1 as. ~'_

’ disc‘s: ma! .;3, ha '9 ::og.tss .2:. 411% u]. ‘:,y Wham i r 3
drilled. 1:1,; Myra; ,

kg, gouLj-n’ 1". :3:-gay ::Xflkjfllf m: 13:11:; simple ‘rerfaon that

I I Sen? my 3.0g book in “if; tilgzi“ well with my testa mri ,

’5. 1’15? <23: 43» 3 received anfgy «:32: from m. a 3:311:- 13, in}. 1': :

nerves: Eleni QhéChfi‘iiifi’l :0. we. 1*:; taut 3T testa’. ‘tfirL-a “y'all '-

the {@1103ng year. 31 33.4358 them: if ea‘rs up w H13 ;;-r3:,:».

en: tune. i

I 51,- how many 'iiei-‘ri's Elev-1*: yzm Z’I-x‘l‘}, e: of if csin ca: it 19:73:: :7
drilled in‘ V A

l Luink mmut fourw 1‘11; 6 its 1.2%: $3311”,

0' 1:111 you tell the jury ':Jhu Those; Teflta 2:11-Jared? :

.1.. 1 have some notes on that {referring to notes}

flow on Deptanber 21, 1.9221, _‘ took 4:: test of that in

.26

a two inch tubing with mercury, and it showed/after

blowing for thirty minutes, that was my last, which

}?

is abuut the most test we take, and it showed at that

time 894,464. It was on the line at that time, the

working, pressure was 102 pounds. That is with the

blowing) of gas into the plant. 80 I shut it in

for twenty gxzinutes, and the rock preasure showed 110

pounds .

., -'.. “206 ' . ' .. r W;

 i g. When was your next that? i
- 1, age 3331;123- 9‘ ‘55:, 3924-, 22:-11'} 2 3 '13::: in :1. f: ":2:: 3.3.1 7
V. tubing "1133131": 1:1ercury, 512m :2.—:.::.529221cums, 1:131:352315 2223001“ch _ .
113;; 3:13: my ’1' 513113 7;:: 59235311.; i‘ege’éf T2431]? day. 23‘. ’2' 2252‘s. 31:33:.
I . :55. 111-15 ‘9' 2'-,‘:;me‘<3, the "*ii‘.-:'r;?fi:~fié':yj «reesure Was fifty
“tam 133.11.33.15139 213351 I 8?.11137 i'?‘ 3:133:11: fifteen 7"1j,nute5, and. 1
--e 3" «15.33213: 5 732321116171 Sigma-<13 3:.-.3“ 7101.11‘1'25-3 ,
-. "2"
~ )3. .':-£2.73, on. {zo‘tnher 29th., 1924; 1‘. blurted it for 372E‘Eiif'ty
21311211? 523', and I had been using; 93.13136 ”stern-in the {purge
‘ 1 I Still}, continued to us a 1112;273:2313 52,211.23 it showed (30,111.10
, with the ‘5’:3?523:“, making 37133251 u‘f‘ 424,323": .’13'=':“~r:?,-’E7 pr 3'
dab? 3 I I,
.’:-2: ., 31:32", i viirir.‘ 3: take tier-{Male pressure rt that time, :2
“nut if. "6091; and :1?-Lu? 5:32.23: a313, in for twenty :-:i.n1:‘res
; and it showed fiftymine pounds pressure in twenty
minutes pick up. I didn't take- the ~ Ada/cw pressure
Sit” Just took the pick up for twenty tinutes. I didn’t .
shut it in long enough. to get "the entire rock pres“:
aur e .
1315. liyre, do you know? whether the B, .33. Stephens ;;
rarell is lecated?
3 has 5311‘: . .
3 1’»: is on the adjoining tract to Kendall igioore‘e J
.:'?" ,,7’
~207- :

 between the Kendall tears and the liberty Carbon plant?
I. a 1* 514% Q
t is it a producing veil?
“a :m: at present, I'.; :.:; .
-. Is it on any pipe line? V
" ;It 1 ? i.8 (zornieeired t:; t}-a i“i fie lii32s, hili iizc ;;es it
. shut oii, well not being aged! » ‘
’ has. it gas in it? .
- ,. not at the present time, ihc gas is thaws. out 1
, it made some little oil, aha ii is a very thick heavy ’
‘ oil and we found that it took more to keep the Nail g
- in operation- the gas in there but the oil Would inrm 4,
H‘ V ' in it and shut it off the some as aster would, so it :6
_ took so much work that we had plenty of gas without '1
it, we are just lbtting it Set there, although paying ii
‘* im.otammm firthewfll.
3. has the Keystone Gas Company some wells just over y}
f: the hill on the hp hays branch of Turkey creek? ‘_
- In lea sir. {I
f u. how many has it there? Jh
' w. fiell, the wells that we drilled on the hp Hays ',
Gas '4
branch are treated as Louisville and Electric Company gf
; wells. They went in there and fried to jump a lease, 1h
’ ~2o8 -
'.’. -, ~, ,. " ,7 : "

 so they drilled three wells on it, and the ieystsne
{',2-as Gompany finally recovered it from the $011183." ills
' has and alectrie Gcmpany through a lawsuit as I under“
etandt
y. hr. hyre, the keystone tee Gemteny markets its
jeriutwfmaa‘tion, '33 you understand .7; “t, '1‘? a the carbon, 2:01n-s3;‘\a1:1y?
f, e rife; i3 .
was you. £37201}! "that it Settlinigrzacie a.) as :4 is: ‘
@9182
Jail, :10, not to my cm y; 1-31113]. 1m :.;“=fle£i;;::. 1' antler- ‘
, Stand; they are pumpting; it to 2.131317517513165. £3.13 to my mm
' fearsome}. Juno-e1 edge 1‘ Joni lame, ,
JD you Ian on? whether nth ey are us 1m: it for ‘i‘ omen/tic
purposes or for carbon? ' ,
;’hey furnish some demesi‘ie gas there around in
"' the ixma'zediate vicinity,l think, at aeytown.
w do they have a gas msim from Liaytown leading to
Louisville, as you understand it? ‘
That is my understanding. I see: part of the line ,
but never was (War the line, cuuldn‘ t safely swéer to
~ that, but first is my widenstanding.
a. What 13 the average life of the gas wells in this '
field, 3;.“1 Eyre?
’ (Defendants object, theccurt. War-ruled the _ii
obj action, to which defendants except.)

 ' A. T312223? 2.2-22:32:11.5: be m: umknuwz 93.11213? 15;; Ma 1525:. :E‘Qx' Hm;-

. sir-.5335:- 1.:' 235253 2':-2121 I 12.2.21" 2913' 2’2" 13:95:22? 11:-125:; 522.202.2525 5:0 e~ 2’:-3:252:51

: exhaufi 2" 25253 g a?

V 12212111322. 2‘22:- “3352212 22:25 22325.5 {5,525.2 11312 21151252225153
" 72111122252212 3 :1? 53522-2222 rare-ii 1:215:12 ‘5“ ‘22.? :2:: 21‘1I‘F2‘ifing; 5:227 ii 01" .
{152.1%}:33’2 22.3.2? or 1321142202335? “2 2212.2 1.23:;y‘k-223022Ie? if? 1.25.24 ‘

i ti 33:33:; 211221223. "'2:;21012. 2322.2221322. 2:3-22.22.; f5.» exisjvus $142292“?

‘ ~ 22.23.], from my mm 3-5-‘2x223532225'2LE Orwer’s‘wtim: L “:‘5'3'22153. '
judge Sim? 2226- 0521253233: 32.151531134232522 would EZXJLBUS 22' i, a 2:2:
{3129:2212 55.592221. £52.25. 23152212,, and in I220”? 223255321 1 was in 23.123.31.222132'22
we 15122-251 airing? 22.2212? 12222-78 3322-2523953 5.12;;12'14'; m 2,235? av 2':-52': 1:235: use _.
of 5.3225:- i‘or sax-123021 purpos es. "av-2:221:35:- it 2.225212222225223 it,
2323.212 JF had the same 0023‘? anti-gm here.- Two year-’25 ”Ego; "
f 53:51) $023.15}. 22'; for :2 1222...; 2:2.2'.‘ 2521;"? kin/’2, in this 5.:-“525‘

I 113:. .:.;yre, do yuu know what distance i“: is from
i3 the Laxan 352153231 #0 the Bradley sand in this f1 61d“? - j
:2. : "fell, it vari as 22 11525162. ‘:'-2‘9 uSually figure some-
thing; :2round 15.22.} feet from the. bottom 01‘ the’imxon to 3
the top of the Bradley.
. '1 Is the Bradley sand :2 water sand or dry sand? ».
‘:‘!e drilled two holes. This one adjacent to this
property is 5:10. 11 which is Very close to a well that
they had so 1 understand from which they pulled the ‘
2. ‘ 2 ~ », 5? -’V

 ' ca'asin; 111111: 1531" 1:111: ‘»’175'1‘5 er 1» the sand. .56 1.1.1.1. 1.1.1.1 4's
‘5 11:13. :..:lcr-cs to 1-:. t, {11'1"}; 1'1112-21122nr‘; leaked 1‘.-xi 1.11;; gym-’31,
,. hut '1. 1.111111: h: e 1:.-rill. era (Actual . .30 l 1:116:11? '11 Jack the
next :11‘;1‘:1.1‘.1'1;. 11::-'1 learn-i 1:, the s li‘t’l‘i =3; moisture .
in 1'? 1 1:12:21, 'i‘i...:«t fares any? we 1101—1111 call ,Lkldiorn :’
1;., 1.1, ..,-mi. ;2 111:»; out pretty elem? to the ,.‘,Et our-100111
. rein? shut run. My 1111: 1:::.1'1'3.£151,215, 31:11:52 71) 1111116311111 .étone 5‘
.15 1:02:11 1:17:16: ‘.,-cone creek 1;.-1n, 1121211335" creek, in that one "
a gut :1 little31,11‘1izgtnre. 1.116.111 the J. s1, is. I
2* I 11::-1:55 exceeded 2‘1'1y:1e1,1' 511134: :1 httle bit Uli‘rl‘fiw ,
5 5; It was 1:101:11; 11114511: three 1:31:1ch in the aft-amass,
the 3.1121113 began 5‘11 (15;. 1121521 1 1.112: "ml; 1 tnunghf
.:_:1ug;;.n‘éi c ':‘1 r3» 1111111.: in g; 1 .'; 47;". hi 1‘. mo ;e than 11:19:; . .
~ .1; f 131-11 1312-. 1::-.2 .st.‘.:‘:‘~e'i701: "31216.: 1111:; ”“1111?in 17 ;mar at ;he 5.
1 t ime tut-it 1' 11:21:11: “1.12.11"; shut this arc—311 down I:
' 11115111: 1‘.-ere, the dent leek Ligand ts mew but we will I
run a short screw. “that was 111011,; about “(our o'clock, .-
,‘ so we run a short screw, the send '.;/as mangging :1 little ‘-
‘bit, emf; was a little bit afraid of it, thought 1' f
would. take a chance, and we got a little water in that ,
but it Just makes a little hard tn operatew the well ..
is 1111111111, we blow the water off of it.
~211-

 N. Is the bredley generally Speaking a dry send or
wet sand, er ”produce a dry gas or wet gas?
A. I wouldn’t say as tO'yhet it would do, ii you .
drilled clear through it, for the simple reason when
1 See a sane ioCSe and likely to go into water, i
shut f( "ell (1017311. '
1,. its that your :11 ethod of onersting?
£9 host assuredly. . I
-‘.-J. that effect does water in a well have on the \ngf’ifi‘f
‘ .’.. il‘ you get a email amount of; ”refer, you can ‘
‘9 probably take care oi it, blow it every day or two? you
‘ can keep the. reefer oi‘f 01“ it, doe‘fin‘t collect enouglil
I to drown the well, but ii the sell is not tnken care 3
I of, e small amount of water will finally drown the well. n
.9 r» how is that accomplished? d
A. It gets so much Water in the sand it overcomes the I
» pressure of thegas and fills the sand and the gas .:
f hasn‘t got FOWer enough to raise that anount of water '
y, or the weight of the water. H
, _. no you know what is meant by a bottom hole packer f
. in a gas well?
': L~ 1 think 30, Yes. ‘ I
L ,, Leecribe to the Jury the differet kinds of packers? V
r L- well, I wouldn't know Just exactly how to explain q
uv a thing like that to a man unless he was practical. :;
~9g’gi ; _1.:...flif°‘ fia.,»=j [Eu'Ffi”iffi"f” "p. f 'f"t.,~".: ,Vf_,lvilr ;€$f¢fiwflfiflitif7 E

 E - W6 have aeNEEal a1349remt kindaa disk pficker: afraiflafi

j: ‘botfma mole fiaukarg nflgk wall vnakerg screw anchor

‘f fimcker? £03 insinnce in a“? well” 3 set firee nwckersg _
" E own h rdly exnlgin it in fhe jury umleas ihey knum
Lft wnmt a v Cker is, A packer is two tubes one vifnin ,
‘KL fjxg gstusrfi Saguafixinit irl t 113 an uiitjugn (i'iltlstkrwt14155
;;3 ihQTE 1% a Shuulder here“ fun rubflar harew you get  
Ix H133 different lengths, we mug thg sixfeen iggh ' '}
f;{ rubbers. lake an ordinary hoifom hole paeker it ig i
if put an the bmtfam of tflm string a; Gfifiifib and tne
‘3  weigh? setfi if, as this 30$s flown if uhQVes down
?? , and.PXp3ndS ThiS rubber Hfifi :Lu?s Sjyo'iafer 0:3; or
i.’ 9VGn T0 Separate The ensings 11 if is used yer inst ‘
 . purnafie‘ The screw anchnr wccker is thm wan? Fhing

'i only in the place of weight sefting it it has got W
1  a left hand thread so that as you screw the casing -
'1? up, inese left hand threads in the packer unscrews,

; and as you screw the the casing up it fingerews the

I‘ packer. It has several threads in it, and after you  
';: screw so far, which is unécrewing the left hand

E; thread in the packer, you screw it to the right i
:5"; ~213-
iiih" »;; ;p=gm,;%;;v ‘;‘;5;5;gg,_;f*;¢gggkyg;:,.5_glfixéfifi’fL??“iflfjfif”g@?fi?kkfi*xainuggfigfi%?fifififlfififiié

 ‘ iniorder ta keep from unacrewing the casing, and
after you gcrew it up so far it drora and expania
.7 the rubber and gets The rubber“
Iha disk flasher packgr ix practically %heafiwme "
I thing only that? is # littlg arrangement 509$ firu .
V, kunwriillugfratin; with pécker befare jury) That is f
A fasfenad mifh fl bolt and fluere ix 3 little hole farm 5
'4 The p 3km: anfl yam set that pfickar fhara gnfl if you 3;
~ run yaw? h iler in or SOHfifhiflLQtQ break thifi “13k 7
1 that let: i? set ficwn and rxnands tag rubber. ' 7
T, The hook wall packer is samethzng hardly nmybady W
”7 ; ”NM-uSeS any more. Thrt has a spring on the side wifh V
fif/
. V a win; and if grips the side of fhe wall fhgfie ?i?fle '
Z yrcngs and fhe weighf will set fhaf. ‘,
Z 4‘ have you had any experisnce, 1r. pyre, in the ‘
7’ matter of vulling tubing from wells?
~‘ A. I run a roustabout gang that practically all the 'R
1? 1vofik we did in four years Wafi pulling tubing and run» i
" hing casing. 5
w: - a. You hEVe had sufficienf practical exyerience in :4
f th:¢ matter to know how to do if prcperly? Vi
’ in I think so. ;
‘3 .fl That is the appIOVed and known and recognized F

 methcu of doing That by axperienaei and canscimnéiaus
I 0;?- (5; 1‘: i“ (3 3? a? t
L. (here ymu have a rig on w 95 coumse new is hwve '
rigs (B‘E‘EI P {great ziga‘my of mx 31-31655, magi we Mlzrfeivys -
‘ ui-‘se ti}, rig; ‘1'; i“ can 1'53 e Jpn: 2:11;; iii 5; 1%; 01/" £31“ i‘llfv ,
“...; ',fl.;a—:,g::: i? is 1205. ca 3451' a trim»; S0 X‘s-r-
30 «:35 is give yew é‘a‘igsului'u :31 :rnar‘anca ebov'ev fi‘he
longest iuning you hrme in the Jail t0 giVe jOfl a
‘ foot cg twa leguway so that if a team agauld aarwen
to mvka a wig-step yam wumldn‘f foul your blocks.
We ufle 5 shart niwfile firebahiy rust lama? ghout "
eigflt lashes long, and rut g 39f 0f a