Todd

In this action plaintiff prays judgment against defendants in the sum of $20,302.28, and defendants Shirley E. Meserve, Robert B. Moran, and T. Howard Knight, individually and as trustees of an express trust, by way of cross-complaint pray judgment against plaintiff in the sum of $100,000.

About July 27, 1923, plaintiff, W. O. Todd, and defendants, Shirley E. Meserve, T. Howard Knight, and Robert B. Moran, as trustees of an express trust, entered into a written contract by the terms of which W. O. Todd agreed to drill an oil-well by the rotary method to be known as " Meserve-Knight-Moran No. 1” upon property in the so-called Signal Hill oil-field. This contract provided, among other things, that the trustees should furnish at the location of the well a complete derrick, boilers (to be set up and connected and steam line carried to the derrick floor), water, fuel, lights sufficient for the boilers and for drilling, and for lighting of the derrick, and all casing; that Todd should furnish all the necessary and proper rotary machinery, drill-pipe, tool joints, drilling engines, pumps, and other necessary rotary equipment and tools, and all labor necessary to drill the well to a…