Jackson Co., TN Loose District/Chancery Court Papers Reel #79
Graham - Halfacre
"G" Divorces

Genealogical Abstracts by Mary Lu Johnson

The quality of this microfilm varies widely. Sometimes the copy at Tennessee State Library & Archives is more legible. Microfilm reels may be ordered by mail. http://www.state.tn.us/sos/statelib/r&r/mfcounty.htm

GRAHAM, JARED H. vs McKINLEY, THOMAS C. et al Chancery 1859

[Continued from Reel #78]

DEED from Ridley Roberts to M. C. McKinley, 10 July 1867, for $100, all right title and interest in land where McKinley lives... Jackson Co. near Granville Dist. 15, both sides of Martin's Creek including the mill... where James Roberts lived at the time of his death except the place where White Myers now lives which was sold by the County Court.... 1000 acres more or less. /s/ Ridley Roberts

Acknowledged in Rutherford Co., TN by John Jones, Clerk; Registered in Jackson County, Tennessee, Book "M" page 408 on 31 October 1871.

REPORT OF C & M. Commencing 1 January 1847 when McKinley took possession of farm to October term 1871... rents, expenses, credits for repairs, etc.

NOTICE TO DAVIDSON CO. SHERIFF: 22 August 1860 Jared H. Graham filed his Bill against T. C. McKinley, James Buchanan, Letta Buchanan and others... still pending.

Whereas the March term 1879 the death of said James Buchanan and Lettie Buchanan was suggested and admitted, and at August rules 1879 it was suggested that Alexr Buchanan, I. H. Buchanan, George Buchanan, Ada Paine and Carolina Buchanan and James Ross a son of a deceased daughter of James and Letta Buchanan are their only heirs at law.

George Buchanan and Carolina Buchanan have been heretofore summoned.

You are hereby commanded to summon Alexander Buchanan ["White Bluff" written in pencil above his name - mlj], I. H. Buchanan, Ada Paine and James Ross ["Randolph Tipton county" written in pencil above his name - mlj].

To appear 4th Monday in September next. Dated 2nd Monday in March 1880.

DEPOSITIONS 20 and 21 Feby 1882:

G. W. McKinley. Have been acquainted with the McKinley land since purchased from Roberts heirs. In 1847 the mill washed away and M. C. McKinley built it back. Think in 1867 DeBow and Donaho purchased under M. C. McKinley, built a mill with mill houses. /s/ G. W. McKinley

N. B. Myers. Known the land 12-15 years, maybe longer. The mill was built in the spring or fall of 1867. In the spring of 1881 I bought half and O. P. Burton bought half. /s/ N. G. Myers

BILL OF COMPLAINT of Jared H. Graham, James R. Graham, Thomas J. Graham, Frederick H. Graham, Michael Graham, all citizens of Marion County, Tennessee against

Matthew C. McKinley and William B. Roberts of Jackson Co. and John K. Sadler and wife Selina Sadler and James Sadler and wife Martha Sadler of Putnam Co., TN James Buchanan and wife Lettie of Rutherford Co., TN, Buck Roberts of Missouria and Ridley Roberts of Illinois and Hannah Graham of Marion Co., Tennessee a minor heir of John Graham by his wife Letha Graham of whom James R. Graham is regular guardian and George Holiman and William Holiman of Jackson County.

Orators are all the heirs of John Graham deceased by his wife Letha who also is dead.

John Graham departed life 18[blank] and Letha Graham departed life 18[blank] and left defendant Hannah who is a minor heir of said John and Letha Graham.

Said Letha is a daughter of James Roberts who died in Jackson Co, Tennessee 1842 by his wife Letha Roberts.

James Roberts in his Last Will & Testament left his wife Letha a life estate in land, about 1200 [acres] and all personal property...

Defendants Holliman are children of Elizabeth Holliman, wife of James Holliman. Elizabeth is a deceased daughter of James Roberts and her children are entitled to her share.

DEPOSITIONS 3 February 1859, Jackson County, Tennessee:

Joel Grace about age 54.

Ques: Did you know James Roberts in his lifetime and John Graham and his wife Aletha in her lifetime?

Ans: Acquainted with James Roberts and John Graham and his wife [Aletha] about forty years, first in Jackson County, Tennessee then in Jackson County, Alabama. Letha Graham was a daughter of James Roberts. In July 1840 I was in Jackson Co., AL and James Roberts was then alive and he said Letha Graham was dead and John Graham was married and I saw his second wife. I heard that James Roberts died in a few months after I left his house in 1840.

Ques: State how long James Roberts said Aletha Graham had been dead... when he was talking to you in July 1840.

Ans: Can't state how long... he said Leatha was dead and Graham was married again.

I visited him [John Graham] twice or more after the death of his wife Aletha and he was a living with a woman he said was his wife. This was between April and July 1840.

Ques: State if you knew the children of James Roberts.

Ans: Knew them all. Ridley Elizabeth Aleath Baler Letta Selina Martha & Buck.

Aletha is dead and she left issue and Elizabeth is dead and she left issue. Don't know all of her children. ?Hope and ?James... know she has more, can't recollect. /s/ Joel Grace

John Fergusson about 47. [Note: Fergusson was asked what he knew about the death of Aletha, daughter of James Roberts, and is end of page. May be a page missing, as the answer was signed by A. J. Fuquay - mlj].

Answer of John Fuquay: I was at James Roberts and heard him say his daughter Aletha was dead and John Graham had married again. A. J. [his X mark] Fuquay

Matthew Matthews about age 46.

Question: Say what you know about the ages of Aletha Graham's children of your own knowledge.

Answer: Jared was born 12 August 1819. Hannah born 1835. She is the youngest one living by his first wife Aletha Graham. The names of John Graham and his wife Aletha's children are Jared H., James, Josephus and Frederick Huling and Michel and Hanah [Graham]. /s/ Matthew Matthews

Buchanan W. Roberts about age 40. Sold my interest in land to Matthew C. McKinley which was 1/6 part. I considered Aletha Graham's heirs had an interest. Five of us sold.

The children of Aletha Graham beginning with the oldest and ending with the youngest are J. H. Graham, James R. Graham, Josephus Graham, Fredrick H. Graham, Michel Graham, Hanah Graham.

J. H. Graham was born 15 August 1819. Her brother J. H. told me Hanah was born November 1835, none were twins.... don't know ages of others or how much older Michel is than Hannah.

My father James Roberts died 28 August 1840. I do not recall the death of Aletha but she died a year or two before her father James Roberts. /s/ B. W. Roberts

Ridley Roberts age 65.

Ques: Say what you heard Matthew McKinley say about the interest of Aletha.

Ans: Some time before I left this state in 1852 I heard Mr. McKinley said he would like to purchase the Graham heirs part in the land. /s/ Ridley Roberts

David G. Shepherd age 55. Was Revenue Commissioner several years in Dist. 15. Land was listed in the name of Matthew McKinley. One-six was listed as [belonging to] heirs of John Graham. /s/ David G. Shepherd

John Hughes about 50. ... was talking about not letting heirs of Aletha Graham come in [for their share]. /s/ John Hughes

White Myers. Was Commissioner District 15 in the year 1855. /s/ White Myers

[NEW] GRAVES, WADE H., Administrator of A. W. Draper County 1880

[Note: Several persons administered on A. W. Draper's estate for several years, more on other reels, probably 67 & 68 - mlj].

INVENTORY OF PERSONAL PROPERTY [It did list amounts on reel - mlj]:

Receipt turned over to Wm Draper, the present administrator by Elvira G. Draper, the widow of A. W. Draper, 3 October 1881.

Paid to J. B. Cunningham... expense of going to Nashville to procure evidence, case of A. W. Draper, Admr of J. W. Draper, deceased vs Joseph Hix.

Note on W. B. Roddy to W. W. Hinds transferred to J. W. Draper 25 Sept 1878.

Note on W. S. Johnson to W. W. Hinds transferred to J. W. Draper 25 Sept 1878.

Note on W. W. McCue ditto

Note on John M. Burris due 15 Sept 1874.

Note on Asa Johnson due 7 August 1876.

Note on Sarah Cherry due 15 Aug. 1877.

Due bill on G. H. Morgan due 18 Sept 1878.

Note on A. W. Draper due 21 Jan 1879.

Note on H. H. Herrod due 21 Jan 1879.

Account from H. W. Rehorn on R. A. Cox due 7 April 1879.

Receipt from W. C. Purcell, Sheriff of Clay Co. for a note on Geo Newman & Sarah Cherry dated 10 Aug 1877.

Note on T. S. Clements due 18 April 1880.

Note on J. S. Draper & D. H. Draper due 18 April 1880.

Note on Ellen Draper dated 18 Apr 1879.

Note on Joseph Hix now in litigation, executed 10 Dec 1875.

Note executed by Wm T. Strode to W. C. Purcell due 31 Aug 1868.

Account on B. P. VanHooser due 14 Oct 1879.

Note on T. H. Jones and J. R. Crabtree due 6 Mar 1877.

Note on E. C. Gaines due 18 June 1875.

Acct on Columbus Billberry due 10 Dec 1878.

Acct on Calvin Hall due 28 Sept 1876.

Acct on Polly Proctor due Aug 22, 1878.

Acct on Eliza Lunday due Oct 8, 1876.

Note on R. B. Crowder, James H. Crowder and Henry Bailey due 18 Apr 1880.

Acct J. B. Anderson.

TOTAL $6565.92

SETTLEMENT September Term 1882 lists [Listed amount of each on reel - mlj]:

E. C. Gaines claim.

J. W. Draper store account.

Logan Hufhines store acct.

G. W. Birdwell store acct.

J. W. Draper, money furnished in redeeming Willis Cornwell's land and for claims bought up by A. W. Draper for J. W. Draper on H. Crowder account.

On William Gentry acct.

Receipt from John Rains 1881.


Due bill on John Proctor Sept 19, 1877.

Due bill on Wm Roddy and John M. Burris due Sept 15, 1878.

Acct on David Strode dated 7 Oct 1878 and out of date.

Acct on Adam Hufhines, insolvent, cannot be found.

Acct on William ?Lauten due Oct 5, 1877, insolvent.

Acct on Joseph Lancaster due Mar 8, 1878, dead and insolvent.

Acct on W. H. ?Motion due 17 May 1879, insolvent.

Acct on John Massy plead out of date.

Joe Phillips due 23 Feb 1878, place of residence unknown.

William Pennington, lives Clay Co., insolvent.

Geo Rains due 19 [blank] 1879, insolvent.

Pierce Buchanan due 30 Nov 1877, insolvent.

Dolly Pryor due Jan 1877, insolvent.

Polly Hufhines due 23 Jun 1876, insolvent

Wm Rash due 13 July 1876, insolvent.

J. H. Proctor due 25 Apr 1877, insolvent.

Jno Carnahan due 22 Oct 1875, insolvent and dead.

Ed McCawley due 22 Oct 1875, insolvent.

Wm Smith due 19 June 1877, insolvent and not found.

Saul Chapman due - dead and insolvent.

W. D. Collins, residence not known.

R. Griffith, insolvent.

Alferd Whitaker due 10 Oct 1877, insolvent.

SUPPLEMENTAL INVENTORY, Estate of Asberry W. Draper, 1 Sept 1882:

Judgment obtained against John M. Clark, L. M. Clark, Alex Clark. Aug 16, 1879.

Judgment on Bennett Minor, Feb 27, 1882.

A. W. Draper - witness claim in case of the State vs W. T. Holland for counterfeiting at Circuit Court.

Note on J. R. Draper due Sept 1, 1882.

NOTICE OF SETTLEMENT on 18 August 1882. To Mrs. Elvira Draper in her own right and as guardian of heirs of A. W. Draper, deceased J. R. Draper, Lula Draper and Robert Lee Draper, heirs of A. W. Draper.

[NEW] GRAVES, WADE H. vs SHOULDERS, L. H. Chancery 1898

BILL OF COMPLAINT of Wade H. Graves against L. H. Shoulders, both of Jackson County, Tennessee.

Complainant is owner of land 4th District, Jennings Creek... begin south side of said creek, north crossing creek to top of first ridge... George Teel's east boundary of a 520 acre tract... crosses longest fork of Spring branch that Thomas H. Wilson lived on... down said branch with its meanders... stake in Shoulders line... stake in Drapers line... 240 acres more or less.

Complainant purchased said land from John Teel on 27 Feb 1857... to whom a portion if not all was granted by the State of Tennessee... held until 1st January 1898 when L. H. Shoulders took wrongful and unlawful possession of a part... even put a barbed wire fence... cut timber [No relationships - mlj].


BILL OF COMPLAINT of Eliza Gregory against John Gregory of the State of Kentucky. Married about 1850 in Pikeville, Tennessee, together until August 1864 when defendant abandoned her and children with no means of support.

Before he left he was guilty of adultery with one Matilda Cook... left the country with her, was living with her in adultery when Oratrix last heard from him.

Two children of their marriage, Mary E. Gregory and James B. Gregory... she has supported them... can by her industry continue to do so. Asks divorce, rights of a single woman, care and custody of children. 30 October 1866. Eliza [her X] Gregory

August term 1869, costs of filing indicate final decree granted, no date.


BILL OF COMPLAINT of Fannie Green against William Green. Married in Jackson County, Tennessee July 1875, together until Jany 1876. Defendant deserted her leaving her in a delicate condition without means of support. After he deserted, she gave birth to a boy child named for his unprincipled father which she has supported as best she could. Defendant never contributed anything of consequence... a few times sent a dollar or two.

Defendant never mistreated her... kind and affectionate... due to reckless disregard for his child, he is unfit... never has seen his child... he is now over two years old. 31 August 1878. /s/ Fannie Green

Witnesses for Complainant: Margarett Hufhines, Drewry Hufhines, David Hufhines



BILL OF COMPLAINT of A. H. and W. B. Green of Macon County, Tennessee against Florence Green, Clara Bell Green a minor, Newton Green, R. L. Duke and wife Lula Duke and Alvin Green, Clarence Green, Artha Burton and her husband John Burton, Eunice Kemp and husband Willord Kemp, Clella Green a minor of Jackson Co., Claiborne Green of Smith County, Emily Williams and her husband Harvey Williams of Davidson County, Aletha West and her husband Thomas West of Missouri, Nora Sircey and her husband Will Sircy of California and John Green of Arkansas.

Complainants on 9 April 1903 filed Bill of Complaint against B. G. Green seeking to recover a tract of land.

22 July 1903 cause was compromised. It is necessary that it be confirmed by the Court. Since the compromise to wit on the 22 day of July 1903 the defendant B. G. Green has died intestate in Jackson County and defendants herein named are his heirs that is Florence Green is his widow and John Green Aletha West Nora Sircey Claiborne Green, Emily Williams and [blank] Green and Complainants are his children and the other defendants except the husbands of married women are his grand children. 217 Oct 1903.

DEPOSITIONS 21 June 1904:

W. W. Draper, solicitor for complainants. Know some of the parties, about 200 acres of land, knows where it is, does not know boundaries. /s/ W. W. Draper

STATEMENT OF COSTS: Included visits from W. A. Hargis for medical treatment rendered Bailey Green in the year 1903, $2.50 each, $65.00 total, on

June 15, 16, 25, 27, 29, 30.

July 2, 4, 7, 10, 13, 17, 21, 25.

Aug 3, 6, 7, 13, 16, 17, 18, 20, 26, 27, 28, 29.

INVENTORY OF ESTATE: Included three notes from Alvin Green for land, due Aug 4, 1905, 1905 and 1906. Notes dated 29 July 1904.

BILL OF COMPLAINT: Albert H. Green and Weldon B. Green against B. G. Green of Jackson County, Tennessee.

Complainants state they are owners of land in the 5th District on Roaring River on the north side of the Cumberland River beginning at a stake in the dry branch containing 190 acres, being same purchased from A. B. West by defendant B. G. Green.

They charge they purchased the same from the defendant and his wife Amandie F. Green on 4 June 1896 and took their deed which is now in possession of defendant.

Afterward the purchaser lived on it for some years. Defendant has taken possession... is insolvent.

ANSWER of Bailey G. Green to Bill of Complaint of Albert Green and Weldon B. Green... denies Complainants are owners or purchased from Respondent and his wife Amandie Green... complainants are his sons... respondent was old and infirm without education, unable to read or write his name... became indebted for material to build a barn... plaintiffs had a lien... did not ask them to stay a judgment...

BILL OF COMPLAINT of Florence Green against A. H. Green, W. B. Green, Emmer Williams, Newton Green, Lulla Duke, A. M. Green, Artha Burton, Clarence Green, Eunice Kempt, Clellie Green and Corra Bell Green.

On motion by Plaintiff by her attorney, states her husband B. G. Green died 11 October 1903.

ANSWER of Clara Belle Green and Clella Green by their guardian ad litem Geo G. Haile to Bill of Complaint of A. H. and W. B. Green. Shortly after compromise, their grand father B. G. Green died intestate.

C & M REPORT: Land advertised, sold 5 September 1904 to highest bidder H. D. Woodward at the price of $210.

[NEW] GREENWOOD, GEORGE vs SMITH, W. M. et al Chancery 1914

DEPOSITIONS 7 October 1914.

W. F. Sadler, age 41, live Gainesboro, am Clerk & Master. Surveyed lands by copy of Joel Curtis' Grant No. 8309.

Also have the deed from John J. Brown to Yancy Greenwood dated 15 March 1856, registered Book "J" page 703 and reregistered July 26, 1886, Land Book D pages 396-7. /s/ W. F. Sadler

S. H. Smith age 63, live on waters of Brimstone, Jackson County, Tennessee, am a farmer. I am a brother in law of George Greenwood. I married his sister. I knew Yancy Greenwood and John S. Greenwood in their lifetime.

A cabin once stood on the land at one time occupied by Rhoda Lee, now known as the burnt cabin.

I was along when a conditional line was made between Old Uncle Johnie Reed and Yancy Greenwood. Some timber had been cut near the line, Old uncle Johnie, Yancy Greenwood and myself. Old uncle Johnie didn't know whether the timber had been cut on Yancy's side or on his... was on his. Since, I traced the line to the burnt cabin, been about thirty years. About 40 years ago it belonged to some of the Hawkins boys... Wayme lived there... Sam worked there too.

Suppose it is the same hollow where Bill Smith lives now. /s/ S. H. Smith

George Greenwood age 60. Yancy Greenwood was my father. He died July 10, 1894. Mother died in the second year of the war. Father made a will.

I think Jones Reed and Andy Smith joins what is known as the Venerable [sp. "Venable" elsewhere - mlj] sink holes. The deed from John Brown to Yancy Greenwood calls for running west... thence with a conditional line between Yancy Greenwood and William Brown. When I first knew what is now known as the burnt cabin, Rhoda Lee lived in it.

Question: Wasn't George Lee, assignee of Joel Curtis grant 8309 named William George Lee.

Ans: Don't know. /s/ George A. Greenwood

W. C. Reed age 64, live 1st District of Jackson County, am a farmer. I am the son of John S. Reed, who died some 25 years or longer. I was raised on father's land. Line running down a lane... part of the Jerry Brown road.

When Frank Sadler ran the line, those along were Billie Smith, Frank Sadler, Mounce Butler, Jones Reed, Will Pharris, Tom Berry, Steve Strong, Bill Overton, Sam Hawkins, myself, Ed Brown, Geo Brown, Geo Greenwood, Rubin Greenwood, think Andy Smith, some other boys, Campbell Reed.

Father's land was between Greenwood land and the Roaring River.

Ques: Was Amanda Overton the widow of John Hawkins and the mother of Sam Hawkins before she married William Overton.

Ans: Yes sir. W. C. [his X mark] Reed

DEPOSITIONS February morning March 29, 1915.

Jones Reed age 56, live 6th District, am a farmer. I am a son of John S. Reed, deceased. Part of the land was covered by the Joel Curtis grant. Others covered by the grant were George Greenwood, Steve Strong, Billie Smith and maybe Pleas Bull. I own the south end of the grant, got it from my father, think he got it from Bill Brown.

DEPOSITIONS March 20, 1915:

Sam Stallings age 36, live 6th Dist., farmer. Sam Hawkins sold a tract to Bill Smith.

Ques: Did you tell George Greenwood what Sam Hawkins said about making a conditional line?

Ans: I told Uncle George what he said.

Ques: Did you ever hear Hyram Greenwood say... where his beginning corner was?

Ans: We were all together... they got Bill Jackson [surveyor] and began at the beech. Sam [his X] Stallings

Hyram Greenwood age 33, live 6th District, farmer. I am a son of complainant George Greenwood. Hyram [his X] Greenwood

Fowler Barnes age 21, live 6th Dist., farmer. I know George Greenwood and William Smith and W. S. Jackson. George Greenwood is my great uncle. Fowler [his X] Barnes

DEPOSITIONS August 7, 1914 at Livingston, TN.

J. H. Hawkins, age 87, live White Co., 11th Dist. I once owned the Greenwood tract, bought it from John Brown, sold it to Yancey Greenwood. I lived on it something like a year. Brown didn't show me the conditional line. He said John Hawkins had bought from George Lee a 50 acre tract to come off this 250 acre tract. John Brown was a right smart older than me. I have heard he was dead.

I moved away from there in 1855.

Rhoda Lee, the widow of Bill Lee, lived up the holler in a little cabin once. Guess she was living there under George Lee's title if she was living there when he sold to John Hawkins. George Lee was her brother in law.

Ques: What relation were you to John Hawkins?

Ans: Me and him was said to be own cousins. Our fathers was brothers.

Ques: Were you brother-in-laws too?

Ans: Yes sir we married sisters...

I owned it two years I reckon. I had paid Brown but had not got a title so when I sold to Yance Greenwood I just had Brown make title to him. I bought in 1853 and sold in 1855. /s/ J. H. Hawkins

W. M. Smith age 49, live 6th Dist., am a defendant. I was along when the survey was run. Mr. [Mounce] Butler said... this... is as far as my father ever claimed... east of the Ivy point. The Jackson survey was made Apr 7, 1908.

The deed from John J. Brown to Yancey Greenwood was dated 15 March 1856.

Ques: Do you know Campbell and Jones Reed?

Ans: Live about 1 1/2 mile of Jones Reed... we are not at the best understanding... suppose Jones Reed is the youngest [son of John S. Reed]. Think he was living with his father at his father's death. John Reed showed me the beech tree... corner... when I was a small boy. Present were my brother U. L., my father and Price Whitaker. The others are dead but my brother lives in Kansas. /s/ W. M. Smith

ADJOURNED to 7 April 1915.

Andy Smith, will be 50 years October next. Live in 6th Dist., Jackson Co., am a farmer. Acquainted with parties, was along part way when survey made.

Ques: State whether Geo Greenwood made any statements about the beech corner...

Ans: He said that his father and Uncle John Reed and Bill Overton agreed.

Old Joe Hawkins the brother of John Hawkins... Bill Overton and Sam Hawkins called him Uncle Joe... knew the old marks, three slashes on a beech, initials "J S R", suppose was Uncle John Reed's initials... it had what looked like a year [number], didn't examine it close. /s/ A. B. Smith

Pleas Bull age 48, live 6th Dist., am defendant. Was along when survey ran. George Greenwood ran from a beech on the Ivy point. I bought some of the land W. M. Smith got from Sam Hawkins... north end. I sold some of it to Perry Barnes. I bought a tract east of this tract from Robert Poston. I have heard he is dead. It was part of the Gore tract. /s/ Ples Bull

Asa Lynn, live 6th Dist., farmer and sheriff of Jackson County. Known land since a boy, raised one-half mile of it. Waymond Hawkins lived on it. /s/ Asa Lynn

Campbell Reed Jr. age 24, live 6th Dist., farmer. Present when survey made about seven years ago. Others were Pleas Bull, My Daddie Jones Reed, Billie Smith, George Greenwood, disremember the others... beech tree.

Ques: Wasn't the name of John S. Reed, your grandfather, carved on that tree?

Ans: Yes sir.

Ques: Is Jones Reed, whose deposition has been given in this case, your father?

Ans: Yes sir. Campbell [his X] Reed, Jr.

William Lynn, will be 73 next September, live 9th Dist., farmer. Known land 35-40 years.

Ques: Who had the land in dispute in their possession when you first knew it?

Ans: Aunt Mandy Overton, or Bill Overton had it in possession then. Bill was running Mandy's business, that was Old Bill, Will's father.

Ques: Was or not Amanda Overton John Hawkin's wife until he died, and then she married Bill Overton Sr.

Ans: Yes sir.

Ques: What relation are you... to Sam Hawkins, Bill Overton or to defendant Smith?

Ans: Me and Sam Hawkins and Will Overton are own cousins. Me and Billie Smith ain't any kin as I know of... Asa Lynn is kin to Sam Hawkins and Bill Overton, not to Billie Smith. /s/ William Lynn

DEPOSITIONS Monday April 12, 1915:

W. C. Overton age 49, live 9th District, farmer. Once owned land... bought when it sold for distribution among Hawkins heirs. Known it since 1877... helped repair a fence, lived 3/4 mile ever since.

John Hawkins was Mother's first husband. The heirs gave her some timber on it to pay the indebtedness. Wayme Hawkins controlled it as one of the Hawkins heirs up to his death about 20 years ago. Sam Hawkins controlled it until it sold for distribution.

Mounce Gore and Mounce Butler sold a tract of land to Copeland and Poston... made this deed covering this strip 24 poles wide on the east side of the Joel Curtis Grant... I went to Gore and told him he had sold part of my land... showed him my Grant which was older than his... took W. R. Poston with me, ran the line and they gave it up and collected off Gore.

John Brown, George Lee and John Hawkins were marking a conditional line... ridge to the hollow... had left two old men, Asa Lynn and I think John Brown's father in the road that leads up from Billie Smith's house... they were drunk or partly drunk... they went to see about them and John Brown never did come back and finish the line... it crosses what's lately called the Jerry Brown road.

Yancey Greenwood was not alive when [I bought the land]... don't know how long he's been dead.

George Greenwood wouldn't let the surveyor run by my papers... said his daddy's were right. He appeared to be in poor health for a few years.

Ques: Do you know the character of W. C. Pharris and Ab Pharris, grandsons of John Reed?

Ans: Good...

Old people and my mother said the line between Smith and Reed is crooked so as to run with the shape of the hill. /s/ W. C. Overton

ADJOURNED to April 13, 1915:

Sam Hawkins age 65, live 9th Dist., farmer. Known land 50 years or more. I am a son of John Hawkins. He bought it from George Lee.

Joe Lynn sold Walker Hix some land up there... let him have the 50 acre tract. After it was surveyed, Walker Hix went back on the trade... lines wrong.

George Greenwood said [my] Uncle Joe Hawkins, me and Pap and John Reed and Bill Overton Sr. marked it... agreed. I told him Bill Overton had no right or guardianship of Hawkins heirs...

Ques: Did you or Bill Overton Jr. cut logs...

Ans: I did and Will did, too...

Joe Hawkins is my uncle by marriage. Will Lynn is my cousin, Asa Lynn is my second cousin. /s/ Sam Hawkins

E. A. Brown age 70, live 1st Dist., farmer. Born on land and lived there until I was 14 years [old]. George Greenwood owns it now. My father was John J. Brown... has been dead 10-12 years, maybe longer. E. A. [his X] Brown

Ab Pharris, will be 49 the 21st of May. I live in 9th District, Jackson Co., am a farmer.

John S. Reed deceased is my grand father, been dead several years. He was talking to my father and he said "Ray, my corner is right over there..." I was between 15 - 16 years old. My father is dead.

Ques: You speak of a beech... your uncle Jones Reed... Ab [his X] Pharris

W. C. Pharris. I am a grandson of John S. Reed, deceased. Will be age 51 the 8th of next month, May. ...Rubin Greenwood, a son of Yancey Greenwood. /s/ W. C. Pharris

Walker Hix age 65, live 13th Dist., am a farmer. At the close of the civil war I lived on Roaring River close to Andy Johnson's... up the hollow. Three or four years after the war I contracted for a piece of land in the old Asa Lynn hollow. It was where a house burnt... had been occupied by Serrilda Ledbetter... don't know if Rhoda Lee lived there before her. Walker [his X] Hix

A. C. Chaffin age 29, live 11th Dist., am the County surveyor. Surveyed part of the land. /s/ Abner C. Chaffin

W. C. Reed [Recalled, cross-examined, nothing new]. /s/ W. C. Reed, Sr.

[NEW] GREENWOOD, W. R. & wife vs VANOY, HESSY & others Chan c1877

BILL OF COMPLAINT of William R. Greenwood and wife Sarah Jane against Hessee Vanoy, Nathan Vanoy, William Vanoy, Noah Vanoy, Green Scantland & wife Martha Scantland, Joseph Flatt and wife Amanda Flatt, Isaac Fipps and wife Docia Fipps, David M. Vanoy, and Marion Haris of Jackson Co.

David Vanoy departed life intestate 1 November 1876... Defendant Hesse Vanoy is his widow. Complainant Sarah Greenwood and other defendants except husbands of married women and Marion Haris [Harris] are his only children and heirs at law... David M. Vanoy being a son of James Vanoy a deceased son of David Vanoy deceased... minor under 21, no general guardian.

David Vanoy died seized and possessed of the following land in 8th District, Jackson Co., TN, bounded by John Hamilton, Andy Flynn, Mahaly Spivey... occupied it at the time of his death, is now occupied by his widow.

Second tract in the 6th District, bounded by Jesse Hooton, Martha Adcock and others, 25 acres worth about $100.

Defendant Hessy Vanoy is committing waste... sold to defendant Marion Haris about 50 valuable logs.

Complainants together with other children of David Vanoy, deceased are entitled to proceeds. David Vanoy had no personal property except what was exempt by law to his widow. Dower has not been assigned... land not susceptible to partition. 21 July 1877. William [his X] Greenwood

[NEW] GRIFFITH, WILLIAM J. et al vs DIXON, WM J. et al Chancery 1853

[Note: Believe there is more on this case on another reel, don't recall which - mlj].

DEPOSITIONS 25 November 1853 at home of David Griffith on Jennings Creek:

Robert Richmond about age 67. Acquainted with land where Ensley Wilmore now lives. Knew Caroline Griffith, wife of Samuel C. Griffith in her lifetime. Do not know how long they lived on the land. /s/ Robert Richmond

John M. McCue [No age]. Knew Caroline, the wife of Samuel C. Griffith. Heard Tandy K. Griffith before Caroline die say he intended to give the land to her and her children... recollect dates badly, cannot say when Samuel C. Griffith and his wife and family lived on the land or when I had the conversation. I moved on Jennings Creek in 1834. The conversation was a year or two after. /s/ J. M. McCue

John McDowel about age 56. Samuel C. and Caroline Griffith lived on the land until she died. Some three or four months after they went on it, Tandy K. Witcher told me he had given the Tinsley tract to Caroline and her children.

I and Vinzant made the coffin [for Caroline] at Tandy K. Witcher's... Tandy said to me it was a broke up family his daughter dying and he would have to get the children out of Griffith's hands for the rent of the land would have to raise them. He said Cul could not manage the land and he would have to get the land and children into his own hands and the old lady and him with the rent of the land could raise them.

Ques: Say whether Samuel C. Griffith did not stay with his children until he married again.

Ans: I think he went off and I think the old people kept the children until the old lady died and I think Griffith stayed there too until he married. When he went off the children remained there until the old lady's death.

Ques: State if Caroline Griffith had a daughter not mentioned as a defendant.

Ans: The daughter of Caroline was named Patsy... she married and left this country... she was a girl of tolerable size when I came to this country some 22 or 23 years ago. I think it has been the rise of twelve years or longer since she married. She was gone a year or two and came back and stayed about one year then went away and came back no more... has been about twelve years ago.

Ques: Say what sized boy William C. A. Griffith was when you came to this country 22-23 years ago.

Ans: He was a small child... could run... about 1 1/2 year old I suppose.

The land where Griffiths lived was 150 acres.

Ques: Say if the daughter Patsy of Caroline Griffith was not born before her marriage to Griffith... if she did not live with Tandy during the life of Caroline and if you do not know by reputation that said Patsy and her child is dead.

Ans: It was said she was born before her marriage with Griffith... that she lived with Tandy K. Witcher during Caroline's lifetime. Don't think she ever made her home at Cul's. I have heard it said she and her child died on the way from Nauvoo to the Salt lake.

I have heard a good many relations speak of it... been several years. She died between [18]44 and [18]47. I first heard of her death about the time peace was made with Mexico in 1847. /s/ John McDowel

Sarah Griffith age 36. Tandy K. Witcher said in 1848 or 9 he had made a deed to Caroline... he couldn't find it, supposed Claiborne Witcher's wife had destroyed it. It was before he went to Nashville for the Supreme Court case against him for shooting Merlin Young in which Merlin Young was prosecutor. He said he didn't know what would become of him.

Ques: State who was present when you had the above conversation... if he was not drunk at the time.

Ans: It was at William P. Witcher's house and in this house... don't recollect who was present but he was not drunk. My mother was present. My mother is now dead. Polly Witcher may have been there, and I think was at the conversation at Witchers.

I was well acquainted with Tandy K. Witcher. He was a man of passionate disposition and high prejudices.

[Note: Ends at bottom of page; remainder of deposition filmed out of order many pages later, after that of John F. Griffith - mlj].

Sarah Griffith [continued]: In 1833 or 34 Tandy K. Witcher said he had given land to Caroline and her children. It was after he had moved to Kentucky and they followed him for his negro. After he moved back he told me about the deed. /s/ Sarah Griffith

David Myers age 67. Knew Sam C. Griffith and wife Caroline, daughter of Tandy K. Witcher. Caroline died on the land [in dispute].

Think it's been 18 or 20 years since defendant Dixon and Claiborne Witcher merchandized on Trace Creek.

Ques: At the time he sold the tract to Dixon did he tell you he intended to give the land to Caroline and her children but he had become enthralled [deeply indebted - mlj] and would have to sell it and give them another piece?

Ans: There was some such talk about that. David [his X] Myers

ANSWER of Defendant [Ensley] Wilmore, states the trade was made in January 1851 and took possession in February 1851, having paid up. Didn't know a bill had been filed until after defendant Dixon was paid. Went to Macon [doesn't specify it's the county, not city, but probably is] to see him about it. They heard complainants intended to claim the land but considered their claim of no value. 11 July 1855. /s/ M. J. Dixon, Ensley Willmore

DEPOSITION: Moses Scarlett, age ?40. Have no recollection of witnessing a deed of gift from Tandy K. Witcher to Caroline Griffith. May have, don't recall... don't remember things that are not important to me.

Ques: State if you were much about the house of Tandy K. Witcher 1836-40.

Ans: I began carrying the mail think October 1836 about one year and stopt [sic] there twice a week long enough for the mail to be opened... usually 15 - 25 minutes. Didn't live on the end of either route, never spent the night there. /s/ M. N. Scarlett

DEPOSITIONS 24 January 1855. Deponents testified to character of Booker Witcher, state whether or not he is entitled to credit on oath, how long have known/proximity to his residence:

James Dycus age 66, known 25-30 years. /s/ James Dycus

George Huffines am 28, known since known anyone, about 2 miles. /s/ Geo A. Hufhines

Vinson Moreland age 60, known 12 years, 3 miles. Vinson [his X] Moreland

John Ray age 51 [or ?57], 20 years, one mile. /s/ John Ray

John Jenkins age 45, known 20 years, live some ? [crease] miles. /s/ John Jenkins

William Proctor age 41, known 10 years, 3/4 mile. /s/ William Proctor

M. G. B. Stubblefield am 28, known 10 years, over 3 miles. /s/ M. G. B. Stubblefield

A. M. Ferguson age 36, known 8 or 9 years, 1 1/2 miles. /s/ A. M. Ferguson

David H. Draper age 33, known 15 years, live 3 miles. /s/ David H. Draper

SUMMONS - give evidence 20 October 1854, cause of Wm C. A. Griffith against William J. Dixon, et al:

Thomas K. Harris, John VanHooser, Thomas M. Wilson, Ephraim Wilson, Thomas Wilson, Pleasant Henley, Joseph Roddy, John Moss, James F. Moss, John McDaniel, Larkin D. Swezea, Jonas Swezea, Matthias Swezea Jr. 2nd Monday in July 1854.

SUMMONS - give evidence 2 August 1854:

Alexander Clark, Alexander Neville, Solomon Wilson, Jefferson Wilson, Ephraim S. Wilson, Thomas N. Wilson, Larkin D. Sweazea, Matthias Sweazea Sr., Matthias Sweazea Jr., E. R. Hancock, Henry Lovelady, Henry Sweazea, Jefferson Price, John Scisco, Thomas Shrum, Pleasant Henley, Joseph Roddy, John McDowell, Pharis Sweazea, Thaddeus C. Quarles, Alexander Keith, Valentine VanHooser, Thompson Cason, David Myers, Burrel R. Land, Jonathan Wilson, Reuben Price, Leroy Gordon, Benjamin C. White, Denton Moore, James F. Moss, Robert T. Moss, John Moss, Booker Witcher and Samuel T. Griffith. 17 July 1854.

DEPOSITION - State of Kentucky, County of Monroe} I John A. Pace, J.P... at my school house... deposition of:

Claiborne D. Witcher age 46... saw a deed purporting to be Tandy K. Witcher to Caroline Griffith and her children to a part of the Tinsley tract witnessed by Moses Scarlett and my wife Mary Witcher... land on the west side of the [Jennings] creek was left out. It was 1837 or the first of 1838.

T. K. Witcher was indebted to Dixon... as much as $500, sold the land to pay his debt. Dixon removed from Jackson County ten years or more, returned shortly after making the purchase.

Understood T. K. Witcher gave Caroline Griffith the place where Sam C. Griffith now lives. To the best of my recollection Caroline Griffith was present when I saw the deed. Don't know what became of it. /s/ C. D. Witcher

CAUSE HEARD: William C. A. Griffith, Nancy Griffith and Claybourne and Polly Griffith by their next friend William C. A. Griffith against

William J. Dixon and Ensley Wilmore [blank] July 1855.

Complainants bill and amended bill are dismissed... William C. A. Griffith and Nancy Griffith and their security John Brown to pay costs.

DEPOSITIONS 18 June 1855:

John VanHooser about 44. William J. Dixon the defendant is generally called Jackson. /s/ John VanHooser

LETTER [Verbatim transcript - mlj]:

"Whitleyville, Jackson County, Ten April 20th 1842

Wm J. Dixon Esq.

We rec'd yours several days since but owing to the old Lady not knowing when she could come we have defer writing until now. Martha was Married to Abraham L. [or ?S.] Workman some time past and they with Mrs. Smoot and others is about starting to the Church they were to have let us known nearly a week ago when they wood start they would cross the river at Bennett's old Ferry and we were to have taken the cart and hawled her things to the cross roads ?at Moors and met them there we had no word from them yet and the old Lady says she can not bear the Idea of not seeing Martha before she goes away but just as soon as they start she will come down and stay some time. I am trying to sell my land more to please others than myself. I some expect Jonas Myers. I want to sell all together. Pleasent Henley thinks Haywood Talbot will buy. I think I could get $1000 for the lower place. I am compelled to sell it to pay my debts but I want to sell all together. Yours respectfully, T. K. Witcher

last Thursday I had a letter from A. O. Smoot he and L. M. Davis had succeeded in obaining [sic] a hall in Charleston to preach the [sic] had petitioned the City Council to obtain leave to deliver a lecture in the City Hall but was rejected. TKW"

ANSWER: Joseph Moss to Bill of Complaint by Bank of Tennessee against himself, Tandy K. Witcher and John Moss. Does not know if co-defendants are indebted to the Bank of Tennessee as charged. True Tandy K. Witcher recovered judgment against him. 14 January 1851. /s/ Joseph Moss

DEPOSITIONS 7 July 1854:

Isaac VanHooser [No age]. Never heard Tandy K. Witcher say he had given land to Caroline Griffith and her children. Known John F. Griffith from a boy. From what I know of him individually, could believe him on oath. Live about seven miles of him, both in same district. There is a big hill between us and I neighbor on my side of the hill. /s/ Isaac VanHooser

NOTICE OF DEPOSITIONS to Allen W. DeWitt [attorney for Complainant]. At dwelling house of Ensley Wilmore in Jackson County, Tenn 22 January 1855 to take depositions of:

Broadus Keeling, Patrick Copeland, Jackson Perry, Jefferson Price, William C. Purcell, John Sisco, Thomas Shrum, Phillip M. Long, Jonas Tanksley, John Watson, Thomas Speakman, Charles McCue, Allen W. DeWitt, William G. Huffines, Leroy S. Gorden, James Stroud, John Fergerson, Asa Lovelady, William H. Botts. Continue the 24th if necessary.

25th of same month at Highland, depositions will be taken of John Ray, Vinsen Moreland, A. M. Fergerson, G. A. Huffines, William Proctor, John Jenkins, Stephen Jenkins, M. Stubblefield, James Dycus, D. H. Draper.

27th same month at store house of Jefferson Craing [sic] in said county, Moses Scarlett.

LETTER [Abstracted]:

Whitleyville, June 17, 1842

Wm J. Dixon Esq.

This leaves us all in a reasonable state of health... exception... the old Lady and Anderson who are both complaining rather more than usual the old Lady has a very bad cough and soreness in her breast... will be down in ten or twelve days... I have been trying to sell my lower Plantation to pay debts... will let you have it 2 or 300 dollars lower... I want Claiborne's debt paid and I owe some money besides... the rent is worth $60 or $70 a year if it belonged to somebody that would manage right. We are anxious to hear how Nancy is, and the ballance of the family also, you will please write by first mail after receiving this & tell me how this proposal will suit you - I am very anxious to have Claiborne's debt settled... he will have as much of my Estate as he ought to have or will get - I have been near two months with a rising on my back or rather my side... not been able to go about... my business... my fingers cramps... can scursly write. Yours respectfully, T. K. Witcher


Whitleyville, July 1, 1842

Wm J. Dixon, Esq.

Sir as I am anxious to pay my debts I want you to take my land but do not wish to take more than I am owing... $800 will pay you and others... last Feb Wm Kerby offered $1200 with $700 down and two years... I wanted more down... while we were pausing Henry Kirby bought of Amon Haile's for him. Yours respectfully, Tandy K. Witcher

OATH OF POVERTY: Nancy D. Griffith, Claiborne D. Griffith, Polly K. Griffith... unable to bear cost of suit, case of William C. A. Griffith next friend against William J. Dixon and Ensley Willmore. 2 October 1855.

DEPOSITION - State of Texas, County of Anderson, residence of John M. Dixon in the town of Palestine, 27 May 1854:

John M. Dixon age 30. William J. Dixon is my father and Tandy K. Witcher was my grandfather. Tandy K. Witcher requested I take a letter to my father relative to the purchase of land... Witcher said he intended the lower place for plaintiffs but got in debt... was bound to let the place go and would make provisions for plaintiff in the upper place. At other times he has told me that he did not intend that they would have anything... had raised them and in his old age they would not come to see him and when he met with them they would not speak to him at all.

Ques: State if Tandy K. Witcher became an enemy of your father about the time he was pursued to Kentucky for a Negro he had levied on? [Note: Later depositions clarify William J. Dixon levied on a slave belonging to his father-in-law Tandy K. Witcher].

Ans: At the time the negro was levied on Witcher gave a delivery bond and my father went security... before the day of sale Witcher run said negro to Kentucky and my father sent the sheriff after him but did not get him he overtook said Witcher... became an enemy at that time. /s/ J. M. Dixon


For the love and affection I bear for my infant child, I Daniel K. Witcher of Jackson County, Tennessee do this day give unto my youngest daughter Martha a Negro girl named Mary about two years old to be hers and her body heirs forever and this deed of gift not to debar her from an equal part of my real and Personal Estate with the rest of my children. Signed in presence of us Sept 15th 1845. /s/ Daniel K. Witcher

Witnesses: T. K. Witcher, P. [or D.] G. Kirby, Wm P. Witcher

Appeared before me... Tandy K. Witcher and Pleasant Witcher... witnessed

DEPOSITIONS 24 April 1854:

Benjamin C. White age 47. Samuel C. Griffith and family lived on the land in dispute for about eight years before he moved to Witcher's after the death of his wife. Dixon was not in this country when Caroline died. Do not know the year she died, has been about twelve years ago. /s/ B. C. White

BILL OF COMPLAINT of Bank of Tennessee against Tandy K. Witcher of the State of Kentucky and John and Joseph Moss of the State of Tennessee.

Tandy K. Witcher and John Moss are indebted by judgment 13 July 1849 of $62.18. Feby term 1851, defendant Witcher recovered judgment against Joseph Moss, ask it be attached. 3 November 1851.

DEPOSITION: John F. Griffith age 43. Knew Tandy K. Witcher in his lifetime, knew the land on Jennings Creek. Understand Tandy K. Witcher conveyed part of his land to Caroline and her heirs, the wife of Samuel C. Griffith... Caroline's daughter Martha was born before their marriage... was to have no part. Martha married a man by the name of Workman. I saw the deed. Tandy K. Witcher read it... included the dripping spring above where Willmore now lives... entry in the name of Jack Tadlock... entry in the name of William P. Griffith of 375 acres... McCue's corner in 1837.

Caroline died in 1838. Some time after, her mother who is also now dead told me she had the deed... was giving Caroline's heirs the upper tract in lieu of the lower. Tandy K. always accused Claiborne's wife of destroying the deed.

The child of Caroline named Martha married a man named Workman and they went off to Nauvoo and Tandy Witcher said she was dead. She had one child.

I think Samuel C. Griffith and Caroline commenced living on the land in 1833.

Samuel C. Griffith and Caroline's children moved up to Tandy K.'s after her death in 1838.

Tandy K. Witcher was William J. Dixon's father in law. Dixon didn't live in the neighborhood but made it his stopping place when he came in the neighborhood.

Don't know where Dixon was born his father lived about two or three miles [from Tandy K. Witcher]. He lived with his father till he married... had an uncle that lived on the mill tract and I would think he was well acquainted in the neighborhood and he was constable in the upper Company.

It was in the Spring 1837 when I saw the deed - Tandy said it was a deed of gift... said he had given Anderson and Dixon land and he wanted to make her equal. Anderson and Dixon were his sons in law... said he had paid out a lot of money for his son Claiburn D. Witcher.

Dixon was Claiburn's security for $400. Witcher said he'd rather let Dixon have a bargain... took $600 from Dixon for the land, was offered $1200 by others.

I have not encouraged complainants to bring a lawsuit.

Their father is my first cousin. Witcher wanted me appointed guardian and bring the suit for them in his lifetime and I would have nothing to do with it.

I think Dixon lived in Sumner County when he bought the land.

When Tandy K. Witcher got into the difficulty with Young he made a deed to Claiborn so he would be a freeholder and go his Security... Dixon was afraid Claiborn would trick him and keep the land.

Claiborne Witcher and Dixon went into partnership selling goods. Dixon went Security for Claiborne for $400. /s/ John F. Griffith

Dolly Griffith age 56. The day before Daniel Witcher's wife died, Tandy K. Witcher asked if I had received a letter from Jonas G. Lock asking me to come to where he was... said I had... Tandy advised me as a friend not to go as Jonas would soon run through every thing... said now you are fixed... can take care of your children... said he had deeded land to Caroline.

When I mean "Cul" I refer to Samuel C. Griffith... generally call him Sam Cul.

In the month that Sam C. Griffith and myself was married, ten years ago next March... had a conversation with Tandy K. Witcher at his house he said to me you have given your land to your children. I told no. That my father gave the land to Nancy Lock who is my oldest daughter. He said the land he sold to Dixon belonged to Caroline's children but he intended to give them the place where he then lived in lieu of it. He said he would deed it to the children because Sam C. was a bad manager and would run through it.

Ques: Say if Sam C. Griffith your husband is not the father of all the complainants.

Ans: [Affirmative].

I first told the conversation [with Tandy Witcher] to my two daughters and after I married Samuel C. to my two daughters and him and his children.

I think Caroline Griffith died in July about 17 years ago.

I heard it talked about by Griffith's children shortly after we married that they was going to have that land - Anderson in particular since he was oldest... Nancy the next oldest... the other two was small.

Dixon bought it [the land] before I was married. Dolly [her X] Griffith

Ephraim S. Wilson about age 23. John F. Griffith's character is good, known him 10-15 years or so, live about 2 1/2 miles from him. /s/ Ephraim S. Wilson

John VanHooser 43, known John F. Griffith 30 years, live 8 miles. /s/ John VanHooser

Pleasant Henley 54, known John F. Griffith 30 years, live 6 miles. /s/ Pleasant Henley

Eleanor L. Borden age 45. Claiborne Borden my husband lived on the land in 1835.

Know William C. A. Griffith... as well as I recollect he was born May 1829. Knew Patsy the step daughter of Samuel C. Griffith. Married a man named Workman about twelve years ago, went off, returned again and again went off... said she went with the Mormons. The reputation now is she is dead. First heard her death spoken of 4 or 5 years ago.

Question: State how you are related to Sam C. Griffith and how long you have lived in the neighborhood.

Answer: I pass for his sister. Lived in the neighborhood nearly all my life, was born and raised in 1 1/2 miles.

The report is that Patsy Workman had two children. Report is both are dead. Don't know about Workman.

Ques: When did you hear from Patsy and did not the report say she and her husband and children had moved from Nauvoo to Salt Lake City?

Ans: They started from Nauvoo and that she and her child died at Rocky Mountain and that the other died afterward. Workman was reported to be again married.

My husband rented the land in dispute or part of it in 1835 and 1838.

James Martin built the house in the hollow above the mouth of the mill... it was moved away from there before 1834 when we moved there and another house put there for us to live in. Understand Sam had it moved away for a grocery.

Question: When were the children of Sam C. and Caroline Griffith born except William C. A. Griffith.

Answer: Nancy April 1831. Claiborn April 1833. Polly September 1835. Tandy January 1838. Elender L. [her X mark] Borden

David Griffith about age 66. [Note: Severe ink bleed-through here, some of the words I can barely decipher. TSLA copy may be better - mlj]. Knew Tandy K. Witcher... showed me the lines... _____ Supreme Court after he had been admitted to the penitentiary. Sam C. Griffith lived there in the date of [18]30 but can't say how long he remained there but he left there after his wife died... there from about 1830 to 1840.

Ques: Do you not know Tandy K. Witcher was not in a good understanding with Dixon in 1847?

Ans: I do not know it... he always in talking to me spoke in highest terms, said he treated his daughter kindly. /s/ David Griffith

John Proctor about ?47 [Nothing new].

Sylvester Copeland about 38. Sam Cul Griffith lived on the land where Wilmore now lives during his wife Caroline's lifetime and left after her death, don't know how long... heard Tandy K. Witcher say he intended the land for Caroline... had to sell to pay debts. /s/ Sylvester Copeland

Nancy Price age 31. Sam Cul Griffith lived on the land where Wilmore lives when I first knew it. I then lived at Tandy K. Witcher's. Sam Cul bet on a horse race and lost it and Mrs. Witcher was mad about it and said if the land had been his he would have bet that. A short time after Caroline died Sam Cul moved up to Witcher's. Witcher had not enough house room and they moved a house from where Sam Cul lived up to Witcher's.

I lived at Witcher's two years.

Ques: Who lived in the place that Cul moved from after he left it?

Ans: Claiborn and Daniel lived there at different times after Cul moved up to Witcher's and John [can't read last name] lived there at one time. Nancy [her X] Price

DEPOSITIONS 2 August 1854, re character of John F. Griffith unless otherwise noted:

Benjamin C. White age 44. Known John F. Griffith about 24 years. First two lived two miles of him, next four lived 1 1/2 miles, next sixteen about 6 miles except 6 or 8 months. Good. /s/ Benjamin C. White

Ephraim S. Wilson age 59. Known John F. Griffith from infant to present, no further than 8 - 9 miles, now within 2 1/2. I was constable two years. /s/ Ephraim S. Wilson

Matthias Swezea Senr about 81. Known several years, now live about two miles. Good. /s/ Matthias Swezea

Solomon Wilson age 63. Known from a child, about 4 1/2 miles, not same district, good.

Jefferson Wilson age 50. Known John F. Griffith some years, good. /s/ Jefferson Wilson

Edmond R. Hancock 38. Raised a short distance from John F. Griffith, now 4 miles; in a mile for several years. I was two years in Overton Co... some distance; within four miles about three years, not the same civil district.

Here recently heard two or three reports that if they would vote for him he would get three or four men to clear a fellow who had been taken up for stealing money... another that he was called as a witness in Court and he swore what was not so. Do not know anything about it myself. /s/ E. R. Hancock

Burrel R. Land age 38. Always considered John F. Griffith honorable. /s/ B. R. Land

Leroy S. Gordon age about 30. Don't know Griffith's character. /s/ L. S. Gordon

Thomas N. Wilson age 37, don't know. /s/ Thomas N. Wilson

Reuben Price age 63. Can't give full credit to Henry B. Saunders. Reuben [X] Price

Thompson Cason age 36. Cannot give full credit to Elisha Sanders jr.; John F. Griffith, yes. You might say I had a difficulty with Elisha Sanders. Haven't lived in immediate neighborhood of John F. Griffith... for five years I lived at the Sadler place on the same side of the river as Griffith, known him 20 - 25 years /s/ Thompson Cason

Pharis Swezea about age 30. Always known John F. Griffith to be entitled to full credit, but if late reports were true... one came from James G. Cunningham. /s/ Pharis Swezea

Alexander Neville age 41. John F. Griffith and myself were both raised on this creek... good. Lately heard tales... assisted in taking up a man in Kentucky and he did not attend because it was the wrong man. /s/ Alex Nevill

Henry Swezea age 29. John F. Griffith of good character, was a candidate for constable.

Ques: Have you heard reports...

Ans: I have heard Mr. Cunningham say so.

Ques: Was it not reported he did not swear the truth... case of State vs Cullom for shooting Davidson?

Ans: Heard one man mention it... never heard anything else. /s/ Henry Swezea

Byrum Wilkerson age 28. Would give full credit. /s/ Biram I. [or J.] Wilkerson

Booker Witcher about age 67. I was at my brother Tandy K. Witcher's house sometime between 1833 - 1837... he asked me to walk with him to Samuel C. Griffith's... he asked his daughter Caroline for the deed and she got it and he read it over, gave it back and she laid it on a shelf where was some books... as we walked back he showed me the lines. Said he intended to do more for Caroline than his other children because she had done more for him.

Ques: How long was it before you went to Nauvoo that you heard the deed read?

Ans: Can't tell... don't know when I went to Nauvoo. I was in Iowa and Nauvoo together about eighteen months I was sick all the time... stayed about six months at Nauvoo... saw Patsy Workman. Seems to me like she had a child. Booker [X] Witcher

Samuel ?T. Griffith about age 34. "In the Spring 1834 I was on the land on which defendant Wilmore now lives in company with Sam C. Griffith's oldest boy and Cunningham Anderson son Tandy K. and Tandy K. Witcher and I was talking to the boys of having had a fight there when going to school across the branch... and Tandy K. Witcher said he reckoned there would be no more school kept there because he had given that land to Samuel C. Griffith and his children". /s/ Sam ?T. Griffith

DEPOSITIONS at house of Ensley Willmore 22 Jan 1855:

James Strode [No age]. Sam C. Griffith was present when I went to look at the land... conversation with Tandy K. about a trade. I was coming home from the sink hole mill now owned by Draper. /s/ James Strode

John Furgurson age 29. I am a son in law of Willmore but no relation to the other parties. /s/ John Ferguson

Jefferson Price age 26, character of John F. Price not good. Jefferson [X] Price

Jackson Perry age 38. Lived 3 miles of John F. Griffith, known 12 years, character not good. /s/ Jackson Perry

Broudus Keeling age 37. Lived four miles of John F. Griffith 18 - 20 years, nothing against him, but if what is generally said is true, could not believe him. /s/ B. G. Keeling

William G. Huffines age 35. Heard James S. Cunningham speak of Griffith being a bankrupt and false swearing about six months ago. /s/ William G. Hufhines

Patrick Copeland age 31. Known 9-10 years, live 3 1/2 miles. Heard Cunningham and Carnahan make charges about John F. Griffith last summer. Patrick [X] Copeland

John Sisco age 37, live one mile, known 20 years. Never heard anything against John F. Griffith until Cunningham, James W. Draper and Lewis Hix... John [his X] Sisco

Thomas Shrum age 30, live one mile, known ten years, would give him full credit in a court. Heard John Watson, Mr. Cunningham, Pinkney McCarver [speak against him]. I am fully acquainted with his character. /s/ Thomas L. Shrum

Asa Lovelady age 56, live one-fourth mile, known 14 years. Not good character... to all appearances friendly... once a hardness between us. At a log rolling at Ben Caruthers I heard Washington White say Griffith was respectable as a young man but now these charges was against every where he went. This was a few days ago. /s/ Asa Lovelady

Jonas Tansley age 31, live 1 1/2 miles, known six years. About six years ago I heard old John Dixon charge him with taking the Bankrupt law and about a year ago I heard Mr. Proctor, Lewis Hix charge him with swearing and about six months ago heard Mr. Cunningham charge him with the same thing. Jonas [his X] Tansley

Phillip M. Long about 35. Live 2 1/2 miles from John F. Gipson, known 5-6 years. Heard James Carnahan, Lewis Hix, Mr. Watson and Willmore [more rumors - cannot believe him if true...] P. M. [his X] Long

John Watson age 56.

Ques: Say if Martha Witcher the wife of Tandy K. Witcher did not say at your house at the time your daughter Susan was born that she had the deed...

Ans: Don't recollect. /s/ John N. Watson

Charles A. McCue age 27. Known John F. Griffith 15-16 years. At this time live about three miles from him. I was principally raised in this country but was absent in Kentucky a few years... been in this neighborhood the past twelve months. Heard it said when John F. Griffith campaigned for constable, on the case against State against Thomas Saunders for Larceny and other charges, he proposed to certain men if they would vote for him he would get a jury [that would give an innocent verdict]. /s/ C. A. McCue

Wm C. Purcell 35, live one mile of John F. Griffith, known 20 years. /s/ Wm C. Purcell

DEPOSITIONS 22 June 1854:

John M. Ferguson about age 53. Spring 1837 had a conversation with Tandy K. Witcher... said he intended to sell the lower part of his farm and come to Gainesboro and [start] merchandizing or buy him a negro. He said Samuel C. Griffith was living on the lower part, said nothing about rent. /s/ J. M. Ferguson

James T. Quarles [No age]. Acquainted with Tandy K. Witcher's hand writing, think the entry showing birth of Wm C. A. Griffith in the bible here shown is his handwriting... all births, marriages etc. in the Bible are in his hand writing.

Nearest I lived was about six miles from Tandy K. Witcher with the Cumberland River running between us. He was a J. P. for Jackson County and I was in his company frequently. He drank to excess and was profane... never heard charges against his honesty. /s/ Jas T. Quarles

James G. Cunningham age 43. Have been acquainted with John F. Griffith 20 years. He appeared to take sides in a court of Justice. Known him from boyhood. He is near my age. /s/ J. G. Cunningham

Elisha Saunders age 39... from a proposition he once made to me I could not believe John F. Griffith. /s/ Elisha Saunders

Ezekiel Carnahan age 38. If reports heard first last February are true... could not believe John F. Griffith. /s/ Ezekiel Carnahan

Benjamin E. Caruthers age 30. Heard reports last Feby... on good terms with John F. Griffith. /s/ B. E. Caruthers

Henry Saunders age 40... from a proposal he made to me 3rd of Feby last, could not give John F. Griffith full credit. We are friendly. /s/ Henry Sanders

James M. Draper age 40. A short time before Dixon bought the land, say 10-12 years ago, Witcher proposed to sell the land to me for he was bound to raise money... otherwise he would sell for less to Dixon as he was his son in law. Gave evidence in a case against Tandy K. Witcher, don't recollect when or which case. Since that time [he] taught a school at Griffith's. /s/ James M. Draper

James Carnahan age 52 [character]. John F. Griffith

Leonard Jones age 57. Acquainted with John F. Griffith about two years... heard gossip. I moved into the neighborhood about two years last February... not mixed much. About 6 1/2 - 7 miles from Griffith. /s/ Leonard Jones

Joseph Crabtree age 33. Known John F. Griffith about 15 years, most of the time within 3 1/2 miles. Know Tandy K. Witcher. /s/ Joseph R. Crabtree

Edwin Price age 59. Friendly with Tandy K. Griffith in the early part of our acquaintance.

Ques: Was he not a very important witness against you in the case of Stephen Price against you in Chancery?

Ans: I suppose he was. Edwin [his X] Price

Walter M. Clark age 51. Know John F. Griffith. If he was interested in a case in any way, could not give full credit. Knew Tandy K. Witcher, could not give him full credit. /s/ Walter M. Clark

James Proctor age 44. Know John F. Griffith and knew Tandy K. Witcher, could not give either full credit. /s/ James Proctor

Pleasant Henley age 54. In 1840 Tandy K. Witcher was trying to sell me the land where Willmore now lives. Heard Witcher and his wife say they would have to sell the lower tract to raise money and would let Griffith's children have the upper tract. Don't think there's much difference between the two. Claiburn owed Dixon and he [T. K. Witcher] was security, about $400. I thought Dixon got a bargain. /s/ Pleasant Henley

Lewis Hicks age 35. Cannot give John F. Griffith full credit. /s/ Lewis Hix

John M. Clark age 35. Known John F. Griffith 8 - 10 years, live mile or some over. Could not give him full credit if he had an interest in a case. /s/ John M. Clark

Robert Richmond age 66 [or 67 - overwritten - mlj].

Had a conversation with Dolly Griffith wife of Samuel C. Griffith about July or August last at my house... I was scolding her that she had married Griffith so he could help her and her children, and instead they were waiting on and supporting Griffith and his children. She said she supposed it was true but if his children gained the land they were to make Griffith a deed and if they didn't there would be a separation.

Sam C. Griffith and Dolly Griffith do not live together. She lives on Henley Creek and he on Jennings. They are friendly and he visits her often. /s/ Robert Richmond

John McCue age 63. Lived between one-half and three-fourths mile of Tandy K. Witcher. Saw the family bible there, entries in his handwriting.

Samuel C. Griffith lived on the land in dispute in 1834, moved after his wife's death. I moved on the Creek in 1834 and he was living there then. /s/ J. M. McCue

Hiram Crabtree age 38. [Nothing new]. /s/ Hiram Crabtree

Robert F. Richmond 37. Was talking to Dixon about buying the land, could not agree on price. Someone told me better not buy it as Samuel C. Griffith's children intended to sue when they became of age. /s/ R. F. Richmond

BILL OF COMPLAINT of William C. A. Griffith and Nancy Griffith of Jackson County, Clayborn D. and Polly K. Griffith minors by their brother and next friend William C. A. Griffith of the same county against

William J. Dixon of Macon Co. and Ensley Willmore of Jackson Co, TN.

Complainants are the only children and heirs of Caroline Griffith, died in the year 1838, and at that time they were all minors.

William C. A. Griffith is now 22 years old the 7th May 1852.

Complainant Nancy D. Griffith is now 21 the 3rd April 1852.

Other complainants are still minors.

Their mother was a daughter of Tandy K. Griffith, who died in Feby 1852.

Complainants charge that some short time after their mother married their father Samuel C. Griffith, their grand father Tandy K. Griffith about 1830 purchased of James Tinsley a tract of land in the 16th District of Jackson Co. on Jennings Creek, about 192 acres. Tinsley made the deed to Clayburn Witcher and the said Clayburn [made the deed] to Tandy K. Witcher.

A short time later their grand father gave the land to their mother Caroline... executed a Deed of Gift to her during her life and at her death to her children. Said deed was never recorded and is now lost or destroyed for the purpose of cheating and defrauding complainants... Their mother and father took possession of said land in 1831 and held until their mother died in 1838, leaving complainants her only children in possession.

Shortly thereafter their father moved with his children into their grand father's house... their father still controlled the land where they had lived adjoining... Tandy K. Witcher sold said tract to William J. Dixon about 1850 or 1851 and they were all still minors.

[NEW] GRISHAM, J. P., Executor of GRISHAM, PRYOR 1914


I Prier Grisham ... sound mind and disposing memory... cancelling and revoking all wills...

1st Pay debts and burial expenses

2nd Beloved wife Martha Jane... the house place where I now live during her natural life in the 5th District of Jackson Co. on Martin's Creek... bounded north by land I recently sold to W. P. Grisham, east by land of G. W. Tittle, south by land I recently sold and conveyed to J. P. Grisham, west by land of J. C. Elrod and Miss E. V. Holleman... between 75 - 100 acres. At my wife's death land to descend and divest to all my children then living at the death of my wife share and share alike and my grand children will represent the share of their parent if not living.

3rd My wife Martha Jane the household and kitchen furniture... exempt to her by the laws of Tennessee. The balance to be turned over to my Executor... sold... distributed to my heirs. My wife Martha Jane... the farming implements she would be entitled...

4th Children of my son Nat Grisham who is now dead shall jointly receive the amount he would have received.

My daughter Mary who married N. B. Apple and who [Mary] is now dead... her children shall receive her share jointly.

5th If I should purchase any more real estate and own same at my death, I direct it be sold by my Executor and proceeds distributed to my heirs.

6th Any heir that becomes dissatisfied... legal proceedings... shall forfeit their right.

7th I appoint my sons J. N. Grisham and J. P. Grisham Executors. 24 April 1907.

/s/ Prier Grisham Wit: /s/ F. A. Kelly, G. R. Maddux

WILL PROVEN 7 November 1911... Prior Grisham died in Putnam County, Tennessee while absent from his house on a visit 2 November 1911, leaving an estate in Jackson County...

INVOICE: From J. P. Grisham, Guardian of Pryor Grisham, dated 6 Feb 1911:

Box Watkin's Salve, $.25

5 Quarts whiskey for M. J. Grisham, $5.00

Kelly Mercantile for medicine, $.35

Team working in garden, hauling wood, etc., $50.00

4 bbl flour from A. G. Hargis, $23.20

10 gal. sorghum @ $.50 per gallon, $5.00

Expense taking dep at Carthage, Gross vs Grisham, et al, $5.50

Bob Stanton for Beef for Pryor Grisham, $.70 TOTAL $90.00

I certify that I paid the above expenses for the benefit of Pryor Grisham and his family. /s/ J. P. Grisham, Guardian

FINAL SETTLEMENT, Distributive Shares paid to:

1. W. P. Grisham, sr.

2. Janie Pharris

3. Celia Apple

4. Elizabeth McKenney

5. Viola Lewis

6. J. P. Grisham

7. Mary Apple she is dead and her share belongs to her children Edgar Apple and Jessee M. Apple, each receiving one-half of his mother's share.

8. Nat Grisham he is dead and his shares belongs to his heirs to wit, one-fourth their father's shares to wit: [1] Houston Grisham [2] Herman Grisham [3] Haschal Grisham [4] Gordian Grisham married [blank] Austin she is dead leaving two children Ernest Austin and [blank] Austin and they are minors. G. L. Bush is the legal guardian.

9. J. H. Grisham he is dead and his share belongs to his children [1/8 each] to wit: [1] Alvin Grisham [2] Ira Grisham [3] W. P. Grisham Jr. [4] Weston Grisham [5] Belle McDonald her share paid to her husband and guardian W. A. McDonald and shares of next three paid to their legal guardian L. A. McDonald [6] Henry Grisham [7] Mary Grisham [8] Tina Grisham

PETITION of J. P. Grisham vs Prior Grisham. Prior Grisham their father is 83, of unsound mind and for 10 - 12 weeks has been unable to attend to business... 2 December 1907. /s/ J. N. Grisham, J. P. Grisham

INVENTORY & SALE OF PERSONAL PROPERTY at residence lately occupied by Pryor Grisham deceased near Granville on Saturday December 2, 1911 [four pages of household items sold, to whom sold, amount paid. Also lists separate sale of farm implements, two pages, 9 January 1908. Also lists two pages of notes due to Pryor Grisham.

[NEW] GUINN, W. H. vs GUINN, MATTIE Circuit 1898

POWER OF ATTORNEY to John Cale. You are authorized to sign my name... bill for divorce of W. H. Guinn against Mattie Guinn as attorney in fact... sign bond for costs. 27 October 1898. J. H. [his X] Guinn, G. W. [his X] Guinn Attest: T. D. Guin

BILL OF COMPLAINT of W. H. Guinn against Mattie Guinn both of Jackson County. Married about April 1895, Jackson County where they resided since except Complainant lived in White County about four months... happy about eight months... certain young man whose name I do not wish to mention began to show his respects to her... became public. Alleges adultery... has child about six-eight months old... I do not know who its father is. 27 Oct 1898

[NEW] GARRISON, BETTIE vs GARRISON, LEX, both of Jackson Co. Married June last in Jackson Co., together until about October 1, 1893 when defendant abandoned, refuses to provide or live with complainant... asks divorce, maiden name Hawkins be restored.

Owing to poverty she is unable to pay expenses. 6 March 1894. Bettie [her X] Garrison


SUMMONS Louraney Garrison to appear 1st Tuesday after 2nd Monday in November 1886 to answer Bill of Complaint of W. L. Garrison for divorce. 1st Tuesday after 2nd Monday in May 1886.

BILL OF COMPLAINT: W. L. Garrison of Jackson County against Louraney Garrison of Putnam County, Tennessee.

Spring of the present year, she the defendant attempted to take the life of Orator by beating up glass and putting it in food... which was detected before damage was done.

Afterwards tried to burn his house down.

Owing to poverty, unable to bear expense... 6 September 1886. W. L. [his X] Garrison


ANSWER of Belle German to Bill of Complaint filed against her by Monroe German. Married as stated, denies deserting him. Offered to live with Plaintiff and tried to get Plaintiff to live with her.

SUMMONS Marthula German to appear first Tuesday after 2nd Monday in September 1882 to answer bill for divorce of Monroe German.


DECREE: Plaintiff and Defendant were married as charged. John M. Gipson willfully neglected to provide for Complainant or their infant child... has gone to parts unknown. Frances to have control and custody of infant Wm J. Gipson [no date]


BILL OF COMPLAINT of Lude Gipson. Married in Jackson County 188[blank]. Thereafter he was convicted in Jackson County of crime of Larceny in Circuit Court, sentenced to serve in the penitentiary and to be rendered infamous. Asks divorce, name changed from Lude Gipson to Lude Cornwell, her maiden name.

Owing to poverty, unable to bear expense. 1 Nov 1887. Lude [her X] Gipson


BILL OF COMPLAINT of Bertie Goolsby of Jackson Co., TN against Bill Goolsby a none-resident of Tennessee and resident of California. Married in Jackson County 1907, together about two years. Defendant sold everything he had and went to the State of Illinois and stayed 3 or 4 months, didn't hear from him during that time.

Returned, stayed two years, sold everything they had and left for California and been there since October 1911. A few weeks ago she had a letter saying he never intended to return to Tennessee or live with complainant. Asks divorce, name changed to White, her maiden name. 10 May 1913. /s/ Bertie Goolsby


BILL OF COMPLAINT of Martha Goolsbie, states were married 5 January 1881, lived as husband and wife to July 25, 1881... he is guilty of visiting lude [sic] houses... one David White keeps a lude house. Failed to furnish anything to subsist on.

Due to poverty she is unable to pay expenses. April [smear] 1882. Martha [X] Goolsby

SUMMONS: Milton Goolsby to appear 1st Tuesday after 2nd Monday in May.

[NEW] GORE, W. C. vs GORE, SOPHIA 1886

SUMMONS Sophia Gore to answer Bill of W. C. Gore for divorce, 1st Tuesday after 2nd Monday November next. Dated 1st Tuesday after first Monday in May 1886.

BILL OF COMPLAINT of William C. Gore of Davidson County against Sophia Gore of Jackson County. Married about 14 years ago in Jackson County. Five children the issue of marriage, Jessee, James, Burnett, George R. and Samuel, all in his custody.

About 2 1/2 years ago defendant abandoned... refused to live with him. He is in business in Nashville making a good living... he has tried on more than one occasion to get defendant to live with him, help raise children, has nothing to do with him or them. 26 October 1886 /s/ W. C. Gore.


BILL OF COMPLAINT of John F. Guinn against Dealie Guinn, both of Jackson County, Tennessee. Married in Jackson Co. 19 Nov 1903, together two months but not happily. Defendant became very jelious [sic] quarlsom [sic] and refused to cook... abusive and was forced to abandon her... was not guilty of the charges she accuses. July 3, 1909. John F. [his X mark] Guinn

DEMURRER of Delie Guinn to Bill of Complaint of John F. Guinn. Bill insufficient at law, no grounds for divorce, asks it be dismissed. /s/ John H. Stafford, Sol. for Deft.

ANSWER: Delia Guinn to Bill of Complaint of John F. Guinn. Married in Jackson County 28 September 1902, together until 19 December 1902. Denies she became jealous, refused to cook... refers to a bill filed July 5, 1909.

Loves complainant does not want divorce, admits his support has been scant. As a result of marriage, have a child Erschel who has always lived with her and respondent has worked to support him. Complainant has given the child $1.00 in money and a suit of clothes worth $1.50... again avers she loves complainant, believes it his duty to help and support child. For much of time Complainant abandoned her she lived with Complainant's father and brother who can testify to her good conduct.


BILL OF COMPLAINT of Bettie Givens against James Givens, both of Jackson Co. Married 28 October 1882, abandoned her, failed to provide. Since marriage was born a female child of lawful parentage maintained by aid and assistance of her relatives and friends... defendant after he left has been seen with Sis Givens a base prostitute. Her child is now about one year old and she is informed he is about to seize said child and take under his control... believes would be neglected... asks divorce, child be decreed to her... name changed to maiden name Pharris. 28 August 1882.

[NEW] HAILE, AGATHA vs HAILE, JAMES M. Chancery 1877

BILL OF COMPLAINT of Agatha Haile of Jackson County against James M. Haile formerly of Jackson Co., now parts unknown. Married in Jackson Co. 24 September 1872. Defendant left her bed and board September 1874 and went to Arkansas, from there to the Indian Nation where he has remained since... failed to provide. About a year before he left, cursed... abused. About two years ago he took to his embrace a girl named Loula ?Steffenbrough, kept her all night... lewd intercourse... carried her next day to Bloomington... again violated his marriage vow.

Your Oratrix has by said marriage a son by the name of Jones [or Jonas] M. Hail about two years old. She has an interest in the real and personal estate of her father. 19 July 1875. /s/ Agatha M. Haile

AMENDED BILL OF COMPLAINT of Agatha Melvina Haile against James M. Hail. On 26 July 1875 she filed her original bill. Defendant abandoned her September 1874 at her mother's house in Jackson Co.

SUMMONS James Fields and Buck Wolf... give evidence in the case of the State vs James M. Haile for murder. 2nd Monday in September 1879.

INDICTMENT for Murder, James M. Hail alias Jim Hail. 2nd Monday in January 1880.

BILL OF COMPLAINT of Agatha M. Hail vs James M. Hail. Married 24 September 1872... slapped, abused, failed to provide since 6 December 1872. Her mother provided support... unsafe to live with him... property includes heifer, bed and bedstead given to her by her father James Mancel in his lifetime, bed and bedclothing given by her mother Sarah A. Mancel, widow of James Mancel, deceased.

Has an interest in tract of land in Dist. 12, Jackson Co., 170-175 acres. Complainant's mother holds as a homestead, complainant being entitled at her mother's death to land where her father lived at death.

Also another tract in Dist. 12, 100 acres known as the highwasee [Hiwassee] tract that James Mancel purchased from E. B. Jackson. Complainant is entitled to 1/6 of said tract.

Also tract in Dist. 12 bounded north by James M. Billingsley, east by Johnson, south by R. H. Jackson, west by Henry Jackson, supposed to be 75 acres, entitled to 1/6.

Also tract in District 12 bounded north by James M. Billingsley, west by R. H. Jackson, south by William R. Dyer, east by 75 acre tract spoken of.

Further, defendant took away $75 in green back and over $100 in hard money gold, besides $100 given him by her father in his lifetime. 19 May 1873. /s/ Agatha M. Haile

[NEW] HAIL, AMON vs HAIL, JOSHUA Chancery 1866

BILL OF COMPLAINT of Amon Hail Sr. of Jackson Co. against Joshua Hail, Adeline Putty, Samuel Johnson & wife Bell Johnson, William E. Putty, Vina Putty, Mary Putty, Margaret Putty, George Putty, all of Jackson Co. and Samuel Denison and Josephine Denison of Illinois.

William Putty departed life intestate [blank] 1865. Defendant Adeline Putty is his widow.

Defendants Denson & Johnson intermarried with daughters of deceased, viz Josephine and Bell.

Defendants William E., Vina, Mary, Margarett and George Putty are minors... children of said intestate with no regular guardian.

Prior to death of said intestate he and defendant Joshua Haile purchased in lifetime in partnership a dwelling, out houses and store houses of one John P. Murray in Flynn's Lick, Jackson Co., bounded by land of John P. Murray, Joshua Hail and the School land and Flynn's Creek... being dwelling and store house once occupied by Thomas J. Jones.

Orator was security for purchase price. 5 June 1866.

ANSWER: R. A. Cox, guardian ad litem to William Edward Putty, Vina Putty, Mary Putty, Margarett Putty and George Putty, minor heirs of William Putty, deceased... protect interest of his wards. 13 August 1866.

[NEW] HAILE, AMON vs HARE, SAMUEL E. et al Chancery 1848

BILL OF COMPLAINT of Amon Haile against Merlin Young, Sampson W. Cassetty, Samuel E. Hare and Samuel E. Stone all of Jackson Co.

31 January 1848 he purchased of defendants a negro boy named Jordan and took bill of sale... $550. Executed notes for $300 due one day after date; $125 due 1 June 1849; $125 due 1 June 1850 - bearing interest from 31 January 1848. Took negro in possession... with four days he became apprehensive negro was not sound and healthy... afflicted with Dropsy and afflictions of the liver... went to Defendants and requested trade be cancelled. 6 March 1848.

PROSECUTION BOND: Amon Haile, Principal with Thomas Huddleston & James M. Richmond Security to Defendants.

INJUNCTION: Defendants are enjoined from collecting, selling, trading notes... Appear and answer Wednesday after the 4th Monday of July next [1848].


BILL OF COMPLAINT of Benjamin Haile Against James Crawford, both of Jackson County. On 4 June 1853 he purchased from James Crawford an undivided interest on a tract of land on Line Creek, being 300 acres, agreeing to make a fee simple title...

Orator purchased at the same time of Robt Hibbit the other half of said land, took a bond for title.

Orator took possession, proceeded to improve. Paid to said defendant January 1854 $1117, $200 of which defendant handed back, making a payment of $917. Defendant holds Orator's note for the balance.

It is now clear defendant holds no title, that at the time of Orator's purchase, title was in the children of Henry Eakle, deceased and they are now seeking to sell land.

Hibbitt rescinded the trade, defendant has not.

PROSECUTION BOND, Benjamin Hail, Principal and P. H. Leslie, Security to James Crawford for $250.



Made in presence of the undersigned subscribing witnesses in her last illness in her own habitation in Jackson County, Tennessee 26 February 1875. Said subscribing witnesses being specially called by her to bear witness to said nuncupative will by the Testator herself.

Said Testator gave all her bedstead beds and bed clothing and household and kitchen furniture to her daughter Julia Darwin and husband Wm H. Darwin.

She gave all her stock to wit all her hogs and sheep to her daughter Julia Darwin and husband Wm H. Darwin.

She gave her heifer to her grandson Edward Darwin.

She gave her side saddle to her grand daughter Ida Darwin together with bridle and saddle blanket.

She gave to her grand son Nate Hail proceeds of a sixty five Dollar note on W. H. Darwin due 26th February 1875.

She gave to her daughter Julia Darwin and husband W. H. Darwin the rents of her land (her dower) for the year 1875.

On the 7 day of April or about that time she called on the undersigned subscribing witnesses to witness a change in her will -

She said that she then gave the sixty five Dollar note on W. H. Darwin due 26th February 1875 to her daughter Julia Darwin and husband W. H. Darwin instead of her grandson Nate Hail - she said that they had been at a great deal of trouble in waiting and caring for her in her sickness and she wanted them to have enough to pay them for their trouble with her and to pay Dr. Fink her physician and hence she said she made this change in her will -

She left all the balance of the will unchanged and as above written - this change was made by her the said Lockey Hail in her last sickness in her own habitation in Jackson County, Tennessee per the undersigned being specially called upon by her to bear witness to the same nuncupative will [crease; can't read 2 - 3 words -mlj] The same was this day reduced to writing in our presence as the nuncupative will of Lockey Hail deceased June 7th, 1885. /s/ W. T. Cooper, W. R. Chilcutt } Subscribing witnesses

POWER OF ATTORNEY: State of Texas, County of Erath}

We B. Sadler and wife Sarah A. Sadler formerly Sarah A. Haile, daughter of Amon Haile, appoint M. D. Haile of Jackson County, Tennessee to take charge of our entire interest in the estate of Amon Haile, deceased... 27 August 1894.

[Acknowledgment by Notary, Erath Co., TX but actual signature page missing - mlj]

NOTICE TO SHERIFF of Jackson Co., TN. Summons William Darwin to appear and show why he should not be made party, appear August term 1868... Elizabeth Hail is Plaintiff and Locky Hail and others are defendants. The said William Darwin having intermarried defendant Fox since the commencement of this suit. Dated 1st Monday of February 1868.

ANSWER: James Draper, guardian ad litem for minor defendants Harriet E. Haile, Thomas R. Haile, George G. Haile, Charles Haile, Margaret S. Haile, Jennie Haile, Margaret McClelland, Mariah McClelland, Nathaniel Haile and Martha McClelland to Bill of Complaint.

True Amon Haile is dead and they are descendants. True complainant purchased land for price mentioned, executed notes...

Came before me, Harriet E. Haile, George G. Haile and Margaret E. Haile, all over age 14. June [blank] 1868. /s/ H. E. Haile, G. G. Haile, M. S. Haile

NOTICE TO SHERIFF of Jackson Co., TN. Summons Lockie Hail, Dudley B. Hail, Nicholas P. Hail and wife Nancy Hail, Julia Fox, Joshua Hail Jr., Mary A. Hail, George G. Hail, Charity Hail, Margaret S. Hail, Jennie Hail, Nathaniel Hail... appear 1st Monday in February 1868 to answer bill of Elizabeth Hail. Dated 1st Monday in August 1867.

DEPOSITION 9 June 1869.

Jessie Hogg age 52. Was present in Flynn's Lick at office of Dr. U. T. Brown in 1867 when a contract was made between Complainant and Amon Hale, Sr. now deceased... myself and Dr. Brown witnessed... Elizabeth Hale then at that time paid Amon Hale $587. No deed or bond for title was signed... agreed by parties to wait until Joshua Hale Jr. a son of Complainant and a lawyer should come home and it was agreed he would do the writing and fix up the papers.

Amon Haile was said to be killed in September 1867 by a tree falling on him... found dead as I understand. I did not see him... was gone from home but have no doubt...

John Rollins had possession of the house and lot and Amon Haile had possession of the land and he had rented to said Rollins for that year 1867 and Mrs. Haile got possession from Rollins before the year was out... She never moved there until after Amon Haile died. /s/ J. T. Hogg

BILL OF COMPLAINT of Elizabeth Haile of Jackson County, Tennessee against Lockie Hail, Dudley B. Haile, Nicholas P. Haile and wife Nancy Haile, Julia Fox, Joshua Haile Jr., Mary A. Haile, George G. Haile, Charlie Haile, Margret S. Haile, Jennie Haile, Nathaniel Haile, all of Jackson County, Tennessee the five last mentioned are minors; Peggy Ragland, Joshua Haile Sr., Bartlet A. Fox and wife Leathie Fox, William A. Fox and wife Lettie Fox, Amon G. Haile, George Haile, David F. Haile, Sarah Craig, Thomas R. Haile, Nancy C. Haile and Missouri E. Haile of the State of Texas and defendant Thomas R. Haile is a minor; E. L. Haile of Indiana; Harriett E. Haile a minor defendant of Kentucky; Margaret M. McClellan, Mariah McClellan and Martha McClellan of the State of Illinois minor defendants.

Oratrix [Complainant] on 15 May 1867 purchased of Amon Haile Sr. two tracts of land,

1st Tract in Dist. 11, Jackson Co., on Flynn's Creek in the village of Flynn's Lick bounded by land of Joshua Haile Sr., land known as the Camp Ground lot bounded by land known as the Simpson lot and by P. M. McCarver on the south, about 1 1/2 acre.

2nd Tract on Flynn's Creek, Dist. 11... begin where lines of P. McCarver and Joshua Haile Sr. intersect opposite a pond of water where John Skimmerhorn lives... up said creek with P. McCarver's line... near Amon Haile's Jack Stable.

Oratrix never took possession or received bond for title... as soon as Joshua Haile Jr. a son of Oratrix came home from Livingston where he was in business as a Lawyer... was to draw a deed.

[Blank] Term 1867 Joshua Haile Jr. was appointed Administrator of intestate and her note of $200 balance for land came to his hands.

Intestate was largely indebted...

Defendants to this Bill are the widow and only heirs of said intestate.

Oratrix will show by proof her payment of $600, execution of $200 note and delivery of a horse of the value of $100. 20 December 1867. /s/ Elizabeth Hail

POWER OF ATTORNEY: J. Wesley Ragland and wife M. G. Ragland of the State of Texas, County of Collin, do appoint M. D. Hail of Jackson County to collect ... due me Margaret G. Ragland as one of the children of Amon Haile, deceased. 17 September 1894. /s/ J. W. Ragland, Margaret G. Ragland

[NEW] HAILE, G. G., Administrator of HAILE, N. P., deceased County 1888

NOTICE to Thomas Haile, M. D. Haile, John Haile, J. F. Haile, Martha J. Reed and husband Samuel Reed, heirs at law of N. P. Haile, deceased... Saturday 26 May 1888... Administrator's Settlement with George G. Haile, Administrator of estate of N. P. Haile, deceased... C & M office, Gainesboro... attend if you wish.

NOTICE to Henry P. Loftis and wife Julia Ann B. Loftis, W. C. Reed and wife Nancy L. Reed, Kinnor Dudney and wife Mary E. Dudney and Mansell Haile, heirs of N. P. Haile, deceased... Will make Administrator's Settlement with George G. Haile, Admr of N. P. Haile on 26 May 1888... may attend. Dated 1 April 1888.


Some assets listed included rent of Free State land years 1884 of $100 and 1885 of $107.19; logs shipped to Nashville in 1885, $432.

Some expenses include Medical Services of G. C. Jourdon rendered in 1884, receipt dated Jan 31, 1885; Medical Services of S. C. Stamp, receipt dated January 31, 1885.

Administrator's Bond dated 14 February 1885.

[NEW] HAILE, GEO G., Executor of HAILE, JOSHUA County 1899

ANSWER of defendant George G. Haile to Bill of Complaint of James K. Richmond. States that before commencement of this suit to wit on 3 March 1902 he as Executor of the estate of Joshua Haile deceased suggested the insolvency of said estate, gave notice... published... any claim not presented will be barred.


William C. Gore [No age]. Live 404 - 2nd Street, Nashville, am a work house guard. Paid account March 1, 1894 to Joshua Haile that I owed to J. K. Richmond, about $40. /s/ W. C. Gore

Ed Blankenship (col), age 28. Live 220 S. colledge [sic] st, Nashville. Work for E & N Factory. Paid the account I owed Richmond & Hix in 1894 to Mr. Haile in the 1st Natl Bank of this city. /s/ Ed Blankenship col

PROVISIONS FOR WIDOW: Commissioner appointed, set aside to Mary Haile, widow of Joshua Haile on 8 November 1889: 1 bay sucking Colt, 5 head of hogs, one sow & pigs, one ward robe... Total value $89.

SETTLEMENT recorded 28 February 1902, personal inventory, Record Book "C", page 576.

DEPOSITIONS 24 October 1902, cause of Robert Nemore vs G. G. Haile, Administrator of Joshua Haile, taken in Gallatin, Tennessee.

Joel H. Anderson age 24. Know Robert Nemore, knew Joshua Haile. I was a witness to Robt Nemore's mark on a note. /s/ J. H. Anderson

COPY OF NOTE: 18 September 1899. Joshua Haile paid us in full for all we done for him in his lifetime by giving us a mule a wagon and one Berkshire sow and to Elizabeth Nemore a life estate in a tract of land which we accepted and now agree shall be in full of all claims rights or demands we may have had or now have against said J. Haile or his estate. This Sept 18, 1899. Bob [his X] Nemore, Elizabeth [her X] Nemore

Witness: /s/ Nathan Huff, Fanny D. Quarles

Attest: J. H. Anderson as to Bob Nemore

NOTICE OF DEPOSITIONS cause of Richmond vs Haile to be taken 28 March 1902 at the office of The Arlington Hotel, Nashville, Tennessee of J. K. Richmond, R. H. Neal, Wm Gore, Ed Blankenship col and Henry Walker col. [Not all depositions filmed, may not have been taken. Regarded notes and payments, no relationships].

R. H. Neal 41, am a Wholesale Grocer, live Nashville. /s/ R. H. Neal

J. K. Richmond, am a Hotel Keeper, live Nashville. /s/ J. K. Richmond

[NEW] HAIL, J. F., Admr of MARY BRANTLEY vs BOTTS, W. H. Chancery 1881

Affiants E. C. Stamps and J. J. Stamps state they are entitled to funds sought to be recovered in this case.

The intestate Mary Brantley was entitled to funds as heir at law during her life of John Stamps, deceased. She died without issue. Affiants are her heirs at law together with John Stamps and Kinnard's heirs.

E. C. Stamps is the owner of the interest of John Stamps by transfer and assignment. 1 October 1881. /s/ E. C. Stamps, J. J. Stamps

DECREE: Whereas, it appeared to the Court April term 1878 that Mary Brantly formerly Mary Hail who was a grand daughter of John Stamps, deceased of Jackson Co., TN died intestate in Stoddard Co., Missouri on [blank] 1862, leaving an estate in Jackson Co. Court appointed Administrator, J. F. Haile, to make bond.

PETITION of J. F. Haile... away back yonder before the war perhaps some time between 1856 and 1859 one John Stamps died intestate leaving lands in Talley's Hollow or the neighborhood thereof in Jackson Co. descending unto his lawful heirs and widow Polly Stamps. Said John Stamps had a daughter Nancy. She intermarried with one William Haile and before the death of her father, she died leaving a daughter Mary Haile the issue of said marriage and her only child. Said Mary is now dead but she was living at the time her gr[crease; probably "grand father died" - mlj].

Mary Haile was entitled to an equal share with the children of said John Stamps. The land sold for distribution many years ago.

E. C. Stamps and James Stamps, children of the deceased John Stamps filed a bill against the widow Polly and other heirs to wit J. R. Stamps, Jane Kinnard, John Kinnard and Montgomery Kinnard [crease; several words hidden - mlj] procured a decree for sale... sold on or about 3 September 1859. Said Mary Haile was then living and lived two years thereafter.

Said Mary Haile before her death intermarried one Abraham Brantley but he is dead and died before she died. She died some time about May 1862.

Said land fund was to be divided in five shares, to wit one each to James Stamps, E. C. Stamps and Mary and one to the Kinnaird heirs making five [No, doesn't add up, but I typed what was there. See deposition below of J. J. Stamps - mlj].


J. J. Stamps age 47. I am a son of John Stamps, deceased. I received my interest in sale of land believe prior to June 1874. I do not know if John and Elijah Stamps were paid. /s/ J. J. Stamps

Wm Loftis age 43. I purchased the land from E. C. Stamps, paid W. H. Botts, former Clerk & Master, $200. /s/ Wm Loftis

SETTLEMENT AFFIRMED: It appeared to Court from proof that James L. Hale is a distributee and the only distributee of said Mary Brantley, deceased and that J. F. Haile, Administrator of said Mary Brantley has paid him... [No date, but receipt immediately following is dated $4 January 1883, $80.00 and signed "J. L. Hale" - mlj].

AFFIDAVIT of James L. Hale of St. Cloud, Missouri, swear I am the only distributee of Mary Brantley, deceased... 1 December 1882. /s/ J. L. Hale

Acknowledged} State of Missouri, Scott Co.

[NEW] HAILE, JAMES M. et al vs MANSEL, SARAH, et al Chancery 1874

ANSWER of Jane Spears and Emily Vance, married women, by their guardian ad litem B. B. Washburn to Bill of Complaint by James M. Haile and wife Agatha Haile.

James Mansel died intestate in Jackson County, Tennessee... Sarah Mansel is his widow. Henry Jackson is the administrator of James Mansel, deceased. 8 September 1875.

PART OF NEXT DOC MISSING... [Begins "Complainants pray" without saying who they are - mlj]... those named be made defendants... all lands of James Mansel deceased including reversionary interest in widow's homestead and dower be sold for distribution; that the pretended heir of James Mansell deceased Cicero Spears alias Cicero Mansell be compelled to prove his heirship. /s/ J. F. Haile, Sol.

Comes J. F. Haile, Solicitor... those named in foregoing are non residents of Tennessee to the best of my knowledge. 18 April 1874.

[Note: This case continues after next case. that of Haile v Stafford - mlj].


BILL OF COMPLAINT of John N. Haile a resident of Jackson County, Tennessee against Sarah Stafford, alias Haile, a resident of Kentucky.

Complaint on [blank] May 1873 owing to threats and epithets made against him... coercion exercised against him by one Arch Stafford, defendant's father and John Stafford, defendant's brother, both of Jackson County, complainant did intermarry in Jackson County with defendant Sarah Stafford alias Sarah Haile... not willingly... duressed and forced in order to save his own life or great bodily harm as he then believed and yet believes.

They married about the last of May and he abandoned her shortly thereafter... duress... does not consider her his lawful wife. 16 Feby 1874. /s/ J. N. Haile

NOTICE TO SHERIFF: Summons James Young, Lafayette Wheeler and James Wheeler of Jackson County, Tennessee, to appear and give evidence 4th Monday in April 1874.

BOND: John Haile and J. F. Haile to Sarah Stafford alias Sarah Haile, $250.

DECREE} Nullity of Marriage. It appeared to satisfaction of Court that Sarah Stafford alias Sarah Haile... a non resident of the State of Tennessee... published in Jackson County News... defendant failed to appear the 4th Monday in April 1874... Complainant's bill taken for confessed... marriage as set forth... be and is a nullity... set aside.

[NEW?] HAILE, JAMES M. et al vs SPEARS, JANE et al Chancery 1874

[NOTE: This case is in a new folder, appears to be continuance of case James M. Haile et al vs Sarah Mansel, et al, documents mistakenly separated when filmed - mlj].

BILL OF COMPLAINT of James M. Haile of Jackson County against

Jane Spears and husband Amous of the State of Kentucky, Emily Vance and husband Thomas Vance and Jane Brooks and Josephine Brooks, children of Eveline Brooks deceased of the State of Missouri; Sarah A. Mansel and Henry Jackson of Jackson County, Tennessee; Cicero Spears alias Cicero Mansel of the State of Illinois, defendants.

James Mansel died in Jackson County, Tennessee in 1872 where he had resided several years before his death.

That Jane Spears who on [blank] 18[blank] married Amous Spears,

Emily Vance married Thomas Vance,

Agatha Haile married James M. Haile on [blank] September 1872 are his only heirs at law. [Note: Divorce on this reel, Agatha Haile vs James M. Haile - mlj].

Eviline Brooks married Elijah Brooks [blank] and died [blank] leaving Jane Brooks and Josephine Brooks her only heirs. Her husband Elijah Brooks died.

That Cicero Spears alias Cicero Mansell claims to be an heir of said James Mansell deceased.

Complainants charge said Cicero Spears alias Mansell is not an heir.

Those named as such in the caption of this bill are non residents of Tennessee.

Complainants James M. Haile and wife Agatha M. Haile are residents of Jackson County, Tennessee.

James Mansell died seized and possessed of property in District 12, being 60 acres, bounded by James Billingsley, Jefferson Jackson and others; tract in Jackson Co., 100 acres more or less bounded by John I. Pippin and others.

Tract of 175 acres more or less where he lived and died bounded by James Petty and others.

Sarah A. Mansell is his widow. Personal estate is sufficient to pay expenses. Ask land be sold and proceeds distributed... four equal shares, one of these shares to be divided into two equal parts.

[NEW] HAILE, JOSHUA vs HAILE, E. L. et al Chancery 1897

PETITION of J. B. Hancock of Erath Co., Texas, asking to become defendant... cause of Joshua Haile vs E. L. Haile filed [blank] 1898.

Petitioner on 5 August 1897 purchased the interest of E. L. Haile in the estate of Elizabeth Haile, deceased in Jackson County, Tennessee 189[blank]. Upon the death of Elizabeth Haile, E. L. Haile became the owner of 1/11 interest, she having made a will devising to her heirs equally... Property to be sold and proceeds distributed among her children, children to account for indebtedness to her. E. L. Haile was not indebted to her.

Soon after making said will and the death of Elizabeth Haile, on 14 November 1895 George C. Darwin and wife Harriett Darwin, Pleas Chilcutt and wife Maggie Chilcutt, J. K. Richmond and wife Jennie Richmond filed their bill against George G. Haile in his own right and as administrator of Elizabeth Haile, deceased... to have land sold.

Petitioner knows nothing of indebtedness of E. L. Haile to John Haile... he bought the interest in good faith. 26 March 1898. /s/ Pleas Chilcutt, Atty in Fact & Agent

DEED: State of Texas, Erath County} I, E. L. Haile of Erath County, Texas for $100 cash sell... quit claim... all interest... estate of Elisabeth Haile, late of Jackson Co. August 5, 1897... /s/ E. L. Haile

Notarized Erath County, received for registration in Jackson Co. 15 August 1897.

BILL OF COMPLAINT of Joshua Haile of Jackson County, Tennessee against Elvis Lafayette Haile of Erath County, Texas and G. G. Haile and J. M. Morgan of Jackson Co., Tennessee.

On 16 May 1895, Elizabeth Haile made and published her Last Will & Testament... after debts paid, willed the rest to her children to wit Joshua, Haile, E. L. Haile, Lizzie Watson, Mary Hancock, Harriett Darwin, T. R. Haile, G. G. Haile, Charley Haile, Maggie Chilcutt, Jennie Richmond.

Also provided that her daughter Nannie Hancock being deceased that her children receive her share.

E. L. Haile is entitled to 1/11. Testatrix required those children who are indebted to her by notes repay same to estate, [namely]: Joshua Haile to J. K. Richmond, transferred to said Testatrix, note dated August 1889 for $400; Joshua Haile, note dated July 26, 1889 for $105 with $15 credit; Joshua Haile, dated April 22, 1885 for $85.50. Son G. G. Haile, unpaid rents where he lives. Daughter Harriett Darwin for $100 and one milk cow.

Elizabeth Haile died seized and possessed of two town lots in Flynn's Lick, District 11 and half interest in the Arbor lot belonging to Elizabeth Haile and J. Haile. Also land in District 11 known as the Amon Haile tract bounded north by Draper, east and south by G. C. Darwin, west by Lee being about 40 acres.

Complainant will further show... 18 Nov 1895 Geo C. Darwin and wife Harriett Darwin, Pleas Chilcutt and wife Maggie Chilcutt and J. K. Richmond and wife Jennie Richmond filed their original bill against Geo G. Haile in his right and as Administrator of Elizabeth Haile deceased, Joshua Haile, E. L. Haile, Jos [or Jas] Watson and wife Lizzie Watson, T. B. Haile, Charley Haile, Bluford Hancock and wife Mary Hancock the children and heirs at law of Nannie Hancock deceased to have the land and town lots sold and proceeds distributed... [blank] 1896 decree made and Geo G. Haile became purchaser of 40 acres at $800 and Joshua Haile became purchaser of town lots at $1630 [both made down payment, signed notes].

E. L. Haile in 1868 executed his promissory note to Complainant for $75 with interest, now amounts to $202, is justly due. E. L. Haile left this state in 1868 or first of 1869... has been about from the State ever since... now and has been for many years a citizen of the State of Texas.

Asks property of defendant E. L. Haile be attached. 23 Dec 1893. /s/ Joshua Haile

POWER OF ATTORNEY 16 June 1894, Erath County, Texas} J. B. Hancock and wife M. A. Hancock appoint Pleas Chilcutt. /s/ J. B. Hancock, M. A. Hancock

POWER OF ATTORNEY 4 Sept 1894, Washita County, Territory of Oklahoma} G. W. Haile of Washita Co., I.T. appoint M. D. Haile of Jackson Co., TN /s/ G. W. Haile

POWER OF ATTORNEY 27 September 1894, Fannin County, Texas} B. A. Fox and wife A. G. Fox appoint M. D. Haile of Jackson Co., TN /s/ B. A. Fox, A. G. Fox



Joshua Haile [No age, no date]. On 24 November 1884 G. W. Petty and wife Nancy Petty conveyed land to W. C. Young. 23 September 1886 W. C. Young and wife Aletha Young sold the land to John W. Patterson, who executed promissory notes due 1st May 1887, 1888, 1890 and 1891. I purchased the notes, paid in livestock. Notes were secured by a mortgage.

I purchased the property, lived in it and occupied myself or rented it to a tenant since 1888. About 1 January 1898, I moved out, fastened the doors. April 1898 I rented it to Daniel Hunter for the balance of the year. He moved out 8 January 1899, and "defendant slipped in as Hunter went out". Aletha Young filed her bill for divorce against W. C. Young before 1892, she has no right to possession. I have the deeds. [Basically states James Jackson has no right to possession, wants him evicted - mlj]. /s/ Joshua Haile

G. G. Haile age 45. I am the Executor of the Last Will & Testament of Joshua Haile, who died 1 September 1899, probated 1st Monday in September 1899. It [the will] devised property included in the deed from George M. Petty & wife Nancy P. Petty to W. C. Young & wife Aletha Young...

Aletha Young lived about 2 1/2 miles from the town of Gainesboro, west from Gainesboro out the Gainesboro Flynn's Lick Road.

My brother Joshua Haile moved out of the dwelling house on said property about the 1st of the year 1898 to the late residence of John P. Murray in the town of Gainesboro [where he died]. /s/ Geo G. Haile

[NEW] HAILE, JOSHUA & HAILE, G.G. vs JOHNSON, D. B. Chancery 1899

DEPOSITIONS 4 September 1902:

Dr. S. B. Fowler, occupation Physician for about 24 years, graduated from Ohio Medical College, Cincinnati Poly[?clinic], Medical College of New York.

Ques: Did you wait on old John P. Murray after he married Mrs. Sallie Murray?

Ans: Treated both of them. Col. John P. Murray died from Tuberculosis. It was confined mostly to his bowel... during Col. Murray's lifetime she developed a bowel condition... developed a condition that was real dangerous... had quite a number of large mucos [sic] discharges... continued until she left my country. This was during the year 1896. Col. Murray died December 21, 1895. Col. Murray and wife ate off of a small table together... consider Tuberculosis contagious. I think she contracted her trubble [sic] from him.

Ques: State if her complaint wasn't dangerous and will likely kill her yet.

Ans: Don't know anything about her condition now. [Was also questioned about land value where Murray & wife had lived - mlj]. /s/ S. B. Fowler

Mrs. Sallie Russell. I was married to Col. John P. Murray, recently married a man by name of Russell. J. P. Murray died 21 December about 1895. My condition is not very good... better than at his death.

I wrote D. B. Johnson some time back and told him I was not well...

Ques: State what your father died with... name of the disease that killed him.

Ans: I have always been told he died of consumption...

Ques: State whether or not his people were subject to and several had consumption.

Ans: Yes this whole family died of consumption.

I sold my homestead and dower to the firm of Joshua Haile and D. B. Johnson.

I will be 29 my birthday. I was married two months ago the 8th day of this month.

My house was burned and the worry and excitement has caused me to feel worse than I otherwise should. 11 Sept 1902. /s/ Sallie Russell


DECREE 22 December 1877: In favor of Complainant against Clinton Jones, $25.20. J. D. Richmond and William Lawson, Security. Concerned rent on land, no relations given.

[NEW] HAILE, JOSHUA vs MONTGOMERY. J. A. Chancery 1874

INJUNCTION BOND: Joshua Haile, Principal to J. A. Montgomery and James T. Anderson for $275 dated 26 September 1874.

DEPOSITIONS 14-19 Sept 1885 [Asked M. B. Young one question a day - mlj]:

M. B. Young [No age]. Long before the Court House burned a suit was pending, Nathan Pharris against James Draper as Administrator of James Pharris. Myself and Joshua Haile represented Nathan Pharris. /s/ M. B. Young

J. W. Smallwood, age 57. Was elected Sheriff of Jackson County March 1868, for three successive terms, went out in 1874. /s/ J. W. Smallwood

BILL OF COMPLAINT of Joshua Haile. Orator would show that [blank] 1874 Nathan Pharris filed against James Draper as Administrator of James Pharris. Nathan Pharris has been dead more than six months and no one has been procured to administer on his estate. He died a citizen of Kentucky. Dated 4 June 1881. [Note: This document has severe bleed-through, very difficult to read - mlj].

ANSWER of James A. Montgomery, Administrator debonis non [distributor of any portion of estate not already distributed] of James Pharris, deceased to Bill of Complaint of Joshua Haile and M. B. Young filed 4 June 1881.

James Draper as Administrator of James Pharris recovered judgment against Nathan Pharris. True Complainants were security of Nathan Pharris. True Nathan Pharris took said cause to the Supreme Court of Tennessee by appeal on advice of his attorneys. Elizabeth Burris became his Security for costs of appeal. James Draper died pending said appeal. Respondent qualified as his Executor.

NOTICE TO SHERIFF: Joshua Haile and M. B. Young filed a Bill of Complaint against J. A. Montgomery, Administrator of the Estate of James Pharris charging J. A. Montgomery obtained a fraudulent judgment against them... enjoined in collecting until case heard.


BILL OF COMPLAINT of Joshua Hale, a citizen of Jackson Co. against Zachariah VanHooser, Administrator of William Pryor, deceased, Dorothy Prior and Sarah J. Prior, all of Jackson Co.

Orator about 13 May 1853 sold William Pryor part of a 200 acre tract (supposed to be 150 acres more or less), a portion having previously been sold to P. N. Dudney on Doe Creek, District 1 in Jackson Co... for description refer to deed from Sam E. Hare to your Orator. Orator made a bond for title, balance unpaid of about $305.10... notes due 25 Dec 1854 and 1855.

About [blank] September 1854 said William Pryor departed this life intestate in said County leaving Dorothy Pryor his widow and Sarah J. Pryor his only child.

Orator and defendant Hoozer at October term 1854 were appointed Administrators... estate considerably indebted. Owns two small tracts besides the one purchased from Orator. Sarah J. Pryor is a minor... no regular guardian. Asks land be sold with proceeds first applied to payment of Orator's claim.

ANSWER of Dorothy Pryor widow of William Pryor. True husband died, and land must be sold, asks for overage to which she may be entitled. Dorothy [her X] Pryor

[NEW] HAILE, JOSHUA vs YOUNG, W. C. et al Chancery 1893

AFFIDAVIT of Aletha Young, states $100 remains to be paid on property plus interest on the $500 for the year 1898 and to now. A fee simple title in property is only worth $500, affiant only owns a life estate and has a large family of small children... no way of supporting except by the land. 14 March 1901. Aletha [her X] Young


Ellis Howell age 52. Live 1st District, Jackson Co., am a farmer. Known parties to suit 20 years, know land. Soney [sic] Young and Aletha Young had it done [the house built]. Alex Hestand was the carpenter. I helped build the house. Joshua Haile sold the property to W. C. Young about fourteen years ago. Ellis [his X] Howell

BILL OF COMPLAINT of Joshua Haile of Jackson County against W. C. Young, a non-resident of the State of Tennessee, Aletha Young and James Jackson of Jackson County, Tennessee.

On 24 November 1884 by registered deed, George M. Putty and wife Nancy P. Putty conveyed to W. C. Young and his heirs on 24 Nov 1884 by registered deed a tract of land just west of Gainesboro... crossing Brooks ferry road... Williams line... Washburn line to the Flynns Lick and Gainesboro road, about two acres. Geo M. Putty was owner, wife Nancy P. Putty relinquished her right to homestead.

W. C. Young is a non-resident, residence unknown to Complainant... has been his condition for some time. 17 [Blank] 1891 he was indicted in the Circuit Court of Jackson Co. and was convicted and sentenced to the penitentiary [more on this elsewhere, believe State of Tennessee vs Young, William C. - mlj]. His wife Aletha filed bill for divorce and decree was entered 8 July 1892, bonds of matrimony dissolved... homestead decreed to her. In addition, she is now claiming homestead on herein land... 7 March 1899.

DEPOSITIONS 18 April 1901:

Mrs. Aletha Young [No age]. I heard a conversation between W. C. Young and Joshua Haile when I lived at the poor house... They made a trade for the house and lot. When W. C. Young was in jail the first time he ordered his children to bring him his papers and I have never seen them since. I have four minor children, ?Rufs [Could be Russ or Rufus, don't know] 20, Thom 18, Cleo 15, Madi_ _ 13.

J. H. Dennis, of lawful age. Aletha Young is my sister. /s/ J. H. Dennis

[NEW] HAILE, LELA vs HAILE, D. B. JR. Chancery 1880

BILL OF COMPLAINT of Lela Haile against D. B. Haile, Jr, both of Jackson Co. Married July 1879 in Jackson County. Alleges abuse, states 4 June 1880 he abandoned her, she is destitute... removed meat and lard, locked up the corn [lists personal property including crop growing on land of D. B. Haile].

Alleges adultery with Milly Pharris a woman of notorious lewd habits... cannot state precisely the times and places... April or March 1880 on the ridge between Flynn's Creek and Ft. Blount on Big Branch. Lela [her X] Haile

ANSWER of D. B. Haile states she may have lived happily with him, but he didn't live happily... her violent temper, jealous and commanding nature... he was always kind, never cruel, did not abandon her, she abandoned.

He was taken violent sick 7 June 1880 with a dangerous fever for more than a month and during this time lived on his father's land... Physicians suggested he move there where it was more comfortable and he could receive better care. Respondent was asked to go and stayed for a while. The meat and lard were taken with them for their own use.

REQUEST TO DISMISS 5 November 1880 by Lela Haile. /s/ Lela Haile

[NEW] HAILE, N. P. vs HAILE, JOSHUA, et al Chancery 1874

WILL PROVEN: This the 3rd November 1884, George G. Haile a son of N. P. Haile, deceased, appeared and proved the death of N. P. Haile and read a paper purporting to be his Last Will & Testament...


I, Nicholas P. Hail of the County of Jackson, State of Tennessee, Being of sound mind and disposing memory to make this as my last Will and testament hereby revoking all other wills that may appear over my signature.

1st I hereby commend my spirit to the hands of Good [sic] who gave it and will that my body be decently buried, but in a plain and _ _ _t way.

2nd It is my will and desire that what debts I may be owing at my death that my Executor shall sell enough personal property to pay all of my just debts and cost of executing this will, and no more and he is hereby required to sell said property for Cash and such property as can be most conveniently spared by my family.

3rd I have heretofore given to my son Thomas one horse bridle and saddle and beding in all worth one hundred and fifty dollars. I have heretofore given to my daughter Martha J. Reed, a horse bridle saddle and beding [sic - all places] all worth one hundred and fifty dollars, I have heretofore given to James Nathan one horse bridle, saddle and beding worth in all one hundred and fifty dollars. This is all that I intend them to have out of my estate at this time. I have heretofore given my son William Hail one horse saddle bridle and beding worth in all one hundred and fifty dollars; this is all I intend for him to have out of my estate at this time; I have heretofore given my son Joshua F. Hail one horse saddle and bridle worth one hundred dollars and it is my will and desire for him to have here beding or the worth in money to wit $50.00 dollars and after he gets this, he has all I intend for him to have out of my estate at this time.

I have heretofore given my son John Hail a horse bridle and saddle worth in all one hundred dollars and it is my will that he have out of my estate his beding or the worth of the same in money to wit $40.00 dollars and when he gets this, I have given him all I intend for him to have out of my estate at this time.

I have heretofore given my son George Hail one horse worth seventy five dollars and I will that he have a saddle and bridle worth Seventy dollars and a bed and bed clothing worth fifty dollars and twenty five dollars out of my estate to make him equal with the other Children heretofore named.

4 It is my will and desire that my other children (to-wit) Nancy L. Hail, July Ann B. Hail, Mary Eter Hail have out of my estate a horse saddle and bridle and beding and bed clothes worth in all one hundred and fifty dollars as soon as they may marry or become of age to make them equal with the other children named above and Nancy having had a saddle therefore she has recd her saddle or $24.00 dollars of the one hundred and fifty dollars

5th I will and desire that my beloved wife Nancy L. Hail live on my farm where I now live as long as she may live or marries again and have the rents and profits of said farm as long as she may live or remains single and in case of her death or in case she marries then it is my will and desire that said farm after after [sic] her death be sold on a credit of one and two years and in case my wife should marries [sic] again then in that case said land be sold as above set forth subject to the widow's dower, and the proceeds of said land be equally divided between all of my children.

6th I will and desire that all of my stock of any kind and all of my personal property that may be on said farm be willed to my wife in order for her to be better enabled to raise my miner [sic, all places] children that may be living with her at my death and at her death said personal property of any kind shall be sold and after the debts are paid be equally distributed between all of my children and I will and desire that said miner children shall live on said land and enjoy the rents of said farm as long as they may remain single and as soon as one marries the rents is to accrue to other single ones and so on until all of the children ar [sic] married that are girls and in case my wife dies before said miner girl children becomes of age or marries then it is my will that the sale of said land be postponed until they marry or become of age and it is my will that in case any of my miner girl children remain single at the death of my wife that so much of my stock and other personal property that my Executor may think necessary for such miners be left until they marries or becomes of age.

7th It is my will and desire that my farm be rented out annually at two barrels of corn per acre for the hillside land and two barrels and one half per acre for all bottom land and the rents paid to my wife the corn delivered in the crib to her to support her and the miner children but for her and the miner children to occupy the dwelling house and out houses all the time.

8th It is my desire that in case any of my boys desire to rent said farm that they have the priviledge [sic] to do so and I desire that my Executor see that the timber on said farm be not wasted or destroyed and lastly I will in case my wife dies before the children are raised or married then my Executor pay the rents to them until they become of age or marries and not sell said land until they are all of age or marries.

9th I hereby appoint my son Thomas Hail my Executor to execute this my last will and testament.

Given under my hand and seal this the 28th day of June 1873}

Attested } N. P. [his X mark] Hail {Seal}

/s/ L. C. Hall, D. K. Fink

DEPOSITION May 25, 1881:

D. B. Haile [No age]. Had a conversation with Joshua Hale after my father's death he said he owed my father about $10 on a $55 debt on a mare father bought at Thos Hale's sale and afterwards let Joshua have her. Amon Haile was my father. I lived between one-half and three fourths mile of [my father]. /s/ D. B. Haile

SETTLEMENT [several pages, not abstracted - mlj].

ANSWER of George Bancroft Murray, guardian ad litem for Charley Haile, Margaret Haile, Jennie Haile and Nathaniel Haile, minor heirs at law of Amon Haile, deceased, to Bill of Complaint of Nicholas P. Haile and wife Nancy and John K. Fox... Lockey Haile is the widow of Amon Haile. Asks court to protect rights of his wards. 29 Oct 1874.

DEPOSITIONS 26 March 1875:

Tobias Gipson [No age]. Know the land of Amon Haile. I rented it in 1867 and 1868. Tobias [his X] mark

Randall Gipson age 73. Know land. Randal [his X] Gipson

John Brown age 59. Know land, greater portion is hill land... best to sell for division among heirs. /s/ John Brown

Roland Boles age 20. Don't think land could be divided among heirs. Roland [X] Boles

Joshua Haile Sr. age 60. About 150-160 acres owned by Amon Haile in his lifetime, easily fenced except a portion that lays next to Flynn's Creek, gets washed out. There is fourteen heirs of Amon Haile. /s/ Joshua Haile

Joshua F. Haile age 27. I was at the sale of Amon Haile's personal property, acted as clerk. Think Amon Haile died in the fall of 1867. Joshua Haile Jr. was appointed Administrator, think October 1867. Think the sale was in October 1867. /s/ J. F. Haile

Nicholas P. Haile about 59. Amon Haile died or was killed I suppose on 6 September 1867. Joshua Haile Jr. as administrator rented out the land in 1868, 1869, 1870, 1871, 1872, 1873 and 1874. N. P. [his X] Haile

PERSONAL PROPERTY SOLD, amount, items. Purchasers were C. W. Wheeler, B. D. [or L.; smear] Presley, Elizabeth Haile, T. J. Craig, Julia Fox, Wm Chaffin, Geo Skimmihorn, N. P. Haile, Lockey Haile, D. B. Haile, Thomas Pippin, John Stout.

DEPOSITIONS about 20 December 1876:

R. A. Cox, am upwards of 40. In 1869 as Clerk & Master I revived a judgment for costs against Joshua Haile, Administrator of Amon Haile. /s/ R. A. Cox

J. F. Haile. My father N. P. Haile, the Receiver in this case rented out part of the Amon Haile land for the year 1876 or about that year. /s/ J. F. Haile

Joshua Haile. I read the depositions of George G. Haile and G. C. Darwin and adopt them. /s/ Joshua Haile

G. C. Darwin. Know Amon Haile land. I purchased said land in the year 1875 I think. /s/ G. C. Darwin

BOND: We Nicholas P. Hail and wife Nancy Hail, John K. Fox, John P. Murry of Jackson Co. are bond to Joshua P. Hail, Dudney B. Hail, William Darwin and wife Julia Darwin, Nathaniel Hail, Charley Hail, Margarette Hail, Joshua Hail, Jr. and others... $200 this 23 March 1873. /s/ John P. Murray

DEPOSITION 25 May 1875.

Thomas J. Gailbreath age 58. The widow of Amon Haile died a short time ago.

William C. Anderson. The widow of Amon Haile is dead.

BILL OF COMPLAINT of Nicholas P. Haile and wife Nancy Haile, John K. Fox, Citizens of Jackson Co. against

Joshua Hail Sr., Duly [sic] B. Hail, William Darwin and wife Julia Darwin, Nathaniel Hail, Charlie Hail, Margaret Hail, Jennie Hail, Robert A. Cox, Locky Hail of Jackson Co., TN,

Joshua Hail Jr. and George Hail of Clay Co., TN

Margaret Ragland, Geo W. Hail, Amon Hail, David F. Hail, B. A. Fox and wife Aletha Fox, William Fox and wife Letty Fox, [Blank] Sadler and wife Sarah A. Sadler, Lafayette Haile, Thomas Haile, George Hail Jr., [Blank] Hancock and wife Nancy Hancock, [Blank] Hancock and wife Mary Hancock, [Blank] Watson and wife Elizabeth Watson, George Darwin and wife Harriett Darwin of the State of Texas,

Margaret McClellan, Sarah McClellan, Marian McClellan, Martha McClellan of the State of Illinois.

Lockey Hail is his widow.

[This is a John P. Murray document, difficult to read. Gives relationships; children, grandchildren - mlj].

[NEW] HALFACRE, ANDREW vs ANDERSON, JAMES H. et al Chancery 1868

BILL OF COMPLAINT of Andrew Halfacre and wife Rhoda Halfacre, Gabriel Jones and wife Mariah Jones of Jackson County, Tennessee against

James Anderson, John Brown, James Anderson Jr. and Elijah Anderson of Jackson County, the last two minors and Julia, formerly Julia Anderson and her husband [Blank] of the State of Illinois.

Docia Anderson purchased about [blank] 18[blank] of John Brown land in Flynn's Creek about 100 acres more or less, bounded north and east by land of James K. Richmond, south by James Vinson, west by Peter Polk. She took and kept peaceable possession 17 or 18 years.

Docia departed life April 1867 intestate in Jackson Co. Her heirs are complainants Rhoda Halfacre wife of Andrew Halfacre, Mariah Jones wife of Gabriel Jones and defendants James Anderson and Julia Anderson married to a man whose name is unknown to Complainant are children of said Docia, and James Anderson Jr. and Elijah Anderson minors sons of Peyton Anderson deceased, grand children of said Docia who have no general guardian, all citizens of Jackson County except Julia who resides in Illinois.

James Anderson son of Docia is Administrator, has taken possession of the lands and claims the same saying he purchased same from John Brown.

James Anderson is hauling valuable timber to Flakes Steam Saw mill in Jackson Co.

Asks guardian be appointed for minors, title be divested out of John Brown and James Anderson Sr. and in Complainants and Defendants except said Brown. 23 July 1868. Andrew [his X] Halfacre, Gabriel [his X] Jones

DEPOSITIONS 24 April 1875:

Rhoda Halfacre [No age]. I am a daughter of Dosha Anderson deceased, dead over four years, left four children [sic; see note below at end of case].

I was present when she died... with her some in her last sickness. Land adjoined that of Elish [sic] Chambers and John Raney and my husband Andrew Halfacre.

James Anderson claimed the land in the lifetime of his mother and afterwards, pretended he bought it.

...my sister Mariah Jones

... my sister Margaret Anderson

Mother said Uriah Brown had done a writing of some sort and signed it, but not being no scoller [sic] didn't understand it.

Ques: Did your mother have a title bond from John Brown?

Ans: She said she had a right in my presents [sic] from Jack Brown. She lived on the land some twenty years and died in James Anderson's house on the land in dispute. She was at James Anderson's some six or seven months.

After mother died, Mariah and myself were at James H. Anderson's and he said if we did not transfer our interest in the land to him we would not have as much as her clothes. William Fuquay and Elisha Chambers, Gabriel Jones and his wife Mariah Jones were there. Rhoda [her X mark] Halfacre

CONTINUED to 4 May 1875:

Johnson Spurlock age 61. Know parties, all but Mr. Halfacre were born and raised mostly above where I lived. Known [Andrew] Halfacre the complainant 8 - 10 years. Knew Dosha Anderson 30 - 40 years. She died some 7 - 8 years ago. She lived on the head of the Dry Fork of Flynn's Creek.

CONTINUED to 5 May 1875:

Elisha Chambers age 53. Known James H. Anderson and his mother several years in the lifetime of Dosha. Dosha told James to buy the land from Brown... make him and Margaret Anderson a home, that she wanted to let Margaret live on the land... that she was not able to pay for it herself... he went and got Brown and they drew an agreement.

James Anderson took his mother home with him... she was confined to her bed about nine months... worth about $100 to take care of her. Margarett Anderson lived with Dosha and waited on her.

The latter part of the summer or fall before she died, she talked about the land at her house. Present were Dosha Anderson, Margaret Anderson and Margarett's two little boys.

Last Spring at my house I heard John ?Sprock [?Possibly Johnson Spurlock - mlj] say he saw [Rhoda] with another man besides her husband.

Question: John married her gal did he not.

Ans: I suppose so, it is said. ?Sprock said the man's name was William Lambert. People say ?Sprock is not much account. Elisha [his X] Chambers

William Lambert age 63. Acquainted 18-20 years with parties to suit and with Dosha Anderson. She said if the got well, she wanted Margarett Anderson to have a place to raise her children, and her daughter Mariah to have 25 acres up Peter hollow and the balance to be equally divided between her other children. I went twice to help move her. Understood she wanted to move to her daughter's, the wife of Andy Halfacre.

Have known Elisha Chambers 20 years upwards he is of mixed character... not entitled to full faith and credit in a court of law.

Seven or eight months before she [Dosha] died, James H. Anderson and U. T. Brown were trying to rogue her out of her land. Think she died in the spring 1867. Did not advise to bring the suit, but did advise to compromise. William [his X] Lambert

Hiram McCoy age 74. With Johnson Spurlock, I was called to arbitrate the personal property division of Dosha Anderson. It was 2 or 3 weeks after her death. James Anderson came up and said something about indebtedness and it would not be divided that day. /s/ Hiram McKoy

James Anderson age 33. Am administrator of my mother Dosha, deceased. Sold her personal property at a public sale, gave ten days' notice, posted four notices. Margaret and Dosha Anderson lived together ten or twelve years. Margaret was a daughter of Dosha. Her husband was dead. Mother came to my house in the fall of 1866. /s/ J. H. Anderson

Margarett Anderson age 44. Dosha Anderson gave me a mare before her death for staying with and waiting on her. I lived with Dosha three or four years before she went to live with James. Before that, I lived in the field just below her. Present when she promised the mare were Andrew Halfacre, Rhoda Halfacre, Gabriel Jones, William Lambert, Mariah Jones and Letha Brown. I have two children one 16 and the other will be 16 in July next. Margaret [her X] Anderson

Letha Brown age 40. Dosha said she wanted James Anderson to have the land and pay for it. Letha [her X] Brown.

DEPOSITIONS 8 August 1871:

John Brown age 75. I made a verbal sale to Dosha Anderson some 18 - 20 years ago. She paid me a little gray mare rated about $30, was to pay $100 more on one and two years credit... mare was all I got from her in person. I went to her... told her she was getting old and she was soon to die and it needed to be settled. She said James could pay. He executed notes. /s/ John Brown

ANSWER of James H. Anderson to Bill of Complaint. Dosha Anderson died intestate in Jackson County, Tennessee April 1867 leaving complainants Rhoda Halfacre, Mariah Jones and defendants Julia Brewington, James Anderson and Elijah Anderson and Respondent her only heirs. Defendants James Anderson and Elijah Anderson are her grand sons, sons of her deceased son Peyton Anderson, are minors.

[Note: Rhoda Halfacre stated her mother Dosha left four children. The Bill of Complaint of Andrew Halfacre and Gabriel Jones lists 1. Rhoda, 2. Mariah, 3. James and 4. Julia. Rhoda states 5. Margaret is her sister. James states Margaret was a daughter of Dosha and that Margaret's husband was dead. There's a Peyton Anderson living in Jackson Co. 1860 and 1870, female children, none named James or Elijah - mlj].

1860 Flynn's Lick, Jackson Co., 220/220

James ANDERSON 20 Farmer 00/$130 TN

Nancy age 21 TN

1860 June 20, page 28, Dist. 12, Flynn's Lick, Docia & Margaret 310/310:

Docia ANDERSON age 50 Farm $150/$300 [All in hh born Tennessee]

Andrew 10

Maria 20

Margaret ANDERSON 28 spins/weaver 00/50

Harriet 10

Nancy 7

Jefferson 6

James 4

John 1

314/314 Andrew HALFACRE 23 00/$150 TN [all in hh]

Rhoda age 20

Parilee 6

James 4

Angeline 2

1860 Aug 15, Illinois, White Co., Tp 5S R9 E, Carmi, 1229/1219:

Aclin BREWINGTON 38 Farm 00/$75 Ill

Julia 37 Ten

Evans 15 MO

George 13 Ten

Missouri (f) 11 Ten

Columbus 8 Ten

Herzade (f) 5 Ten

Kansas (f) 1 Ten



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