Jackson Co., TN Loose District/Chancery Court Papers Reel #109
Reeves, - Richmond, F.

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[Note: First part are documents, possibly introduced as Exhibits, from Mary E. Young's divorce action against Z. M. Young, the father-in-law of C. E. Reeves. There is more on another reel; do not recall which - mlj].

TESTIMONIES:

Z. M. Young. [Divorce cause of Z. M. Young's second wife Mary E.] I never fussed when the flour was out, never offered or attempted to strike her or to draw my fist on her. I never refused to make fires, never had any fuss with complainant about a fire, never rubbed my fist in her face.

Never asked her anything about her going to Oaklahoma [sic] - did not know she was going until a short time before she left. Told her I though it would be best to wait. I was in a press for money. Never told her to kiss my ass.

Never saw Dave Whitaker at my house after sausage, never knew he got any. Saw a negro woman get a sock of sausage some 3 - 4 pounds for 10 cents, just told Mollie that if she didn't get more for the sausage she would soon be out of money. The sock of sausage were worth 40 - 50 cents.

Never broke down her rose bushes - I did cut out the dead parts.

Never threatened to burst a chamber over her head. Until I saw it in her bill I never dreamed of it.

If she asked me to get her some slippers that hers was almost worn out, dont remember. If she wanted shoes I got them or she got them and I paid for them.

Never assaulted her in my life with a slop bucket. I was out slopping my hogs heard Beulah and her quarrelling, asked them to hush I made Beulah hush and go in the house.

Some 2 - 3 years ago there was a band of house breakers... plank in floor would squeak - heard it squeak twice, had a shotgun by the bed and asked Mollie to light the lamp. I never scolded... she quarreled a long time because I asked her to light the lamp...

The pistol transaction spoken of is denied... I went to dinner and after I returned thanks she read a note from S. S. Dudney - said was the first dun she ever got... she began to quarrel... I didnt finish my dinner, went in the living room, she followed fussing then I went to the porch and she came out and kept up the quarrel - I never had a pistol, never drew a pistol on her and her adopted daughter. Mrs. Minor was not in the room - no such thing... occurred.

Never kicked compt out of bed... Compt turned her head to the foot of the bed and kicked me several times... I put my head off the bed and pretended I was asleep, she kicked me hard... I put my feet against her and said two could play at that game.

Never neglected in sickness... she had the flux and chills and I waited on her as best I could... She would sometimes take my prescriptions and some times not. I am a practicing physician for thirty years. She would sometimes want medicine not needed... would fuss and Dr. H. P. Loftis and Dr. Minor prescribed for her. Dr. W. T. Briggs and Dr. Chesly Briggs also prescribed for her.

Dr. Fowler was at my house and performed operation on Mr. Jacquess. Complainant called Dr. Fowler in her room... conversed. I told Dr. Fowler I did not think anything the matter, that she was mad because I told her to make her underclothes instead of buy them.

When Compt started to Nashville to Briggs Infirmary she did not know whether she would have the operation... gave her $40, carried her to the river... she got on the boat said she might need more... gave her $20 and sent Tinsley Gilbert & Co. $35 and think $25 or $35 more that she had borrowed while at the Infirmary. She was to write if she had the operation. When I got the letter my daughter Dora was sick... thought pneumonia fever... no one to stay with her... knew operation was not dangerous... knew Compt would have attention... her sisters were in Nashville.

I met her at the river when she came back... storm coming... I put the trunk in the house, complainant and her daughter were in the carriage... I did not lock Compt on the porch, never tried to have sexual intercourse that night... never forced her... it was always up to her. Never tore the shades down, threw them in the yard.

My daughter's child was sickly... low as any I ever saw... had sent to St. Louis to get her some malted milk and complainant carried it to Mrs. B. A. Butlers. I told her she should not, she said she'd go get it... I told her she should not, she did and I threw it against the fireplace and broke it. When she returned with it, it was dark she said here take it and stick it in your ass.

Never told her washing dishes was the occupation that suited her - that she was not fit for anything else.

I did tell her the meal was musty and got some more. She put the musty meal in the slop bucket.

Never said Id drive the Allen girl off - did say she was no account and told Compt to turn her off.

When she came home from Celina after her mother's death I did not know she was in the house. I was in the family room washing... saw her, shook her hand, kissed her said was glad to have her back... never treated coolly just said Mollie I thought you were staying til Christmas... she refused to eat. Jones [Jonas] L. Young was there for dinner.

Never heard about George Smith sending or carrying a ____ ____ to my home.

Compt always got anything she wanted at Tinsleys store... I never told compt not to go to my store run by Tinsley.

Never encouraged the children to mistreat... always told the children she was there in the place of their mother and to obey...

Never fussed when sugar, coffee, flour, etc. was out... I knew it was useless to quarrel.

I was presented with accounts by merchants of Gainesboro, showed them to her... she said she never got the articles and not to pay... I told her Id have to... that I had the money and from now on would pay cash. Accounts were for articles I never saw on the place... I told the merchants not to make any more accounts for my family.

I paid about $80 in KY debts before we married and after I got back from KY several debts were sent here... paid about $25 more.

There was a contract she was not to bring her adopted daughter here but was to live in Clay County with her grand mother. About 10 months after we married she was brought here and stayed until she married.

Compt said to me I want to be your Cashier I kept all of Mr. Nevills and want to keep yours.

She visited more than any woman in Gainesboro I always gave her money to go except Oaklahoma [sic] when I was very short. I took her to Double Springs and put her on the train - she would not wait until summer when I would have plenty of money - said she had money of her own.

I paid Elizabeth Young $1 I owed her, had $2 more in my hand. My wife was quarrelling and I told her she could have the other if I could just have peace one week.

She said if I didn't do what she wanted shed make a Guist out of me, referring to an old man whose wife filed a bill and squandered his property.

My daughter Dora and nees [sic; niece] Lena Young went to a protracted meeting at Bro White's my wife said she'd never cooked a bite for me nor never would to save my life... she went to Mrs. Pickett and Dr. Minor's three days & knights [sic] and got her meals - said I could eat cold meals or do a thought [sic; without].

She would sell meat and other things at reduced prices to get the money.

She did little housework... except sweep her own room.

She assaulted me with a stove stick, threatened to shoot me, assaulted me with a toy anvil... about four pounds.

About Feby 1899 weather was cold... I left her sleeping, lit fires, fed some 50 - 60 head of stock... come in my nees [sic] Lena Young got me some hominy for breakfast from the kettle by the fire... My daughter Dora came in to eat... my wife said they had done got some...

When she fussed I would generally go out... sometimes just laughed.

Always treated Georgie her adopted daughter well, bought shoes, clothes, paid tuition.

About a week before filing she got very nice... wanted me to pay her brother George Barksdale out of trouble he was in... she said it would take $5000, said we should pay if it took all we had. I declined.

The operation she had in Nashville was for hemeroids [sic].

Compt had an old mare about 21 years old, had tried to sell to Arch Green in Celina for $75. I paid her about $140 at various times for the mare. None of her money made anything for my estate.

I was not aware Bulah Tinsley and Lena Young were there against my wife's wishes. They fussed some, but not much. Lena Young is my niece and I cannot refuse her a home.

About 23 years ago Chas F. Burton my first wife's father gave her $2000 and it has been used by me in accumulation of property I now have. About nine years ago Chas F. Burton gave my three children the sum of $1500 and it was turned over to me and I gave bond as guardian. This has been invested for the children. I have paid to Edna Reeves my daughter $500... paid my daughter Beulah Tinsley $500... the other $500 and interest still remains due.

I think the farm on the other side of Cumberland River and the two ferries are worth $8000... will sell for that if anyone wants them.

My other daughter is a minor under age 21. I and my minor child live at the old home place where I and my first wife lived.

I meant what I said in the letter I wrote Compt at Celina.

In addition to what I owe my daughters I owe the bank $300 besides what I owe my attorney in this case.

I waited on Miss Rettie Kelly and Mrs. Young found out and took up my fee.

My daughter Mrs. Bula Tinsleys daughter was very sick. I told Dora to take her a bucket of hominy... their cook had left... when she went to get it Mary E. Young began to quarrel.

Cross-Examination

I told Dr. Fowler at Celina I did not know anything about Compt stealing a trunk but thought it could be proven. Talked to witnesses A. P. Green, H. H. Kyle, Steve Hamilton and perhaps others. I took the deposition of F. H. Overstreet - Mary E. Young forged an order... got contents of a trunk that were presents from Mrs. Kirkpatrick to F. H. Overstreet's mother. I took depositions of T. P. Myers, Mrs. R. B. Myers and Mrs. R. K. Herod... attempted to show Mrs. Mary Kirkpatrick of Nashville sent a dress pattern of superior quality to Mrs. Gip Herod... compt substituted damaged gingham.

S. S. Dudney. Nothing new.

Thomas Walker. I was at the river at Shrigley's baptising... saw Mrs. Young get out of the buggy... said she was afraid of the horse said she wanted to go in a hack... he told her there was no danger he and the girls rode in the buggy.

Oliver Carlisle. Was at work at Dr. Youngs when Mrs. Young came home from a trip... he shook hands with her and kissed her... glad to see her.

I live on the farm of J. H. Stafford on Doe Creek.

AMENDED BILL OF COMPLAINT of C. E. Reeves and wife Edna E. Reeves, Bailey C. Butler and wife Dora Butler all of Jackson County, Tenn and L. P. Tinsley and wife Bulah Tinsley of the State of Arkansas against

H. L. McDearman of Jackson Co., TN and Z. M. Young of Macon County.

Complainants filed Bill of Complaint [blank] 1906, answer was filed Oct 17, 1906 by deft McDearman. Judgment for confessed taken against Z. M. Young [Did not make defense - mlj] .

Complainants alleged Mollie Burton daughter of C. F. Burton intermarried with Z. M. Young 187[blank], issue of said marriage Edna Reeves intermarried June 20 1892 with C. E. Reeves; Bula Tinsley intermarried with L. P. Tinsley [blank] 1893; and Dora Butler intermarried [blank] 1902 with B. C. Butler.

C. F. Burton gave his daughter Mollie $2000 as her separate estate to invest for children. Mrs. Mollie Young died 20 June 1884 intestate leaving Edna, Bula and Dora only children and heirs... money to be invested for children in part of the land known as the J. W. Lock farm then owned by W. K. Lock bounded south by Cumberland River north by land of J. T. Draper formerly owned by A. G. Maxwell, north and east by M. A. C. Williams.

Defendant Z. M. Young purchased the farm after the death of Mollie... consideration $2000 and went into possession until [blank] 1900 when he was ousted. Mary E. Young went into possession... divorce... occupied until her death 190[blank] and since her death one S. H. Minor and his wife as heirs at law of Mary E. Young occupied until recently when they sold to defendant H. L. McDearman executing only a quit claim deed. Mr. Dearman purchased the land in controversy well aware of facts...

Gift by D. F. Burton to his daughter Mollie Young was made just before the birth of Edna while Mollie was en ciente.

ANSWER of H. L. McDearman... denies any such gift was made to Mollie Young and her bodily heirs... full strictly legal proof is demanded... he and those under whom he claims have been more than seven years in possession.

The farm was decreed to Mary E. Young by Tennessee Supreme Court. At the death of Mary E. Young, S. H. Minor and wife Georgia Minor or one of them immediately took possession by virtue of the will of Mary E. Young... Complainants... stood by and seen or known of it being decreed to Mary E. Young, or Nevill, as alimony... saw S. H. Minor & wife acquire possession.

Alleged gift by Burton made if at all as far back as 1875... Burton and daughter Mollie died before this suit was brought... defendant Young bought the land in 1890, took title in own name... filing of divorce of Mary E. Young was March 1899.

DEPOSITIONS 21 Feby 1907:

John J. Gore. Was solicitor for Z. M. Young vs J. W. Cason... ferry rights on Cumberland River. Z. M. Young gave deposition 31 August 1901... Deed registered Book I pages 586, 7 & 8... land decreed to Mrs. Mary E. Nevill by the Chancery of the Supreme Court... Mary E. Nevill was Z. M. Youngs second wife.

/s/ John J. Gore

John (Husler) Stafford age 33, live mouth of Doe Creek 1 1/2 miles from Gainesboro. Known Dr. Z. M. Young about all my life. I was born in this County and always lived this County. Worked for him, ferried for him at Doe Creek and Roaring River, worked on what is known as the Lock farm. He said he bought the land for his children... money that come through his hands by old man Burton. He said the ferries belonged to him and the farm belonged to his children... I was about 17 going on 18.

Ques: How long have you been married to your present wife.

Ans: I have been married 11 or 12 years maybe longer. I am not related to parties in suit.

1890, 91 and 92 was living there about the river. 1890 I was living with my dady [sic] staying elsewhere part of the time. My father lived in the upper house from the road at the mouth of Roaring River. Always lived around the river then with my father and my sisters.

Don't know if J. W. Cason rented and run the ferry in 1891.

John [his X] Stafford

R. S. Dennis age 40, live Gainesboro, have lived in Jackson County the principal part of my life. Dr. Young has practiced medicine in my fathers family and my family.

/s/ R. S. Dennis

Marsh Spurlock age 48 or 49, was born in 1859, live Gainesboro. Known Dr. Young since 1871 or 1872.

Ques: Didnt you make a statement to H. L. McDearman at his store a month ago...

Ans: I stated to W. W. Draper and Lee McDearman in a conversation at Minors that Dr. Young had worked hard for the money that paid for the farm. I told Draper and McDearman that Dr. Young said he had worked hard for his money and they were trying to break him... they didn't write down just what I said...

M. F. [his X] Spurlock [*]

[* HINDSIGHT by Mary Lu Johnson - Note: I declined to abstract part of a deposition as there was no genealogical data of help; THINK it was Marsh Spurlock, may not have been, but indicated good sense, and was fun. Tried to find it later on the reel without success. The person giving the deposition said someone had told him H. L. McDearman wanted to see him; he went to his store, told McDearman what he planned to say. McDearman told him he would harm him, not help, acted as though he was going to pull a knife on him, ordered him out of his store house.

Ques: What did you do?

Ans: I went.

Marion Stewart age 45, live 6th District, Jackson Co. Known Z. M. Young I expect 25 years. Knew first wife. I lived there from 1877, stayed four years. She said her Papa had given her money for land for the children, was a year or two after I went there. She had two children then, Edna and Bula.

/s/ Marion Stuart

M. F. Young age 56. Live 9th District Jackson Co., am a farmer. Z. M. Young is my brother, knew his first wife Mollie. They married in 1873 and I in 1874. After I married I lived in Carthage, Smith Co. four years, moved to Jackson Co. and lived at mouth of Roaring River and in Gainesboro to her death. In 1879-80-81 I visited them ever two or three days.

Knew old man Charly Burton, father in law of Dr. Young... understand he has been dead 12 - 15 years.

Edna Reeves, Dr. Young's oldest child was born 9 June 1875.

Shortly before her birth up to now Dr. Young purchased land:

East side of town back of where Beverly Minor now lives, $400-$450, 1880-84.

Think a store house in Gainesboro east side of town about 1885, paid $400 I think.

House and lot south side of square here in Gainesboro 1887-1890.

Bought the farm on the far side of the river $2000 and bought the ferry about 1881, think $700.

Lower ferry in 1880 something, think $1750 and before he bought the farm.

Bought a portion of Murray land near mouth of Doe Creek in 1899, said he paid $1500.

Bought Roaring River Mill about 1899 paid about $2000... some of the places he paid on credit.

He was on a trade with James Howard Brown about the land. Molly said she had thought about buying J. Z. Beck's land. There was trouble with Lock making a good title...

/s/ M. F. Young

ADJOURNED, resume April 29, 1907:

John J. Gore. Represented Mary E. Young in her divorce. I know J. Z. Beck, character good. McDearman had a letter from Beck saying he would be in Tennessee soon and we could take his deposition.

/s/ John J. Gore

DEPOSITION Monday, Aug 24, 1891 [Possibly entered as Exhibit from old case - mlj]:

Z. M. Young. The deed that M. A. C. Frost now Williams and myself made the trade for the ferry was March 26, 1881. She was on the porch of the house where she now lives... said if we was going to trade let her know for she was going to start to Missouri. There was litigation over the J. W. Lock estate. G. B. Murray drew the deed. G. B. Murray was a nephew of M. A. C. Williams.

Ques: Don't you know the fact they are not blood kin that G. B. Murray was a nephew of her first husband then long since dead.

Ans: I have always heard that G. B. Murrays mother and James Eaton was brother and sister and M. A. C. Williams was the wife of James Eaton. James Eaton was dead at that time.

H. W. Williams was called in [to witness deed], we all took it to G. W. & Lizzie Hamptons, all signed, we took it to T. H. Butler the County Court Clerk for acknowledgment.

Ques: Were you mistaken about Mrs. Williams talking about going to Missouri then... that it was never spoken of until after her marriage with Complainant T. J. Williams.

Ans: I am not mistaken and she did go a short time after.

The character of M. A. C. Williams, Lizzie Hampton, G. W. Hampton, J. W. Stafford, J. A. Williams and M. L. Gore is good. M. A. C. Williams not as much as others if she is interested.

I bought a house and lot from James W. Stafford that he had let Jonas have, had both sign deed.

/s/ Z. M. Young

ADJOURNED, Resumed September 4, 1891:

H. W. Williams. I was called to witness deed of M. A. C. Williams to Dr. Z. M. Young. She was talking about leaving that country and did leave a short time after. Known Dr. Young since 1863, character good. Believe M. A. C. Williams had good business qualities... she is not easily cheated.

Suit of J. D. Bennett against Lock heirs has been determined. M. A. C. Williams is one of Lock heirs. Known her about 25 years.

/s/ H. W. Williams

Lansdon Robbins age 49. Know Dr. Z. M. Young. M. A. C. Frost now Williams offered to sell ferry and ferry property at mouth of Roaring River for $800, I wouldn't pay it. Wished many times I had. She left the country soon after she sold it to Dr. Young, said she was going to Missouri.

/s/ L. Robbins

L. P. Mainear age 45. Know Dr. Young and land.

/s/ L. P. Mainor

DEPOSITIONS June 12, 13 & 14 1907:

A. B. Hestand age 37, live near Gainesboro, know parties. Known Z. M. Young 25 - 30 years, rented lower ferry and part of the farm eleven years ago, in 1896. He said he bought it with money old man Burton gave his wife. My wife was present.

Ques: How many times have you been indicted and what for.

Ans: I couldn't tell. I know of four - one for gambling, one for tippling [selling whiskey without a license], one for contempt of court, one for murder. I was tried by a jury in all cases, never took the stand in but one case and was cleared. Indicted for killing Will Roberts.

Ques: At the time he was killed you had a life insurance policy on him didn't you.

Ans: Yes Sir.

Ques: Defendant McDearman was a witness against you?

Ans: Yes sir and lots of others around here. Was indicted Federal court for selling whiskey - compromised it. Cheaper to pay it off than go to Nashville and fight it is what my lawyer said.

If I sold whiskey in this neighborhood it was in violation of the law. I sold it.

Ques: Did you say you hoped Reeves would gain this suit?

Ans: Don't recall.

Ques: Are you and Dr. Reeves and Clay Reeves very warm personal friends and didn't they assist you when you were indicted for murder.

Ans: Me and Clay Reeves are good friends me and Dr. Reeves are not... If they assisted me in any way in my suit I dont know it.

/s/ A. B. Hestand

B. L. Quarles age 36, merchant in Gainesboro since 1886. Know A. B. Hestand, give full credit.

Ques: What is the character of Marsh Spurlock, Andy Skimehorn, J. H. Stafford, H. A. Brown, M. F. Young, B. T. Minor, J. H. Montgomery.

Ans: Pretty good, would give full faith and credit under oath.

Ques... Character of J. A. Williams, R. V. Brooks, J. T. Anderson, A. J. Dudney, J. M. Morgan, A. G. Maxwell, R. B. Crowder and his wife [blank] Crowder, J. W. Pickett, H. L. McDearman, J. M. Johnson, W. M. Draper?

Ans: Don't know Crowders wife, others good. John Martins character not as good as some, would give credit on oath.

/s/ B. L. Quarles

N. B. Young age 64, have been a J. P. in Jackson County about 30 years. A. B. Hestand character is mixed - fair in dealings, would give credit on oath. [Was asked about same individuals above, said would give credit on oath - mlj].

/s/ N. B. Young

D. C. Maynor age 53. Know lands and parties. I was living at the upper ferry, Dr. Young came to my house about 1 April 1899 to collect some money. I told him I was scarce - wasn't hardly making any, that I didn't have boats fit to ferry with.

/s/ D. C. Maynor

Frank Dennis age 31, live Gainesboro, am a livery man [Character testimony, good - mlj].

/s/ Frank Dennis

J. A. Williams, live Gainesboro, occupation banking nearly 40 years. A. B. Hestand character good, acquitted of murder 5 - 6 years ago, heard nothing against him since.

Ques: Is it part of his character he has been indicted for selling whiskey, gaming and Bastardy?

Ans: Previous to murder indictment, selling whiskey - don't know about bastardy and gaming.

/s/ J. A. Williams

Luke B. Anderson age 32, live Gainesboro, druggist [Character testimony, good - mlj].

/s/ L. B. Anderson

DEPOSITION June 14, 1907:

H. L. McDearman [No age].

Ques: State what occurred between you and S. H. and B. S. Minor at the time the deed was written by W. M. Gailbreath.

Ans: B. S. Minor stepped out, then came back and said Dr. Young had offered $3000 cold cash for the farm... Dr. Minor remarked that he couldn't get it. I didn't know about a possible suit. They said they thought their title was good.

I live in Gainesboro across the street from Dr. Young until he moved to Lafayette, Tennessee.

Ques: Did anyone offer to buy it.

Ans: Yes Clay Reeves came to me and proposed to buy it and said he didn't believe they would law him. He came on his own - said he was trying to avoid the family getting into law. He is brother to C. E. Reeves the defendant.

I have heard Dr. Z. M. Young is taking sides. J. M. Dudney told me Dr. Young and Dr. Reeves came to see Polly Ann Dudney to see what her testimony would be.

Aunt Sally Bailey told her Dr. Young had been out to see her with B. A. Butler one of the Complainants solicitors.

Polly Ann Birdwell in her deposition said her uncle Zeb and Dr. Reeves had been to see her.

B. A. Butler, solicitor for complainant, admitted Dr. Young ought to be for his children while we were taking M. A. Birdwell's deposition.

My quit claim deed was executed March 9, 1906.

I went to see the land with B. S. Minor. He didn't have title paper with him. We discussed S. H. Minor's title.

Ques: Did you ever talk to Dr. C. E. Reeves or his wife Edna, L. P. Tinsley and wife Bulah and B. C. Butler and his wife Dora before you became satisfied to risk the title...

Ans: No Sir.

Ques: Did you talk to Dr. Young?

Ans: About five minutes. I told him I was negotiating... I asked if his children were going to bring suit... he remarked he had heard some such talk... but the only thing he knew it was gone from him and commenced abusing the court who had decided it... how wrongfully they had treated him.

Ques: Did you talk with A. B. Hestand about what he knew?

Ans: Had a talk with Boon, he said he already told Gore.

Ques: Were you not advised before you purchased the land by your mother in law Mrs. I. B. Pickett that you had better not buy the land and that it properly and honestly belonged to the children of Dr. Young.

Ans: No Sir.

/s/ H. L. McDearman

AFFIDAVIT: Mary E. Young makes oath she cannot go to trial without witnesses John M. White, Dr. Van Edwards, Malissa Edwards, Jack Thompson, Mrs. C. Thompson, Phillip Walthall and Capt. Caldwell of Horse Cave, Kentucky; of J. K. P. Davis, Wm Davis, G. W. Stephens, H. H. Kyle, M. M. Smith, A. P. Green, J. H. Parker, Mrs. John J. Brown, O. R. Maxey, L. Kirkpatrick and W. L. Brown of Clay County, Tennessee; Capt. Stephens of Monroe Co., KY, Mrs. Sallie Bailey of Macon Co., Tenn; J. Z. Beck, Mrs. Florence White of Sumner Co., Tenn; Mrs. Sallie Burton and Mr. Ed Burton of Putnam Co., Tenn; of Frank Beck, Benton McMillan and Mrs. John Armstead of Nashville, Tennessee; of John Burton, Frank Burton, ____ Burton of Trousdale Co., Tenn and others not summoned living in Jackson Co., Tennessee.

BILL OF COMPLAINT of C. E. Reeves and wife Edna E. Reeves, Bailey C. Butler & wife Dora Butler all of Jackson TN, L. P. Tinsley & wife Bula L. Tinsley of the State of Arkansas against H. L. McDearman of Jackson Co., TN and Z. M. Young of Macon Co., TN.

On 20 October 1873 Z. M. Young intermarried Mollie Burton daughter of C. F. Burton.

Some time after the marriage of Defendant Z. M. Young to his wife Mollie, her father C. F. Burton gave his daughter Mollie $2000 with the express declaration at the time of the gift that Mollie Young should hold same as her own as her separate estate and invest in suitable real estate for the benefit of herself and her children she may have. This money was received by Mollie in the presence of her husband who assented to said conditions.

Their mother Mollie Young died 20 June 1884 leaving children Edna born June 9, 1875, Beulah born March 9, 1877 and Dora born October 3, 1880. She also left her husband Z. M. Young.

Complainants Reeves intermarried 20 June 1892, complainants Tinsley 3 April 1893, complainants Butler [blank] 1900. Said three daughters have been since respective marriages under the disability of coverture [under authority of husbands - mlj].

A short while before her death their mother Mrs. Mollie Young turned over to Z. M. Young the $2000 with the express condition it be invested in a farm for the use and benefit of three minor children Edna, Bula & Dora... to be invested in the J. W. Lock farm then owned by W. K. Lock. It was the understanding at the time of payment that as soon as a good title could be procured and the purchase could be made at said price same would be used by Deft Young for the children... defendant Young [blank] 189[blank] purchased the land in his own name using said funds, described as follows:

Lying north of Cumberland River, District 1, Jackson County, Tennessee known as the lower shares of the Lock land bounded north by Cumberland River west by land of J. T. Draper formerly owned by A. G. Maxwell, north and east by M. A. C. Williams [blank] acres more or less.

Defendant after purchase immediately occupied said land and he and complainants herein had the possession until ousted... as Trustee for Edna, Bulah and Dora during his entire holding he recognized their right to same.

On [blank] Defendant Z. M. Young married a second time... lived together until March 1899 and she filed a bill for divorce and alimony in Chancery Court, Jackson Co, TN. [Blank] 1900 when a final decree was rendered all of said Z. M. Youngs right and title was vested out of him and vested in Mary E. Young. Said Mary E. Young went into immediate possession... held to her death 190[blank] and since her death S. H. Minor and wife Georgia Minor occupied and possessed same through tenants as heirs at law until recently when they sold to Defendant H. L. McDearman and executed a quit-claim deed only, refusing to execute a deed with covenants of warranty of title... consideration is $3500.

Complainants are informed and believe the question of bringing this suit was freely discussed by Minor and wife and others and McDearman.

Defendant Young never had his deed registered so they never had any notice either direct or constructive said land was in defendant Young until the divorce proceedings as they had never seen said deed.

McDearman was fully aware of the facts on which they base their claim before the trade was consummated... purchased the land at his peril and with the prospect of litigation... made the remark he knew... would take all the risk of any lawsuit... that he had played poker too long and too often and too successfully to fear a lawsuit or words to that effect. This was said before and while the deed was being drawn up for Minor and wife to McDearman...

Complainants ask conveyance to McDearman be set aside and they be restored to rights of ownership... Filed July 16, 1906.

SUMMATION of Bill for Divorce [Note: Bill for Divorce, depositions, Cross-bills are on other reel/reels. Documents on microfilm will be abstracted here if I don't recognize it as having already been done - mlj].

DEED: We for the consideration of $2000, $1800 paid down in cash the receipt is hereby acknowledged... $200 to be paid 1st June 1890... purchaser executed his note,

We, W. K. Lock and his wife Ollie Lock of the County of Montgomery State of Texas have sold unto Z. M. Young of the County of Jackson State of Tennessee following described tract, 1st Civil District... begin at a rock between Robt White and J. W. Lock lands... to Pollie Ann Williams corner and with her line back to the Cumberland River with the meanders of said river to the beginning including all the land that W. K. Lock & Sallie Sadler got as heirs from their father James W. Lock to have and to hold... Feby 12, 1890.

/s/ Wm K. Lock

ACKNOWLEDGMENT of Wm K. Lock, 12 Feby, 1890, Jackson Co., TN by J. H. Chaffin, Clerk

DEPOSITIONS - Mar 27-Apr 4, 1891 [Next depositions from old cause of M. A. C. & T. J. Williams vs Z. M. Young may have been included as Exhibits or may have been misfiled - mlj]:

Newton Moore about age 65, live Jackson Co., am a farmer. Know land in the bill of complaint M. A. C. & T. J. Williams (formerly M. A. C. Frost) against Z. M. Young, G. W. & Lizzie Hampton.

M. A. C. Williams is a sister of my wife. Lizzie Hampton is a niece of my wife and Wade Hampton is a nephew by marriage of my wife.

Ques: Was your wife and Complainant M. A. C. Williams both daughters of J. W. Lock.

Ans: They was.

I was present when lands were partitioned. Wm Gore was the surveyor. Commissioners were G. W. Puttie [Putty] and Jno W. Meadors. Chain carriers were Henry Riley and Thomas Meadors. Don't recall the other two.

/s/ Newton Moore

Wm Gore age 67, live Jackson Co. Made a survey. Since I first knew land, Robt White first owned, then Dr. Montgomery then Joshua Stone then A. W. Dewitt then Settle heirs.

/s/ Wm Gore

M. F . Young age 38. Know land. Z. M. Young purchased from M. A. C. Williams. I rented the land 1879, 1880, 1881 from M. A. C. Frost, now M. A. C. Williams. People were stacking logs [on portion next to river], she said I should charge them rent. I said I would not for it was my brother and A. C. Stafford.

/s/ M. F. Young

E. A. Brown age 46. Know log & lumber yard near mouth of Doe Creek, worth $100 year rent.

/s/ E. A. Brown

Geo. G. Haile age 37. /s/ Geo. G. Haile

James W. Stafford age 45. /s/ James W. Stafford

DEPOSITION Sat Feby 2, 1907 M. A. Birdwell at her residence, Willette, Macon Co., TN:

M. A. Birdwell, age 55. Married W. T. Birdwell Oct 29, 1896. Know Dr. Z. M. Young and J. Z. Beck, knew C. F. Burton and Mollie Young, first wife of Dr. Z. M. Young, am his niece. Z. M. Young married Mollie Burton daughter of C. F. Burton in 1874 or 1875... to best of recollection. I was living with my father P. N. Dudney about 2 1/2 miles east of Gainesboro.

After they married, I stayed there off and on 7 - 8 years, perhaps longer. About the time Beulah was a baby I boarded there and went to school. After that I boarded there and taught school. Shortly before Dr. Youngs first wife died they sent for me and I staid [sic] there until the day before the left for Nashville to be treated shortly before she died. She was dead when I boarded there and taught school. I stayed there several days at a time before and after birth of their children.

C. F. Burton and J. Z. Beck came to visit... afterward Dr. Young showed me money he had rolled up in his pocketbook apart from other money and said it was Mollie's - a gift from her Papa. Mollie Young Dr. Youngs first wife said her Papa had given Puss (Mrs. Beck) money to buy a house and Mr. Burton had also given her money to buy her a house... Dr. Young always said it was her money.

Mollie Young died 20th of June, not sure what year, brought her home on the 24th of June.

Ques: What relation are you to the Complainants [Edna, Beulah and Dora - mlj].

Ans: First cousins to Complainants.

/s/ Mary A. Birdwell

DEPOSITION 22 September 1906:

W. H. Young age 62, live 1st District, Gainesboro. I was born and raised here and have lived here most all of my life. Am brother of deft Z. M. Young. Knew Mollie his first wife. Think she died 16 - 17 years ago.

About the end of the divorce trial, Z. M. Young told Judge Fisher to take another property, that this [Lock farm] was purchased for the children with money their grand father had given to their mother.

Dr. Young claimed the land... offered to sell to Gillum Maxwell and Dr. Youngs second wife refused to sign the deed unless Dr. Young would agree to give Mrs. S. H. Minor and equal share of the proceeds with Edna, Beulah and Dora. Dr. Youngs second wife... told me about it.

/s/ W. H. Young

DEPOSITION 21 January 1907:

M. A. C. Williams age 66, live Gainesboro. Known Z. M. Young since Ive known anybody. W. K. Lock was my brother. He is now dead four or five years, died in Texas. The lower share of the J. W. Lock farm was owned by him and Sallie Sadler my brother and sister.

It has been 15 or 20 years since the trade was made with Dr. Young. My sister Sallie was 45 or 50 she is just two years younger.

Ques: Was Sallie Sadler living or dead at that time.

Ans: She was dead, left three children, think their names are John, Jim and Kate.

Ques: Did Dr. Young say... he wanted to put money in land for his children...

Ans: Yes he did and begged mighty hard for it and Henderson Young tried mighty hard to keep me from letting him have it. He bought it March 1881. My name was Frost at that time. I married three or four days after that.

/s/ Mary A. Williams

W. M. Gailbreath, live Gainesboro, am C & M of Chancery for little over four years. Known S. H. Minor all his life and his wife since she was a small girl. Known H. L. McDearman 15 - 20 years. S. H. Minor and H. L. McDearman asked me to write a quit claim deed and I did. Minor said they was threatening to bring suit. Minors wife was not there. B. S. Minor was there.

/s/ W. M. Gailbreath

ADJOURNED, resumed 23 January 1907.

B. S. Minor, age 40 in a few days, live Gainesboro, am a traveling salesman. I am brother of S. H. Minor. Known H. L. McDearman 20-25 years. I was married same day and same time complainant Reeves married [blank] June 1892.

J. A. Montgomery offered to buy the land, don't know the price. I advised my brother to sell because of the probability of a lawsuit.

E. J. Stafford was going to buy it and Dr. Reeves went to Stafford and said he was bringing a lawsuit. S. H. Minor said Reeves had scared Stafford off and asked me to see Reeves. I did... said I understand you have knocked the trade in the head... prevented Sid from selling the farm to Stafford.

Ques: Did you not learn that week that B. A. Butler [attorney for complainants - mlj] had come up from Nashville to file suit...

Ans: Do have a slight remembrance... Sid H. Minor told me something about that...

Ques: Is J. A. Montgomery kin to you...

Ans: He is an uncle by marriage.

J. E. Stafford is a partner with H. L. McDearman in the mercantile business in Gainesboro and have been for years... intimate fast friends...

Mrs. Neville formerly Mrs. Z. M. Young had willed that place over there to seven heirs who were to have $200 each and Dr. Minor and wife were to have the balance. Dr. Minor and his wife were to take the land and pay the $1400. I understand Dr. Minor had paid some of her debts, dont know how much... borrowed some money for that purpose. The heirs have all been paid and the debts as far as I know. Dr. Minor owed money to me and my mother.

/s/ B. S. Minor

A. C. Stafford, age going on 62. Known Z. M. Young since I was a little boy, some 57 - 58 years. Lived 1 1/4 - 1 1/2 miles in our boyhood days, since 4 1/2 miles until he moved to Lafayette, Tenn. He has doctored me and family.

Knew C. F. Butler and J. Z. Beck. Was at Becks helping make a rolling frame to roll logs up a hill, was about 21 - 22 years ago. Think at that time Dr. Youngs first wife was dead. There was a conversation with Jesse Beck. Two of the men who were there are dead. Merlin Trisdale, old man McCormack and Dave Hamlet was there they were all there at work and Frank Beck was there and maybe Willie Beck. Dr. Young wasn't talking to anyone particular just talking to the crowd there. Me and him and Jesse Beck were doing most of the talking. I told him if he ever wanted to sell the land I might try and buy it and Young said he wanted to keep the land for his children.

Ques: Have you ever talked the matter over with Dave Hamlet...

Ans: Dont think I named it to Uncle Dave but once or twice... down here at Washburns [store]. Been 4-5-6 years I stoped [sic; stopped - mlj] up at his house and we talked about Jessie and Zeb [Dr. Zebulon M. Young].

When we were working at Jesse Becks was 1886 or 87... Z. M. Young had not remarried. I had sold my one-sixth interest in my father's land to my mother except one-sixth interest in her dower. She couldn't pay me and said she would deed it back but I fooled around and let the statutes [of limitations on collecting] knock me out.

A. C. [his X mark] Stafford

E. A. Brown age 63, live 1st District, Jackson Co., am a farmer. Known Z. M. Young since I knowed anybody. He doctored my family since 1867.

E. A. [his X] Brown

M. J. Dixon, was 39 years old the 12th of this month, am a Lawyer.

Known Z. M. Young 20 years. My wife's father was a nephew of Dr. Young and we have been very intimate since I have known him. Said it was his negligence in not having deed made to his children.

Lawyers representing Dr. Young in his divorce were myself, G. B. Murray, D. B. Johnson, M. G. Butler, J. H. Stafford and L. K. Smith.

/s/ M. J. Dixon

John Martin age 56, live about five miles from Gainesboro. Known Z. M. Young since about anybody. He practiced in my family as a physician.

John [his X] Martin

J. E. Stafford, live Gainesboro, am a member of the firm McDearman Bros & Stafford. H. L. McDearman is one member. Me and N. L. McDearman have been connected in business since 25 April 1898.

Known S. H. Minor since he was a small boy. Three or four years ago I agreed with Minor to pay $4000 for the farm, considered it well worth the price, was to get a Warrantee deed. The day the papers were drawn up I went to see Dr. Reeves and asked if there would be a lawsuit and he said there shure [sic; sure] would and us being kinfolks and good friends he would rather we wouldnt buy it. It was rumored... he was going to bring a lawsuit. I had heard it several times on the grounds the land was bought with their mothers means.

/s/ J. E. Stafford

J. H. Stafford age 59, am a farmer, have a license to practice law. Dr. Young is my uncle. He came up to our office and I was sympathizing after the divorce and he said oh John dont take it too hard or something that way, that that money was bought with money given to my wife...

Think Dr. Young married first wife in 1873 or 1874, had four children one of them died which left three girls. Dr. Young was appointed guardian on 14 September 1891.

Dr. Young asked me if I had ever seen a $500 bill and he showed me two... I think that was the day Capt. Jim Davis arrested me here in town and Z. M. Young went my bond. Think this was 1878.

/s/ J. H. Stafford

Reubin E. Johnson age 70, live 3rd District Overton Co., TN. Lived in 10th District, Jackson Co. seven miles from Gainesboro before I moved to where I now reside. Known Z. M. Young since we were boys. Had a conversation with him on the day the decision against him was given in that divorce case... on the street going from the Court house to his house for dinner. Said I, "Dock she beat you," Says he "Yes it is gone from me now, but if my children have got any get up in them when the youngest one becomes of age they will get it - because their mother's money paid for it".

/s/ R. E. Johnson

Andrew Skimihorn age 53. Live on Haile branch 1st Dist., about 2 3/4 miles from Gainesboro, lived near Gainesboro 30 years.

Had a conversation with Dr. Reeves 7 or 8 years ago when our baby was born, Dr. Reeves was the physician. It will be eight years this coming April I think.

Ques: Have you a record giving the date of your baby's death.

Ans: No I have no record of it.

Ques: Have you taken any whisk [sic], brandy or other intoxicants today.

Ans: A couple. My friend Pink Mahaney give me a couple since I got off the stand for dinner... Not the least intoxicated.

Andy [his X] Skimahorn

DEPOSITION Jan 31 & Feb 1, 1907:

J. A. Montgomery age 54, live Gainesboro, am a farmer. I was negotiating with S. H. Minor about buying the land at first he was not anxious then he was. He wanted $4000.

Sid's mother Mrs. Minor and B. S. Minor said they wanted me to have the land. Think they had money in it some way. I told them there would be a lawsuit and they didn't think so. I told them B. A. Butler had come from Nashville to file.

Soon after he [Sid H. Minor] sold I heard he invested in a $6000 farm in Sumner County.

I talked to J. T. Anderson about the matter. I could not hear him good. I got my son Bob to do the talking. Bob said Anderson said there was going to be a lawsuit about it and he wouldn't have it for $3000.

Ques: What relation are you to J. T. Anderson.

Ans: Brother in law.

He is a lawyer and a good one, practicing a number of years, well regarded...

/s/ J. A. Montgomery

DEPOSITIONS 18 February 1907:

Amos J. Dudney, live Cookeville, Putnam Co. Known Dr. Young 40 - 45 years, lived in Jackson Co. before moving to Cookeville. Was tax assessor in Jackson Co. on 16 Feb 1898.

/s/ A. J. Dudney

A. G. Maxwell age 40, live Cookeville, lived Gainesboro several years and moved here in 1900. Known Dr. Young 15 - 20 years. He proposed to sell me land and his second wife wouldn't sign deed.

/s/ A. G. Maxwell

J. T. Anderson. Live in Sparta, Tennessee.

Ques: Did your family live in the vicinity of Gainesboro, if so how long.

Ans: I lived near Gainesboro 1876 to November 1897 and in Gainesboro from November 1897 up to Aug 1905 since which date I have lived in Sparta. Known Dr. Young since 1875.

I was one of Mary E. Youngs attorney in her divorce. Dr. Young said not one dollar of his first wifes money paid for the land. I believed Mary E. Young's title was good and so stated to H. L. McDearman.

Known J. Z. Beck 35 years, character while he lived at Gainesboro was good. Moved away from Gainesboro several years.

/s/ J. T. Anderson

DEPOSITIONS April 18 [No year but likely 1907]:

R. B. Crowder. Known Z. M. Young 30 years. Conversation with Dr. Young at my house after lawsuit with his wife about six years ago... said they beat him out of his farm... paid for out of his own money.

R. B. [his X] Crowder

P. Susan Crowder. I am the wife of R. B. Crowder. Heard conversation between Z. M. Young and my husband... said his wife beat him out of $9000.

P. S. [her X] Crowder

Nimrod Reed. Known Z. M. Young 35 - 40 years. Heard him tell the judge he paid for the land with his own money - the judge was deciding the case. My understanding was she had beat him out of $2000.

Nimrod [his X] Reed

J. A. Williams age 69, running bank in Gainesboro. Known Z. M. Young since 1865 or 6. Wanted to sell me the land and ferries for $10,000 about the time his wife filed for divorce.

/s/ J. A. Williams

J. W. Picket age 40, live Gainesboro, am a traveling salesman. Know parties. McDearman the defendant married my sister. Known Dr. Young 31 - 32 years. During the divorce pendency between Dr. Young and his wife I told Dr. Minor that P. Tinsley and Dr. C. E. Reeves were fixing to bring a lawsuit. He said would do them no good that it was his.

Ques: Do you remember when Dr. Young and his brother M. F. Young owned the Roaring River Mill jointly.

Ans: I dont know who owned... know Merlin Young used to live there.

H. L. McDearman was talking about Aunt Sallie Bailey living there at Dr. Youngs and Polly Ann Dudney and he asked me to see what she had to state...

/s/ J. W. Pickett

J. M. Johnson age 72. Been an attorney about 27 years. In 1870 or 71 when I moved to Gainesboro Z. M. Young was a young man - just beginning to practice medicine.

I was in court during the divorce. The judge asked Dr. Young if his first wife's money had paid for the land, Dr. Young said No sir. At that time I lived about seven miles from town in Whites Bend.

I am not related to Mary E. Young.

[Answered "Don't remember" to most other questions; nothing new - mlj].

/s/ J. M. Johnson

J. M. Morgan age 73, live near Gainesboro, Dist. 1, am a lawyer and farmer. Practice law but very little.

Ques: Did anyone approach you about bringing a suit at the Youngs divorce trial.

Ans: Dr. Reeves and his brother in law Tinsley approached me. As I remember they said Charley Burton the father of their wives mother had given her $2000 which was used to buy the J. W. Lock farm. Divorce filed March 2, 1899 and Chancery decree Sept 22, 1899 is what the record showed. The bill in this case was filed 16 July 1906.

My recollection is the conversation was at Tinsleys store down here where Birdwell now occupies on the northeast corner of the square. Tinsley was in business there, understood Z. M. Young was backing him.

Nearly all the lawyers in town and some from a distance were employed on one side or other of the divorce.

I had the opportunity to buy land from W. K. Lock for $2000.

/s/ R. V. Brooks

D. B. Johnson. Was one of Z. M. Youngs solicitors in divorce. My feelings are good toward Complainants except C. E. Reeves - not good towards him.

/s/ D. B. Johnson

DEPOSITION Feby 16, 1907.

J. W. Pickett [re-called]. Dr. Young said not a dollar of Burton money went to pay for land.

Ques: At the time you went to see Aunt Sallie Bailey as stated in your deposition, didn't you tell her your mother and sister were interested in McDearman's purchase... and in outcome of this trial.

Ans: I told her McDearman had bought it and that my mother and sister had an interest. I understand Mrs. Bailey has a very kind feeling for my mother and sister and myself.

Ques: Did you have a sister named "Sallie".

Ans: Yes I had a sister named Sallie. She died May 1880. She was in the neighborhood of 24 years old when she died.

/s/ J. W. Pickett

DEPOSITION at office of S. S. Kirk, Notary, 303 Main St., Dallas, TX, 27 Dec 1906:

J. Z. Beck age 76, live Dallas, Texas. Knew C. F. Burton he was my wife's father. He has been dead eight or ten years.

Ques: Please give us the names of your wife's brothers and sisters.

Ans: Jennie was my wife, Margarett married John M. Armistaid [Armstead], Fannie married Dr. Harrison Fitzpatrick, Ann married Dr. W. H. Ragland, Mary or Mollie married Dr. Z. M. Young. The boys were Dr. Ned Burton, W. S. Burton, Frank Burton and John Burton.

The girls are all dead. The three other boys are still living.

C. F. Burton was a man of considerable means. He divided out his property before his death and delivered to them in person the property he desired to give each of them. He bought the place where we lived for $3000 and then gave her [Jennie] some money. It was in the deed it was not to be taken for any debt I might have.

I was with C. F. Burton when he gave Mollie money at Dr. Young's. Believe either Polly Ann Dudney or Sallie Pickett came out of the cook room while I was there.

/s/ J. Z. Beck

OPINION OF THE CHANCELLOR... Sworn statements made by Dr. Young in divorce proceeding..."I paid $2000 for the farm across the river six to eight years ago. My first wife's father gave her $2000 about 23 years ago; he handed the money to my wife and she handed it to me. Afterwards I gave it back to her, and afterwards I used it in trades my necessities demanded. I don't know that a single dollar of that money went to pay the purchase price on the tract of land across the river belonged to me."

[Chancellor stated this sworn statement carry more weight than other testimony - mlj]. Cause dismissed with costs to complainant.

BILL OF COMPLAINT of Mary E. Young. She and defendant Z. M. Young married in Clay Co., TN April 2, 1888, immediately removed to Gainesboro. Shortly after marriage he... became ill tempered... insulting... rude... coarse.

At time of marriage she was the widow of Geo W. Neville deceased... gentlemen of refinement culture and good breeding. She had been educated by her parents who were of good breeding... unacquainted with coarse rude conduct.

Complainants father John Barksdale who lived in Clay Co.... considerable wealth and provided for Complainant and other members of family bountifully. She from infancy had always been accustomed to necessaries and comforts without stint or grudging.

After marriage with defendant he became parsimonious and stingy... called her mean, low-down, sorry, trifling... used language too obscene to be stated here.

February 1894 complainant received a note from S. S. Dudney that defendant had told him to charge nothing by any member of his family unless it was on his written order. After dinner complainant came to her room and began to stare in a most threatening manner... she asked what was the matter and he said don't say three words... Complainant said "Well, I say the three words" and if not for the other lady [her adopted daughter Georgia] in the room, believes he would have inflicted harm - he ordered the lady from the room, snatched a loaded revolver, made a remark about shooting which she did not understand... cocked the revolver and turned the chambers...

14 August 1895 raised a slop bucket as if to strike her...

July 1896 threatened to strike her with a chamber...

July 1897 kicked her out of bed...

March 1898 told her washing dishes was the occupation that just suited her...

Tuesday morning 28 February 1899 without just cause struck her in the face with his hand causing her face to inflame... prostrated her... her overwrought nervous condition... still hurts.

[Lists personal property - not abstracted, and following real estate - mlj]:

Land 1st District... part of J. W. Lock property worth $4000.

Ferry and ferry franchises across Cumberland River and adjacent land called Upper Gainesboro ferry purchased from M. A. C. Williams worth $1500.

Ferry at mouth of Doe Creek called Lower Gainesboro ferry formerly owned by W. H. Quarles worth $1500.

House and town lots in Gainesboro where Z. M. Young now lives adjacent the Tanyard Branch, W. H. Settle, J. A. Williams and I. B. Picket worth $800.

House and lot in Gainesboro occupied by Wiley Roberds [sic] bounded by land of John P. Murray, I. B. Pickett and R. M. Maxwell worth $75.

Store house and lot in Gainesboro now occupied by Holland & Carter on south side of public square adjoining lots of L. S. and J. T. Anderson worth $500.

Store house and lot on northeast corner of square in Gainesboro formerly owned by W. H. Quarles worth $1200 - $1500.

Lot in Gainesboro adjoining lots and land of H. H. Cason, B. L. Quarles and others, 4 acres, $500.

House on the Gailbreath lot in Gainesboro called the school-house worth $75.

Tract of land on Morrisons Creek worth $100.

Water mill and fixtures on Roaring River called the Merlin Young mill formerly owned and operated by R. W. Allen worth $1500 - $2000... Perhaps other property.

Complainant at the time of their marriage owned a tract of land in Kentucky which sold for $1000, all spent on support of Complainant and her adopted daughter except about $350 in notes and $30 cash. 2 March 1899.

/s/ Mary E. Young

ANSWER of Z. M. Young to Bill of Complaint by Mary E. Young. Agrees her first husband was a gentleman, denies harsh treatment, denies he refused to buy necessaries... when he asked her about charges she denied having purchased items, so to avoid problems with merchants he told them not to allow charges without his permission.

The tract of land north of Cumberland River is worth $3800 not $5000.

House and lot in Gainesboro occupied by L. P. Tinsley is worth $500 and stock $400.

Respondent's interest in Roaring River mill worth $1200.

Respondent's first wife was a daughter of Charles F. Burton, gave her $2000... intended for her and children Edna Reeves, Beulah Tinsley and Dora Young; he left aforesaid three grand children $500 each in his will.

/s/ Z. M. Young

DOCUMENT [Appears to be part of Mary Young's Bill of Complaint or a Supplemental bill; first and last parts missing -mlj]

I had two sisters in Oklahoma I had not seen for several years. I had been in bad health and desired to see them...

I never asked him to help my brother...

Dave Whittaker came to buy 10 Cents worth of sausage...

I had some nice rose spouts on which I bestowed care and one morning he broke some of them off.

One morning I told him to get me a new pair of slippers he said now you are beginning to quarrel...

One time Beulah Tinsley was there pulling some grapes that were green... I told her not to until they were ripe he said pull as many as you want. He went to slop his hogs and I remarked to Beulah "You will take possession here won't you" she replied "Yes I will" and I told her well it's my house... she went to talk with her father and he came back and raised the slop bucket as if to strike and looked over toward Joe Gore's place and lowered it. Mrs. Gore is dead.

Came in my room in a threatening manner and stared and said don't say three words...

The operation [Briggs Infirmary in Nashville] was performed by Dr. W. T. Briggs and his two sons Charles and Sam... these three doctors and Miss Crafton were the only ones present... under ether two hours... neither Dr. Young nor any member of his family were there... my daughter was at the Infirmary... I went to my aunt's in Nashville and Dr. Briggs visited twice... I returned home after a week by boat.

My visit to Oklahoma was to see my sisters one an invalid.

When I went to Celina it was to see my invalid mother who had been sick three years.

My daughter Georgia was 13 when we married.

/s/ Mary E. Young

John V. Minor. Am in the drug business in Gainesboro. In 1894 Z. M. Young came to my store and said not to sell anything to his wife on credit. Said she was buying things and giving it to her kin.

/s/ J. V. Minor

CROSS-EXAMINATION of Mrs. Mary E. Young:

I did not use vulgar language, did threaten to strike him with a stick of stove wood, he called me a liar.

Before we married I told defendant my daughter could stay at my mother's until ten months school was out. After we married defendant invited me to bring her to his house. He always treated her kindly.

Did not say unless he did so and so he would go as Blue Gist went.

Did not say Henderson Young and defendant's three children were worse than devils.

My mother and her sister Mrs. Overstreet and an old aunt of ours lived near each other in Clay County, Tenn; my aunt Mrs. Kirkpatrick and my mother's sister living at Nashville sent a trunk on a steamboat to Celina addressed to my mother care of H. H. Kyle wharf-master at Celina... dress pattern addressed to Mrs. Overstreet and one to Mrs. Neely and another to my mother. My aunt Mrs. Kirkpatrick has a niece living near Gainesboro, Mrs. Gip Herod. Mrs. Kirkpatrick... her daughter Manie... my daughter Georgia

DEPOSITION:

J. E. Stafford age 39, live Gainesboro, merchant. Born & raised 1st District, lived here all my life. Knew Col. John P. Murray in his life and his wife Sallie. Know land and town property owned by Murray in litigation. Don't think it susceptible to partition. Think feelings between complainant and defendants are not very good.

Ques: Considering that defendants Johnson own the life estate of Sallie Murray in the land and are in possession of same... could they destroy...

Ans: Not destroy, but considerably damage.

I understand Sallie Murray is 35 years old, understand her health is good. I haven't seen her in six or seven years.

Land is worth about $2500, town property about $2000. Been on land today. Fencing in poor condition, hill land above where John Martin lives is badly washed and worn, houses in very poor condition. Fences are a little better condition than June 1899 when Clay Reeves and D. B. Johnson bought reversionary interest... house worse condition.

Complainant Clay Reeves asked me to look at it. J. J. Gore, Frank Anderson and L. B. Anderson was along.

Ques: What do you know about J. M. and Bedford's feelings toward Complainant being hostile.

Ans: I have been informed they passed without speaking.

Suppose there are 16 - 20 town lots if the streets were opened up. Two dwellings, one tenement house, two smoke houses, one barn or livery stable, one small box stable, about four closets [sic; ?storage sheds].

Ques: When you lived in the main residence in 1896 wasn't it dilapidated.

Ans: Yes - rotten sills, floors bad shape, part of the house had squatted for want of sills and in the part I occupied the floors were bad and needed painting.

/s/ J. E. Stafford

ADJOURNED, RESUMED December 29, 1906:

M. F. Anderson age 33, live at the river 1 1/4 miles from Gainesboro. Occupation ferry man and ware house keeper. Worked on the land when I was a boy 14 or 15 years old.

/s/ M. F. Anderson

W. H. Young age 62, live 1st District, known land 45 - 50 years, since I was large enough to come in town. Lived within 4 - 5 miles all my life except what time I was in the war and two years gone to Missouri.

Ques: What would be a reasonable price for the land considering the purchaser would not get possession until after the death of Sallie Murray widow of John P. Murray - a young woman some 30 - 35 years of age and supposing reasonably good health.

Ans: I would say for the McCue place $1600 - $1800 and to get possession at her death, not over $1000. Town property $2500 now, at possession at her death not over $1500. The longer she lives the less the reversionary right is worth.

Ques: Did not William McCue live on the east of the old Gainesboro and Cookeville Road and had a tan yard there before the war and then bought west of said road from R. C. Kirkpatrick.

Ans: Dont know who he bought from.

I am the attorney in the case of Kenner Dudney and wife against the defendants.

I am uncle of J. H. and J. W. Stafford but if they are in a suit [with complainant] I didn't know it.

Ques: Who did you think was defendant when you gave your original testimony.

Ans: Daniel B. Johnson

Ques: You are mad at D. B. Johnson?

Ans: I don't have no use for him on God's earth.

Ques: You are mad at your son John L. Young are you not?

Ans: No sir and the man who says I am is a liar and a son of a bitch... Me and him get cross a little.

Ques: You went... without speaking to your brother Z. M.?

Ans: We had a lawsuit but we are friendly... have been for some time. Me and Clay Reeves are good friends - never had a fuss as I remember.

Dont think house and land are in as good condition as in lifetime of John P. Murray.

/s/ W. H. Young

DEPOSITIONS June 4 & 7, 1907:

D. B. Johnson. Have controlled [land] something like ten years and owned an interest something like that time. Land is suitable to being partitioned in two equal shares or the town and farm are pretty much equal value. Joshua Haile and D. B. Johnson purchased Sallie Murray's life estate October 22, 1896 - I mean the dower. I became sole owner 18 October 1902. I bought it from R. V. Brooks. Reeves and myself owned the reversion.

I tore down the mansion, used doors and window frames for the cook house to the cottage. Used some ceiling in the cottage, used siding in building some of the closets, used some studding and rafters in framing the cottage. A good deal was rotten.

Ques: Wasn't it comparatively new - built since the Civil War, only 20 - 25 years old when you tore it down?

Ans: Don't know when it was built.

/s/ D. B. Johnson

J. W. Pickett. Know the homestead and dower of Sallie Murray known as the McCue place upwards of 30 years. Understand there are bad feelings between Clay Reeves and D. B. Johnson.

/s/ J. W. Pickett

J. B. Elkins age 45, live near Gainesboro, known land 30 years, lived on the McCue farm four years, the Washburn place ten and cultivated it fourteen - had to pass through the McCue place during this time. It could be partitioned - about 130 or 140 acres on both sides of the creek.

/s/ J. B. Elkins

W. H. Sadler age 49, know land. Think it could be divided equally.

/s/ W. H. Sadler

G. G. Haile age 52, live Gainesboro. I am a brother of Joshua Haile deceased. At his death D. B. Johnson and Joshua Haile owned the life estate of Sallie Murray widow of John P. Murray in homestead and dower. I was there in 1898 as my brother lived there and was sick... houses out of repair at that time.

/s/ Geo. G. Haile

DEPOSITION June 11, 1907:

S. M. Tinsley. Known land 25 years, lived in the house one year and have used the barn for two.

Ques: Is it not a fact that D. B. Johnson attempted to bring about litigation between Complainant Reeves and Maggie Jones widow of Geo W. Jones for the purpose of extorting money from said Reeves before Johnson committed the offence for which Reeves assisted in the prosecution and is not this the reason for the bad feeling...

Ans: Don't know of fact, heard of litigation. Don't know that Daniel was instigation... believe this was before Johnson committed the offence that Reeves assisted in prosecution. I don't know the purpose of litigation.

Ques: Is it not a fact after D. B. Johnson filed against Reeves et al to ____ the purchase price of the N. P. Haile land... Johnson became purchaser of two or more tracts and Reeves began preparation of his defense... Johnson sent him word if he didn't let him alone and if he did make defense he would bring suit for the widow Jones as aforesaid against him and institute other suits against him.

Ans: No sir don't know it to be a fact. My recollection is the bill was filed before the shooting - possibly before.

My understanding there was bad feelings between Clay Reeves and D. B. Johnson for some time.

/s/ S. M. Tinsley

D. B. Johnson. Gave my deposition prior to last term of this Court. While Clay Reeves and I owned Reversionary interest jointly and I owned the life estate... [Calculated cost of improvements he had made to land and town property at about $700 - mlj].

/s/ D. B. Johnson

Johnie [sic] Martin. Lived on McCue place the last ten years, lived on the adjoining farm several years before moving to McCue place.

/s/ John Martin

J. A. Montgomery. I raise and sell livestock and sheep [Value of ewes at $2.50 - $3.50 ea. - mlj].

/s/ J. A. Montgomery

DEPOSITIONS, Value of land, no ages given: S. M. Tinsley, L. Washburn, W. C. Reed [all signed], Nathan Hunter [X mark]

Clay Reeves. Know land and town property. Own one-half interest in reversionary interest after the death of Sallie Murray.

Ques: Is it your opinion to the best interest of yourself and J. M. and Bedford Johnson to sell the reversion in said lands and town property and divide proceeds, if so why...

Ans: I think it would be better for all concerned to sell and divide because D. B. Johnson and myself are not friends... he seems to boss manage control... I cant afford to talk to him concerning it... neither do I regard J. M. and B. D. Johnson as my friends and do not think either of them would consider my interest...

Ques: It is stated that D. B. Johnson and J. M. and Bedford Johnson have placed a lot of improvements on the farm which enhances its present value... to wit...

Ans: In 30 years from now I do not think the improvements will be worth anything.

Ques: How many fire policies have you collected on.

Ans: Two.

Ques: How many life policies have you collected on.

Ans: Collected on a man named Jones, J. W. Carter collected on a man named Rector and paid me about $800 he owed me. I had loaned him money to pay premiums. Carter had promised to pay me when Rector died as he was very low with consumption.

Ques: Your father lived on the Dr. Fowler place and you have been live [sic] on said place lots and are familiar with its location.

Ans: My father lived on the Fowler farm but I was there but very little.

/s/ Clay Reeves

James Godsey age 45, live 1st District, am a rock mason fifteen years or more. Recently built and repaired 480 - 490 yards of rock fence for J. M. and Bedford Johnson. It cost 10 Cents per yard except one piece $2.00 - one piece I was getting 12 Cents per yard. D. B. Johnson said he didn't understand it that way so we compromised...

James [his X] Godsey

John S. Quarles. Have been acquainted with McCue farm 60 years. There's a few hundred yards between my farm and McCue farm - less than 1/4 mile. The road I travel coming to Gainesboro passes over the McCue place.

/s/ John S. Quarles

W. T. Poston. Until 6 or 7 years ago I owned the farm adjacent the McCue farm called the Poston place - was raised there. I don't live over 1/2 mile now. I sold to W. E. Smith.

/s/ W. T. Poston

Peter G. Cox. Lived adjacent McCue farm four years, moved 5 years ago the 1st of this October.

/s/ P. G. Cox

DEPOSITIONS [Value]: G. G. Haile, M. G. Butler [both signed as written - mlj].

DEPOSITION:

H. L. McDearman. Am a merchant, own a good farm. I have been knowing the Murray property since I have lived in Gainesboro and I have lived here 14 years.

/s/ H. L. McDearman

BILL OF COMPLAINT of Clay Reeves of Jackson Co. against J. M. Johnson and Bedford Johnson.

John P. Murray died intestate in Jackson Co., land and property was assigned to his widow Sallie Murray as homestead and dower. D. B. Johnson became the owner of the life estate and recently sold same to defendants who are now the owners.

Some time after the death of John P. Murray, land and town property were sold subject to the life estate of Sallie Murray and D. B. Johnson became the owner of an undivided one-half interest in the reversionary interest in the land and town property which he sold to defendants.

Complainant became owner of the remaining of the same. Therefore complainants and defendants are joint owners of the reversion subject to the life estate of said Sallie Murray.

Said land and town property described as follows:

Tract of land bounded north by lands of L. G. and Gid H. Lowe and C. E. Reeves; east by lands of S. B. Fowler; south by J. S. Quarles and W. E. Smith and west by S. M. Tinsley, C. E. Reeves, perhaps others known as McCue place [blank] acres.

Town Lots in Gainesboro known as the John P. Murray home place including house and lots where the Murray stable stands and house and lot where G. W. Hampton and W. E. Ragland now live bounded north by street running between this property and the lots of B. L. Quarles and Mrs. J. V. Minor; east by property of B. L. Quarles; south by property of J. W. or Nettie Draper; west by street running north and south by the Methodist Church and J. W. Draper's residence.

Asks land and town property be sold and funds distributed.

ANSWER to Bill of Complaint filed 10 March 1906 by Clay Reeves. Bounds setting out tract not correct - not bounded east by S. B. Fowler but east by L. Washburn and W. E. Smith and the said place is not bounded south by J. S. Quarles but is bounded south by W. E. Smith or rather his wife's lands and S. J. Keith or S. M. Tinsley - respondent does not know which owns the title. Originally contained two tracts and divided by the old Gainesboro and Cookeville Road.

Complainant owns a very small portion of interest, it only being one-half of a reversionary interest of a young woman's life estate and that respondent J. M. Johnson is the father of Bedford Johnson, and J. M. Johnson is 71 years old and he does not desire his son's interest in said lands be separated, that his son is a young man able to look after it and they desire their reversionary interest be layed off together.

MOTION FOR NEW TRIAL: June 20, 1911, D. B. Johnson one of the parties and also Solicitor was sick for eleven days, had a fever, was taking calomel... Dr. H. P. Loftis treated.

Recently B. D. Johnson died and the case has not been revised against his lawful representative.

/s/ D. B. Johnson

DEPOSITIONS:

M. L. Gore for complainant Reeves. Know land and town property.

Ques: Was you acquainted with Col. John P. Murray who owned this land and property prior to his death Decr 1895.

Ans: Yes Sir.

I am the father of John J. Gore but don't know if he is a solicitor in this case or not.

Ques: Col. John P. Murray was an invalid many years before his death, not able to see to property...

Ans: He was an invalid. You might call him an invalid but he would go over his lands where he could with a buggy.

Ques: Is J. M. Johnson an old man and several of his heirs are married women?

Ans: He is an old man and his daughters are all married. All his children are married except D. B. Johnson.

/s/ M. L. Gore

A. B. Hestand. Knew John P. Murray in his lifetime. I lived there before his death. Think he's been gone 13 - 14 years.

/s/ A. B. Hestand

John H. Stafford. Known the McCue place on Doe Creek just south of Gainesboro 40 years, lived about three-fourths miles [from it] for the last 23 years.

/s/ John H. Stafford

ANSWER and Cross-Bill of James Lynn to Bill of Complaint of Clay Reeves, Administrator debonis non of John M. Gipson, deceased.

John M. Gipson died as charged and Eliza F. Gipson was the first Executrix.

Said Eliza died and L. M. Gipson was appointed Administrator &c.

L. M. Gipson afterwards died, and supposes true Clay Reeves is now acting as Administrator of John M. Gipson, deceased.

Respondent admits he purchased land from John M. Gipson, deceased, executed notes... not accurately described in Bill:

Note for $500 dated November 6, 1877, interest from Jan 1, 1878.

Note dated November 6, 1877, bearing interest from Jan 1, 1879.

4 Notes $1000 each dated Nov 6, 1877, bearing interest respectively from Jan 1, 1880, 81, 82 and 1883. All except the last mentioned have been fully satisfied, has paid notes in his possession... he is entitled to a title in fee to land as follows:

Land in District 9 Jackson Co... south bank Roaring River begin William Johnson's east corner... southward direction with William Johnsons line... to a stone... Wm Johnsons corner in David Johnson's line... to include land conveyed by Nimrod Johnson to David Johnson on 17 Dec 1852 by deed of that date... to the line of Jones Mercer Jr formerly line of Wm Johnson between Jones Mercer tract and a tract formerly owned by Daniel Johnson... down the hill... including all the land on the west side of Blackburns Fork... crossing Roaring River at the Boils to the north bank then east to the east boundary line of the McClelland tract... on a line between McClelland tract and Wiley Gaw tract to the mouth of Gaw branch down the river crossing same to beginning.

Also same Dist 9, 56 acres more or less deeded by Samuel Johnson to Laban Loftis 9 Nov, 1859... David Johnson's line southwardly with the top of the ridge to the George Kinnaird line... William Johnson line... his corner in Maberry's line.

One other small tract purchased by Laban Loftis from John Lee, deed October 19, 1861 adjoining above 56 acres. 20 June 1887.

ANSWER of Mary Jane Gipson, Lena May Gipson, Robert Gipson, John Gipson and Levisa Ann Gipson by guardian Emily Gipson to Bill of Complaint of Clay Reeves. Allegations true. 9 Feby 1888.

DEPOSITION 17 March 1888:

J. B. Cunningham. Saw James Lynn pay L. M. Gipson, Administrator of J. M. Gipson.

/s/ J. B. Cunningham

DEPOSITIONS 13 August 1888:

J. B. Anderson. Saw James Lynn pay L. M. Gipson, Administrator of J. M. Gipson.

/s/ J. B. Anderson

John W. Lynn. James Lynn borrowed $50 from me to pay L. M. Gipson. Gipson and my father James Lynn afterwards came to my house and I loaned Father $250 more. I understand that Kirk got it. I gave up the $50 note to my father and took his note with L. M. Gipson security. Think this was November 1884, near the first of the month.

/s/ John W. Lynn

BILL OF COMPLAINT of Clay Reeves, Administrator de bonis non of John M. Gipson against

James Lynn, John M. Gipson York, Samuel H. York guardian of John M. Gipson York, Emily Gipson widow of L. M. Gipson deceased, Mary Jane Gipson, Lena May Gipson, Bob Gipson, John M. Gipson and Levisa Ann Gipson and Armel Gaw all of Jackson Co., Tennessee.

John M. Gipson died in Jackson Co. [blank] 1881... Last Will & Testament Eliza F. Gipson was appointed Executrix and qualified [blank] 1882. Said Eliza died and [blank] 1882 L. M. Gipson was appointed Administrator de bonis non cum testimento anexo [Administrator of property not yet distributed with will attached - mlj] of estate of John M. Gipson deceased.

On 11 August 1886, L. M. Gipson died intestate and [blank] 1886 Orator appointed administrator.

Your Orator's intestate L. M. Gipson and John M. Gipson are the sole devisees of the last will & testament of John M. Gipson deceased. Samuel H. York is the general guardian of John M. Gipson York. Emily Gipson is the widow of L. M. Gipson. Mary Jane Gipson, Lena May Gipson, Bob Gipson, John M. Gipson and Levisa Ann Gipson are the only children or heirs of L. M. Gipson deceased. The children of L. M. Gipson are minors and Armeil Gaw is their guardian. 13 December, 1889.

ANSWER of Bedford Lynn, J. R. Lynn and Joseph Lynn by guardian ad litem Geo H. Morgan to bill against James Lynn now deceased. Suppose allegations true. Protect interest of minors.

NOTICE TO SHERIFF of Jackson County Feby term 1891. Suggested and proven to be true that James Lynn is dead and Barbary J. G. Lynn is his widow and Administratrix and Thomas Lynn, John Lynn, Bedford Lynn, James R. Lynn and Joseph Lynn are children and heirs at law and Thomas Lynn is Administrator and they are the widow, children, Administrator and Administratrix of James Lynn deceased. 1st Monday in September 1892.

BOND of Angeline Richardson and next friend J. T. Anderson and R. A. Cox, security to S. G. Richardson, R. V. Brooks and T. J. Brown.

BILL OF COMPLAINT of Angelina Richardson a married woman who sues by her next friend J. T. Anderson against

S. G. Richardson, R. V. Brooks and T. J. Brown and H. W. Williams C & M, all of Jackson County, Tennessee.

Oratrix is a daughter, heir at law and devisee of R. P. Brooks and Mary H. Brooks, both died in Jackson Co., TN in the year 1881. Her father died after having made a Last Will & Testament. R. V. Brooks was appointed administrator with will annexed of R. P. Brooks, deceased who died seized and possessed of a considerable estate. Some land sold, some unsold. It has been two years six months since his appointment as administrator. T. J. Brown was appointed to collect rents.

Oratrix was devised one-sixth interest under her father's will.

Her mother Mary H. Brooks died seized and possessed of considerable landed estate and a small personal estate and R. V. Brooks was appointed administrator... not yet made settlement.

Since the death of Mary H. Brooks, R. V. Brooks and others filed against W. P. Brooks and others for the purpose of procuring sales of land. Decrees have been pronounced directing sales.

Orator as heir of Mary H. Brooks is entitled to one-fifth of her estate.

Oratrix has purchased two tracts of lands of Mary H. Brooks deceased to wit the Trace Creek tract on the north side of Cumberland River on both sides of Trace Creek adjoining lands of James E. Ray, William Halcum and others at $800 and

the Thomas Hail tract on north side of said river bounded by land of James C. Ray and Cumberland River at $1100... believes her one-fifth interest in her mother's estate and rents of land will probably pay - or come near.

On [blank] 18[blank] she became owner of 80 acres more or less on north side of Cumberland River... her father said R. P. Brooks took possession and either cultivated or rented it... her father collected and managed... agreed to pay Oratrix the rent but never did.

Oratrix was most of the time a married woman, wife of defendant S. G. Richardson, therefore incapable of suing in her own name so Statute of Limitations of six years does not bar her claim and besides it was a running account from year to year.

She was a widow and lived with her father for some time after he took possession. She afterwards on the 18 day of December 1870 intermarried with defendant S. G. Richard [sic] and went to live with him on his own farm. Seeks to recover from R. P. Brooks estate the rents of said lands after her marriage up to his death - 1871 to 1880 inclusive.

When she and said Richardson were married, she was the widow of James H. Lee deceased and then had and still has two living children, namely Oscar Lee and Mary A. Herring wife of Thomas Herring.

Defendant S. G. Richardson was a widower and had a family of four children by a former deceased wife. S. G. Richardson has a valuable tract of land... she does not believe her husband would desire to possess himself... of her estates... desires to keep her estate separate for the benefit of her children.

BILL OF COMPLAINT of American Richardson and husband James Richardson against Elijah Price. They sold a portion of their land to Elijah Price, boundaries wrong.

DEPOSITIONS 27 July 1891:

Marion Wilmotte age 37. Known America Richardson and husband James Richardson about 7 - 8 years, live 100 yards, known Elijah Price about 8 years.

Marion [his X mark] Wilmouth

Charley Allen age 50. Known Marica Richardson about eleven years, James Richardson a long time and Elija Price about 30 years.

Charly [his X] Allen

Ab Allen about age 47. Know parties to suit and land, could not give Richardsons credit on oath, can Elijah Price. Had a conversation with Richardson a few days before the trade and he said he knew where the line was going.

Ab [his X mark] Allen

Sally Allen age 41. Could not give Richardsons credit on oath. Can Elijah Price.

Sally [her X] Allen

Jane Allen age 40. Could not give Richardsons credit on oath. Can Elijah Price.

Jane [her X] Allen

John Hopkins age 30. Live about one-half mile from James & America Richardson. Known America 13 - 14 years, James not so long. Know land known as the John Stout tract of land. Richardsons character bad, Price good. Price is not educated and don't know anything about surveying.

/s/ John Hopkins

Elijah Price age about 48. Am defendant. Complainants executed deed 14 May 1889.

/s/ Eligh [his X] Price

G. W. Jones age 48. Wrote the deed from America and James Richardson to Elija Price dated 14 May 1889 at the request of James Richardson.

/s/ G. W. Jones

J. R. Spurlock age 52 [Nothing new].

/s/ James R. Spurlock

BILL OF COMPLAINT of America Richardson and husband James Richardson against Elijah Price, all of Jackson Co. America Richardson is the only child and heir of John Stout who departed life in Jackson Co. about six years ago, owned following land in Dist. 11, Mercers branch of Flynns Creek... bounded by Jackson Snodgrass... conditional line between John Keath and Jesse L. & Wm Case... along the center of the ridge... so as to give Spurlock the top of the hill... between Jesse L. and William Case and James M. Richmond and John Keath... where John Stout once lived... Elijah Prices north boundary line... John Keath's 250 acre survey near the head of Lacys branch... 50 acres more or less.

Complainants very ignorant, knew nothing of the value of property... Elijah Price induced them to see a portion of their land...

ANSWER of Elijah Price. True he bought land, they knew where the lines were.

America Richardson's maiden name was America Stout and she was the only child of John Stout deceased.

DEPOSITION:

Bob Nemore age 25. Known parties to suit since I was a boy.

Bob [his X] Nemore

Elizabeth Nemore [No age]. Know parties to suit.

Elizabeth [her X] Nemore

BILL FOR SALE OF LAND, Isaac W. Richardson of Jackson Co. against R. D. Circy [sic; Sircy/ Sircey] and wife Martha Circy; R. V. Brooks and wife Mollie Brooks; Charles, Percy and Walter Hufhines all citizens of Jackson Co. and John Hufhines of the State of Texas and Angelina A. Richardson [bottom of page torn - mlj].

S. G. Richardson departed life intestate in Jackson Co., TN 15 September 1890... land 14th District Jackson Co. on Salt Lick Creek of 120 acres more or less bounded north by D. S. Hufhines, west by B. M. Law, south by Mary L. Stevens, east by D. J. Shepard.

S. G. Richardson left the following heirs, to wit:

Complainant Isaac W. Richardson a son,

Defendant Mollie Brooks a daughter,

Defendants Charles, Percy and Walter Hufhines and defendant Martha Sircy, grand children and sons and daughters of Dona Hufhines a deceased daughter.

Defendant John Hufhines a grand son and a son of Bettie Hufhines a deceased daughter.

The defendant Angelina A. Richardson is the widow and relict of said S. G. Richardson.

Isaac W. Richardson is Aministrator. Neither dower nor homestead has been allotted. Angelina is owner in her own right of a separate estate... Minute Docket K page 161, Jackson Co., TN, 6 November 1883.

Land is not subject to partition.

Defendants Charles, Perry, Walter and John Hufhines are minors without guardians and John Hufhines is a resident of the State of Texas.

Defendant Angelina A. Richardson has no family or children living with her. She and her husband S. G. Richardson had no children. All his children by a former marriage are of age.

Complainant Isaac W. Richardson is entitled to one-fourth.

Defendant Mollie Brooks is entitled to one-fourth.

Charles, Percy and Walter Hufhines and defendant Martha Circy are jointly entitled to one-fourth.

Defendant John Hufhines is entitled to one-fourth.

AMENDED BILL of Isaac Richardson. Charles Hufhines one of the minor defendants in this cause has died since the last term of this court leaving as his only heirs at law defendants Percy Hufhines, Walter Hufhines and Martha Sircy his brothers and sister.

DEPOSITIONS July 1, 1891.

D. S. Huffhines age 43, live Jackson County. I am the son in law of S. G. Richardson. I married his daughter. I have lived on S. G. Richardson's land about twelve years. Rents and use of land went for his family. S. G. Richardson was an invalid and confined to him room before his death. He died in 1890 about the middle of last August I think.

Mrs. Richardson made a visit to Texas the latter part of 1884 or first of 1885. Had a conversation with S. G. Richardson while his wife Angelina A. Richardson was in Texas. He said he wanted his estate kept separate to go to his children, that R. V. Brooks wanted him to sign an agreement giving up his interest in Angelina's property, and he said he would if she would sign giving up her interest in his property.

/s/ D. S. Hufhines

T. G. Hufhines. S. G. and A. A. Richardson had separate estates.

/s/ T. G. Hufhines

Jeremiah Ray age 52, live Highland, Jackson Co, Tennessee [Nothing new].

/s/ Jeremiah Ray

Isaac W. Richardson age 33. Live Hollimans Ferry in Jackson Co., am a son of S. G. Richardson deceased. Angelina A. Richardson has no children living with her now. They are all of age, married and living in the State of Texas. My father and Angelina had no children born to them. All are by former marriages.

/s/ I. W. Richardson

Martha Sircy. I was on 14th of last January 20 years old. I am married. I was a grand daughter of S. G. Richardson.

/s/ M. F. Sircy

ANSWER of R. D. Sircy and wife Martha Sircy. True S. G. Richardson departed life leaving Angelina A. Richardson as his widow.

BILL OF COMPLAINT of Josie Richardson of Jackson Co., TN against Tobe Richardson, John G. Howell, Robt Cooke, Joel Richardson. Married 1884... Defendant left her without immediate subsistence on ?last ?Sunday 25th inst [Current month/year]. Tobe Richardson took defendant to her mother's, left, said would be back in an hour, has never returned.

She is informed and believes he has said he did not love complainant... did not intend to live with her...

With a view of leaving the state sold their cow and calf at a greatly reduced price to John G. Howell, believes Robert Cooke had full knowledge... procured one Jerry Richardson to buy defendant's other property. Tobe Richardson has crops growing on land of Joel Richardson.

Asks marriage be dissolved, maiden name Josie Forkum be restored, property attached and decreed to her as alimony.

Josie [her X] Richardson

ANSWER of Joel Richardson to Bill of Complaint. Tobe Richardson did not have crops growing on his land...

DECREE: Cause of Anna L. Richmond vs William D. Richmond, the defendant being a non resident of Tennessee, whereabouts unknown, judgment confessed having failed to appear.

DEPOSITIONS 4 August 1894:

A. D. Maberry age 46. Known defendant 20 - 25 years, Knowed in Armstrong Co., Texas. He introduced a woman to me as his wife while in Texas August 1890. I stop at Will Swift's while in Texas, a brother in law of W. D. Richmond, and Richmond and his wife were there and the family relatives recognized her as his wife. It is the reputation of Richmond that he had a living wife on 11 May 1894, and reputation now he has several living wifes [sic] from whom he was not divorced. Understand the woman he was living with in 1890 they married in Oklahoma.

/s/ A. D. Maberry

P. Chilcutt. Knew defendant about 21 years, knew him in Armstrong Co., Texas. I lived in the same Texas county as defendant about two miles from his house. In 1890 he held a woman out to the community named Rose as his wife. My information she was living 11 May 1894. Richmond had a living wife at the time he married complainant, was not divorced. Reputation he has several wives some in Tennessee, some Oklahoma and some in Texas. He married in Jackson Co. in 1883. In the same year he married in West Tennessee before his first wife was divorced from him. The next marriage I know of was Oklahoma Territory 1890. My understanding he is under indictment in Tennessee.

/s/ P. Chilcutt

Cowen Darwin. Character of defendant when he married complainant is he was married to several women... not divorced. I am a cousin of defendant W. D. Richmond and know his character and reputation. Complainant is a lady of fine reputation, good family, young and inexperienced.

/s/ Cowel Darwin

W. M. Gailbreath age 43. Known W. D. Richmond since he was born except when he was in Texas and the West. Married several times, several living wives, not divorced. Complainant is of good character - fooled by chicanery...

/s/ W. M. Gailbreath

BILL TO SET ASIDE & ANNUL MARRIAGE FOR FRAUD & DECEIT. On 11 May 1894... mock or supposed marriage. Defendant claimed to be a citizen of Colorado... resided in several states, nefarious deseption [sic] of marriage, leading astray young ladies... abandoning them... visited Jackson County, Tennessee to wind up his father's estate and participated in distribution... married her 11 May 1894 - now finds he is a Bigamist...Polygamist... follower of Brigham Young...

Her mother and father came to find her and advise her of the situation, but it was too late as the marriage had been consummated.

Married 1883 in Obion County, Tennessee a lady named Mims - never divorced. 1889 or 1890 married in Oklahoma or Indian Territory, never divorced.

On 16 May 1883 defendant married one Miss Nancy M. Johnson in Jackson County, remained but a short time, went to Union City in Obion County, married Emma Mimms.

[In margin: "Minute Docket K, page 406-7, Chancery, Jackson County, Tennessee" - mlj].

That 30 September 1885 Nancy Richmond nee Nancy Johnson procured a divorce... illicit intercourse with said Emma Mims.

NOTICE TO Frank Richmond, guardian of W. F. , J. A. and Jennie Dawes. Last bond made Jan [or Jun] 7, 1889, never made settlement as guardian, law requires bond every two years. Appear Wednesday, November 28, 1894 and give renewal bond. [Nothing to indicate parents - mlj].

SETTLEMENT 21 June 1902 with Frank Richmond, guardian of Fannie M. and Frank Richmond, Jr. [Nothing to indicate parents - mlj].

Recap indicates amount to be divided of $343.60.

Disbursements May 1900:

Fannie Carlin $171.80

Frank Richmond $171.80.

SETTLEMENT 23 June 1888, Estate of Henry Richmond, deceased. Wills, Admin & Inv Book B, pages 330 and 331. Include notes on Frank Cooper, W. T. Cooper, Frank Richmond.

CREDITS:

Hannah Cooper, her distributive share June 26, 1886, $787.56.

Abbie Hail, her distributive share June 26, 1886, $687.56

Maggie Maddux, her distributive share June 26, 1886, $687.56

W. H. Richmond, his distributive share June 26, 1886, $366.69

Elisabeth Cooper, her distributive share June 26, 1886, $1087.56

Ann Holleman, her distributive share June 26, 1886, $987.56

[Note: Nothing I saw indicated why some payments were unequal, i.e. whether an heir may have received disbursement previously, borrowed against inheritance, or otherwise - mlj].

S. R. Tolbert, Burial Expenses, paid June 30, 1886, $5.50.

Williamson & Cornwell, making coffin, $10.00.

Dr. J. V. Minor, medicine $12.30, invoice July 5 1886 with interest July 2, 1886 of $1.47.

12 April 1889, Received in full balance of my distributive share of Henry Richmond.

/s/ Abbie Hale

/s/ M. D. Haile

12 April 1889, received in full, balance of my distributive share of Henry Richmond.

/s/ E. L. Cooper

END OF REEL #109