Jackson Co., TN Loose District/Chancery Court Papers Reel #115
Stafford - Stafford, W. and
Delinquent Tax List Dist 5, 1888

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[Note: This is a continuation of the last case on Reel #114 - mlj].

DEPOSITION September 6, 1907:

W. W. Draper. I filed the bill as Solicitor for W. T. Bennett ordering Stafford land sold for payment of debt. H. W. Williams represented himself as agent for Bennett who lived in Mississippi. A. C. Stafford said he had a receipt for payment of debt, I asked him to show it to me. I was appointed Deputy Clerk & Master by H. W. Williams 6 Feb 1888. Williams was in office when I came to Gainesboro in 1881 and remained in office until 1889. Stafford told me something about L. S. Anderson knowing the debt was paid.

/s/ W. W. Draper

Mrs. M. A. C. Williams age 68, live Gainesboro. Know A. C Stafford, knew J. T. Stafford in his lifetime. I was acquainted with Dr. W. T. Bennett, we were cousins. Brother and sister's children... W. T. Bennett came here and said he would have left the land to me, but that I had been too frisky. He was talking about the Stafford land.

Ques: State whether A. C. Stafford ever proposed to purchase your interest in the lands in controversy in this case as heir at law of Dr. W. T. Bennett.

Ans: I don't remember the exact date but it was last year some time he came to me - said he'd give me as much as anybody. I sold my interest in the land to J. W. Pickett and I reckon Wash Chapman had an interest in it. I got $15 and was to get $10 more... I have no interest in the case. The trade was I would get my money whether they won or lost.

Ques: Who was the father and mother of W. T. Bennett.

Ans: John Bennett was his father and Nancy Bennett was his mother. She was a Holliday before she married.

Ques: How many brothers and sisters did John Bennett have.

Ans: He had three Jim, Bill and Ben they are all dead. He had two sisters, they are both dead.

Ques: Did your uncles and aunts that are dead have children.

Ans: Jim Bennett had some. Ben was never married. Bill left here 50 odd years ago and he has never been heard of since. My mother had five children all dead but three. Aunt Sally Terry had two children both died without children.

Ques: How do you know Sally Terry's children died without any children.

Ans: Because I got letters, and they were never married. One died before her father left here. My Aunt Sally died here, Mary died before her father left here and he took Sally off with him and he wrote back that she was dead. I was at the burial of Mary. She was buried in Smith County near what they call Buffalo. I can't tell you when she died. My Bible has been burned. She died before the war.

Ques: How many brothers and sisters did W. T. Bennett's mother have?

Ans: I don't remember.

/s/ M. A. C. Williams

S. B. Fowler 54, practicing physician, live near Gainesboro, about 1 1/4 miles for five or six years. I lived in Gainesboro 18 years.

Ques: Did you know J. T. Babe Stafford during his lifetime.

Ans: I knew J. T. Stafford. I came to Gainesboro in 1882 and knew him until his death. I am a graduate of Ohio Medical Collecge since 1881. I took a post graduate course at the Polyclinic College of N. Y., practice of medicine 27 years. Treated J. T. Stafford a couple of times, bought chicken and fodder from him.

Ques: Say whether J. T. Stafford was a man of very weak mind...

Ans: I regarded him as below the average of mankind.

Ques: Say whether he left two children... weak minds.

Ans: He has one boy that is below the average of mankind and doesn't talk very well. I don't know anything about the girl.

/s/ S. B. Fowler

ADJOURNED, resumed Sept 7, 1907 with Hickman Dowell:

Hick Dowell. I am a son in law of Dan Allen. /s/ H. H. Dowell

M. J. Dixon. Have been a practicing attorney 21 years. I was employed in this case by J. J. Stafford when Chapman and Pickett filed a bill against him. I filed an answer for J. J. Stafford. A. C. Stafford had made Joe J. a deed to his interest. I told A. C. Stafford he should file to have the old sale of land set aside. J. J. Stafford said he did not want to get into law and gave A. C. Stafford back the deed. Me and A. C. Stafford went to see Geo G. Haile who represented some of the Babe Stafford heirs as guardian ad litem... grounds to set aside...

A. C. Stafford had paid off the debt.

He was never cited to answer the bill filed by Bennett.

Babe Stafford was an idiot and not ___ ____ and that the entire proceeding of Bennett vs A. C. and Babe Stafford was void.

Some of the Babe Stafford heirs were minors and some not very intelligent so I advised him to get someone to file as next friend for all of them and he said he would do it. We met at my office two or three different days and he said he had the bill pretty well in his head and that his son Tom was a good scribe and he would get him to write it up and in a day or two he came back with the draft and I looked at it and we decided it was a good bill. We lost the case here in this court but gained it in the Supreme Court. Believe my fees are worth $250 or $200.

/s/ M. J. Dixon

J. J. Stafford. I am one of the parties to the suit, A. C. Stafford and others against G. W. Chapman et al and T. G. Stafford vs J. J. Stafford et al. I emploid [sic] M. J. Dixon. A. C Stafford was with me is my recollection. I owned a one-third interest in the Rhoda Stafford dower tract. Dixon said he would charge $15 and I signed a note and paid it off.

Ques: Say whether your father A. C. Stafford also employed him.

Ans: Yes sir... was to represent both for $25 as I understood.

/s/ J. J. Stafford

A. C. Stafford. Employed Miles Dixon. He said he would represent me and Joe for $25. I owned 1/6 in the dower tract and Joe owned 1/3. I expected Joe to pay the biggest part.

Ques: Who owned the other part.

Ans: J. T. Stafford's heirs.

Ques: Did either of you sign a note for the fee.

Ans: Joe did for $15. I was straped [sic; strapped] and hardly able to keep clothes fit to wear... I was a poor man, they had my land tied up so I could not do anything. I had granulated sore eyes and was in very bad health.

/s/ A. C. Stafford

Dr. N. M. McCoin. I have been practicing medicine 26 years, reside Jackson County. Knew J. T. Babe Stafford... inferior brain capacity...

Ques: Say what you know about his family...

Ans: There was one called Jasper... an idiot. Don't know relationship.

/s/ N. M. McCoin

J. W. Anderson, previously gave deposition.

Ques: State where Asa Anderson lived.

Ans: In the Free State in this district.

Ques: Did John Jackson live with his mother and step father when they lived in the Free State.

Ans: I think he did most of the time he would come and go.

Ques: State whether John Jackson was a grown young man some 21 when Asa Anderson moved up on Roaring River.

Ans: He was a right smart boy. Don't know if grown.

Ques: How long did Asa Anderson live up on the river with the mother of John Jackson...

Ans: ... lived there several years before he moved off of the Gray place, and he lived on the river above there until he died, he has been dead four or five years.

Ques: State whether John Jackson continued to live in the Free State after his step father and mother moved to Roaring River.

Ans: That is my recollection.

Ques: State where A. C. Stafford lived when you moved to Roaring River.

Ans: At the Rhoda Stafford farm in the Stafford old house. He lived there with his mother [who] lived there. His family lived there until him and his wife parted. They moved to the Barlow place at the mouth of Blackburn's fork.

Ques: Was you acquainted with T. J. Stafford alias Cap Stafford in his lifetime.

Ans: I have seen him.

Ques: Did you ever see Dock Stafford a brother of Cap.

Ans: Yes sir.

Ques: Cap Stafford was the father of Babe was he not?

Ans: Yes sir.

Ques: Dock Stafford had a son named Jasper did he not.

Ans: Yes sir. He is still living as I understand.

James W. [his X] Anderson

George Stafford age 47, live 6th District, am a farmer. Knew Babe Stafford in his lifetime. He married Martha Reed. He had a spell of fever not long after he married and Dr. Bennett waited on him... I was in Gainesboro and heard A. C. Stafford tell Dr. Bennett he had charged too much that he could take half and that would be enough. Dr. Bennett said borrow and pay it off.

Ques: Were they friendly or otherwise.

Ans: They seemed to be a little bit harsh - that is Anderson Stafford and Dr. Bennett. They went off together friendly.

Ques: Did you not leave here and go to Illinois. If so when.

Ans: Spring of 1886. The conversation was 1884 or 1885.

Ques: Do you know John Kinnaird, if so what kin is he to A. C. Stafford.

Ans: Son in law.

Ques: Do you know Russel Kinnaird brother of John Kinnaird who is son in law of A. C. Stafford.

Ans: Yes sir... I have heard a heap of hard things about Russ...

/s/ G. W. Stafford

J. J. Stafford age 40, live in the 11th District now, farm. [Rest missing - mlj].

John S. Burris age 72, live Gainesboro, am a farmer. I lived on Aarons branch up towards Roaring River about ten years about a mile from the Cap Stafford farm. My recollection is Babe Stafford died while I lived there.

Ques: State whether Jasper Stafford has a brother John Dock Stafford.

Ans: Yes I think Dock is his brother they say he is.

Ques: State whether John Dock and Jasper are children of the old man John Dock Stafford deceased.

Ans: They say so. Jasper Stafford is said to be a son of Cap. There are some idiots in this Stafford family in the John Dock family his daughter Manda is an idiot and Dow Stafford has a daughter who is an idiot. Jasper a son of Dock is an idiot.

John S. [his X] Burris

George Kinnaird age 24, live Gainesboro. I am a son of Russ Kinnard. Know Dan Allen. A conversation came up at my father's house on the porch that the Rhoda Stafford land was to be sold to pay a doctor bill. Dan Allen said it was not right that he saw Anderson Stafford pay the debt off... those present to the best of my recollect were me and my father, my brother Bob my Uncle John Kinnard and his son George, Henry Gore col., Dan Allen and his son Warren...

... my brother Bob Kinnaird.

/s/ George W. Kinnard

Bob Kinnard age 22, am a farmer and son of Russ Kinnard. /s/ R. ?S. Kinnard

George Kinnaird age 24, live 15th District, am a farmer. Russ Kinnaird is my uncle.

Ques: What kin are you to complainant A. C. Stafford.

Ans: He is my grand father.

Ques: What kin are you to complainant Martha Harris and her children by Babe Stafford.

Ans: ... me and her children would be second cousins.

/s/ G. E. Kinnard

J. M. Dudney age 47. Live near Gainesboro, am a Rural Route Carrier. I was raised on Aarons branch, 1st District. I first went to school on what was called the Gray place now Andy Johnson place.

Cap and Dock Stafford were brothers.

Jasper and Amanda were Dock Stafford's children. They are first cousins to Babe Stafford.

/s/ J. M. Dudney

DEPOSITIONS September 11, 1907:

J. B. Dudney age 61, live 1st District, am a farmer. Knew T. J. Stafford father of Joel and Anderson Stafford in his lifetime. Uncle Caps is what we called him, his mind was considerably below that of an average man.

Knew J. T. (alias Babe) in his lifetime he attended school to me... mental condition below average man... T. J. Stafford's brother Dock has a guardian.

Ques: What kin are you to A. C. Stafford.

Ans: We are some kin but I don't really know, we are distantly related.

/s/ J. B. Dudney

B. B. Chaffin age 58, live 1st District, am a farmer [Nothing new - mlj]. /s/ B. B. Chaffin

J. M. Chaffin age 49, live near Roaring River. Knew J. T. Stafford in lifetime, lived 1 1/2 - 2 miles, raised in same community.

/s/ J. M. Chaffin

ADJOURNED to September 12, 1907:

W. C. Reed age 57, live 1 1/2 miles from Gainesboro, am a farmer. I knew J. T. Stafford he was a brother in law to me he married my sister. I lived 4 - 5 miles of them part of the time and 3 miles part of the time.

/s/ W. C. Reed

James [or Jones] Reed age 50, live 6th Dist., farmer. Knew J. T. Stafford in lifetime. Known Dan Allen 30 years. Had a conversation with Dan Allen about Dr. Bennett being paid. It was at Robert N. Allen's house. J. T. Allen and Robert N. Allen was present. Robert N. Allen is dead now.

Ques: When were you first married.

Ans: I have been married about 26 years since first time.

Ques: When did your sister and J. T. Stafford marry?

Ans: They married some time before I did.

Ques: Did they stay at W. C. Reed's after they married?

Ans: I don't recollect.

/s/ Jones R. Reed

William Allen age 65, live 1st District, farmer. Knew J. T. (Babe) Stafford. I never had nary a lawsuit.

Ques: You are a brother in law of Complainant A. C. Stafford are you not?

Ans: Yes sir.

Ques: Tell if J. T. Babe Stafford made use of silly expression.

Ans: I worked with him in 1865 and he had a heap of foolish talk.

Ques: How old was he in 1865.

Ans: He was a good big plow boy he plowed that summer.

William [his X] Allen

ADJOURNED to September 14, 1907:

Russ Kinard age 58, live 1st District, farm. Know Dan Allen he was helping me pull fodder 2 or 3 years ago... Dan said Anderson Stafford paid the doctor bill and Fay Anderson wrote the receipt. Knew J. T. Stafford 35 years or so up to his death. [No signature].

J. W. Stafford age 62 [or 67 - mlj]. Occupation merchant. Knew T. J. Stafford, mind not good. He was the father of J. T. Stafford.

Ques: What is your relationship to A. C. Stafford and to J. T. Stafford's children?

Ans: About 3rd to 5th cousins.

Ques: Was not his mother Rhoda a woman of strong natural sense.

Ans: Yes sir of very good mind.

Ques: Did J. T Stafford ever have any lawsuits.

Ans: If he did I don't remember.

Ques: Did he... file a bill for divorce against his wife Martha Stafford now Martha Harris wife of F. M. Harris.

Ans: I think he did...

/s/ J. W. Stafford

ADJOURNED to September 17, 1907:

W. H. Young, age 63. Live Gainesboro, am a farmer and lawyer. T. J. Stafford had one brother called Dock... I called a natural born idiot he also had three children I considered idiots and one not so bright but not an idiot.

Ques: Did you know old man Johnnie Stafford in his lifetime.

Ans: Yes Sir.

Ques: Was he a man of ordinary sense.

Ans: Yes Sir that old John was.

Ques: Did you hear A. C. Stafford say John Stafford was a brother of T. J. Stafford.

Ans: Yes one John Stafford if that was the one I heard him say it.

Ques: Did you hear him say Polly Butler was his father's sister.

Ans: I heard him say... I did not know her. I never saw her.

/s/ W. H. Young

Wm B. Stafford age 43, live DeKalb Co. [Tenn], farmer. A. C. Stafford is my father.

Ques: Who looked after J. T. Stafford's business.

Ans: Granny and Pop - Rhoda and A. C. Stafford, then after he married, Martha mostly.

Ques: When were you married.

Ans: 19 years ago last February. After we married we lived with Pop and grandmother Rhoda, stayed for a year after we married, then up to Blackburns fork to Mr. Andersons place 3 or 4 years, then out on Gainesboro road about seven miles from Gainesboro a little over a year then back to Blackburn's fork a little over a year then back to Roaring River to John Stafford's place from Spring until Christmas and from there to DeKalb Co.

/s/ W. B. Stafford

H. H. Johnson age 54, live 9th District, farmer. Knew J. T. Stafford (Babe) in his lifetime. Know his wife, now Mrs. Martha Harris.

Ques: Is she not a woman of good strong mind.

Ans: I suppose her mind was good, a good average mind.

Ques: What relation is she to you.

Ans: She is a first cousin.

/s/ H. H. Johnson

John L. Young. W. H. Young who was an attorney in lawsuits of F. M. Harris, Pickett & Chapman and A. C. Stafford et al was my father. I am Administrator of his estate. [No signature].

D. C. Morgan age 36. Live 2 1/2 miles from Gainesboro, farmer. Lived in Jackson Co. all my life. I was gone nearly two years, 1892 and 1893. Known Russel Kinnard 15 or 20 years.

Ques: Your father J. M. Morgan and Kinnard had some trouble...

Ans: I rented Russell my father's land and he failed to comply with the contract and they had a lawsuit.

/s/ D. C. Morgan

James W. Anderson Jr., age 45 or 46, live 1st District, farmer. Know Russell Kinnard, Knew J. T. (Babe) Stafford. I am a son of Asa Anderson.

Ques: What relation are you to John Jackson.

Ans: We are half brothers. My recollection is when my father and mother moved to Roaring River John Jackson went to Kentucky, was there something like 5 or 6 years.

Ques: Did he then return to the Free State?

Ans: Don't recollect.

Ques: Where did you attend school.

Ans: I went to Hoovers school house I don't remember the other place - it has been a good while back.

James W. [his X] Anderson Jr.

DEPOSITIONS March 11, 1909:

Robert L. Hamlet age 32. Know Martha Harris wife of F. M. I saw Martha Harris. She said she paid the [W. T. Bennett] debt. She said she let the last two mules she had go on it. She said Joe and Anderson had been trying to root her out ever since Babe died but that she had bought the place now and had a deed and as quick as the old lady died she was going to show them which way the rooting was going.

Robert L. [his X] Hamlet

Lee Ann Hamlet. I have heard the foregoing deposition of my husband read... adopt the same as my deposition...

Lee Ann [her X] Hamlet

William J. Terry age 66. Live half a mile of Gainesboro, am a farmer. Cap and Dock would stop at my father's and get dinner when they went to the mill. I never ate with them... when someone was there I had to wait... They were not too bright but smart enough to get something to eat.

Ques: Give your relationship to G. W. Chapman.

Ans: First cousins.

W. J. [his X] Terry

Clay Reeves age 50. Live in Gainesboro, am a traveling salesman.

Ques: Did you know L. S. (Fay) Anderson in his lifetime?

Ans: I was engaged in the drug business with him in Gainesboro on the SW corner of the square. Went in business 1884 and remained in business about two years. I bought the business from Dr. Fowler and sold half interest to L. S. Anderson and later sold out to L. S. Anderson. Before that he was engaged in the mercantile business before he went in business with me and on the south side of the square.

/s/ Clay Reeves

M. Y. Sittle [possibly Settle] age 48. Knew J. T. (Babe) Stafford several years. One year I lived within one mile and within 3 1/2 miles the balance of my life.

Ques: What relation are you to Complainant J. W. Pickett?

Ans: About third cousins.

Ques: What relation is your wife to J. W. Pickett?

Ans: They are first cousins.

W. T. Copeland age 51, farmer, 1st District. I have lived in Jackson County all my life. Know the Rhoda Stafford dower tract, was raised with J. T. (Babe) Stafford. I lived there with them and worked there with them and made a crop there with them one summer and hauled logs one season and worked there off and on in different years. Attended church and social gatherings.

Ques: Did he file a bill of divorce...

Ans: He told me he was. She had gone off to her father or brother or some of her folks. They got back together and lived together til he died.

He was given to spells of sick headache... wouldn't work until it wore off he tied up his head I have known him to work when he was complaining of his head.

/s/ W. T. Copeland

J. W. Anderson. J. T. West, Asa Anderson and myself purchased a part of the S. S. Gray land, Tract 1 known as the homestead 18 May 1878. Me and Asa Anderson moved on the place Spring 1879 about March.

Asa Anderson was John Jackson's step father. John Jackson moved to the Gray place and lived there with Asa Anderson until John married.

J. W. [his X] Anderson

DEPOSITIONS September 17 & 18, 1907:

G. W. Chapman. Know Martha Harris, her husband is F. M. Harris. Know R. B. Stafford. Had a conversation with Marion Harris at his house in the presence of Martha Harris, Bertie Harris, R. B. Harris, T. Harris and Mr. Acre and others... I was passing by and they called me. Martha Harris said she had been down to *uncle Henderson Young's and had bought the balance of Aunt Rhoda's dower. Henderson was to warrant and defend the title against the Bennett heirs.

/s/ G. W. Chapman

[* "uncle" used in this context could be kinship, or term of respect/affection - mlj].

J. R. Chaffin age 60, live on Roaring River, 1st District, farmer. Known Rhoda Stafford dower tract about 40 years, live one mile.

/s/ John R. Chaffin

BILL OF EXCEPTION REGARDING EVIDENCE:

Deed from T. J. Williams and wife M. A. C. Williams to Complainants G. W. Chapman & J. W. Pickett

Deed from Newton More and wife Katherine More date June 29, 1906

Deed from Sallie Bruce & J. B. Bruce to J. W. Picket & G. W. Chapman

Deed from J. W. Bennett & John Bennett [No grantee; probably to Pickett & Chapman - mlj]

Deed from F. A. Bennett to J. W. Pickett & G. W. Chapman

Deed from Allen S. Bennett, Charley McClellan, Kate McClellan, Nanny Bell Bennett dated Jan 23, 1906.

[These next three were marked through - mlj]:

Deed W. D. Monday June _7, 1907

Deed J. B. Holloday Jan [or June] 28, 1907

Deed Albert Howell

DEPOSITIONS about September 1907:

W. C. Morgan age 64, live Cookeville, am D. U. S. Marshall. June 1885 was Sheriff of Jackson Co. and lived at Gainesboro.

A. S. Lock. Was first cousin to W. T. Bennett. Sold my interest to Wash Chapman for $10, gave him a quit-claim deed.

Ques: How many W. T. Bennett heirs are they?

Ans: I don't know. There is all the Locks and some of the Holladays and some of them dead. Three living of the Locks - Myself, Polly Ann Williams and Kittie Moore. I don't know whether brother Wills children are living or not he is dead left three children. My Sister Sallie Sadler is dead and left three children. I don't know if they are living are not.

I don't know how many of Jim Bennett's children are living - they are the same kin to W. T. Bennett that I am. Dr. Bennett had two uncles on the Bennett side, Ben Bennett and Will Bennett. I don't think Ben ever married but I understand Will Bennett did and left some children. He had an aunt on the Bennett side married a Terry she is dead and left some children and some are dead and left children.

Dr. Bennett's mother was a Holliday she had some brothers and sisters. Her sister was Jim Bennett's first wife. Jim Bennett was married three times and had children by all of them but I don't know how many are living.

Dr.'s mother had two brothers Bob and Breck [Holliday - mlj] and they died leaving children but I don't know whether any of them are living or not.

Dr. W. T. Bennett didn't have any brothers or sisters.

/s/ A. S. Locke

ANSWER of G. W. Chapman to Bill of Complaint filed April 23, 1914 by Eliza Stafford. Denies Complainant is owner of land or that same were devised to her by the will of Uriah Stafford because title was never vested in Uriah Stafford.

Admits Josh Chapman was his brother... died [blank] September 1890 and his estate has been distributed among his heirs.

Complainant waited 30 years after the death of Uriah Stafford to file.

BILL OF COMPLAINT of Eliza Stafford and husband G. W. Stafford against G. W. Chapman. Complainant says she is owner of land in 6th District and has been for some time prior to 1883, bounded north by Gaws, east by Gaw, south by Gaw and Mercer land and west by Gore lands. Land devised to her by the will of Uriah Stafford when she was an infant. Married to George W. Stafford when an infant...

Defendant and Josh Chapman were pardners [sic]... he and defendant cut logs...

Uriah Stafford's will was probated 2 July 1883...

Eliza [her X] Stafford, /s/ G. W. Stafford

REQUEST FOR CONTINUANCE: Complainant cannot go to trial without these witnesses:

Byrd Stafford lives in Nashville, has been summonsed.

Henry Gore has been living at Carthage, Tennessee, subpoena sent to Smith Co., returned with a note saying he had moved to the State of Arkansas... is informed he has been working for the Welch State & Heading Co.

D. N. Johnson lives near Gallatin, Tennessee.

George Stafford husband of Complainant went to Nashville - the said witness has a case in the Federal Court at Cookeville and will have to be there Monday-Thursday.

Hughie Whetstone likewise has a case in the Federal Court at Cookeville and will have to be there Monday-Thursday. April 23, 1915.

Eliza [her X] Stafford

Mart Scott age 67, live Jackson Co., farmer. Known Eliza Stafford since she was a child, known Mr. Chapman all his life. Knew Uriah Stafford and his wife Patsy Stafford in their lifetime.

Uriah Stafford sold timber off the land to Howell Williams [who] ran a steam mill it was setting down there at the spring where Marion Steward now lives.

Ques: After the death of Uriah Stafford who lived with his widow Patsy?

Ans: George Stafford and his wife stayed there a year or more... Daniel Morgan one year... George Stafford and wife the next year. I went down and lived with her six years... was living there at her death.

Mart [his X] Scott

W. L. Brown age 52, live 6th District, occupation carpenter and farmer. Known Wash Chapman all my life, known her [Eliza] since she was four or five.

Ques: Did you marry at the same day and time Complainants married?

Ans: Yes sir in the year [18]87.

/s/ W. L. Brown

C & M NOTES:

Searched for will of Uriah Stafford, can't be found. Copy read - Date of will June 8, 1874, probated July 2, 1883.

George Stafford, husband of Eliza. Married April 21, 1887, wife not 21 when married. "Patsy" Stafford died after they married.

DEPOSITIONS about September 1907:

D. N. Johnson age 68. Live Sumner Co, lived Jackson Co. until a few years ago.

/s/ D. N. Johnson

George Stafford age 53, live Jackson Co., am the husband of complainant Eliza Stafford. We married 21 April 1887, Uriah died 1882 or 1883, willed land to Eliza. Widow Patsy died 1892 or 3, something like that.

Ques: State whether the will of Uriah Stafford and the party named in the will as Eliza Gipson Walker Heady is your wife.

Ans: Yes sir.

Land described as being in the 16th District is in the 6th District now.

Ques: Which one of the rafts did Josh Chapman say brought $800 on the Nashville market.

Ans: That was the first one they ran after Uncle Hugh's [?Uriah Stafford] death.

Ques: Who assisted in cutting and hauling.

Ans: They had some darkies with them. Little Henry Gore, Louis Armstrong, Meridy Gore Colored, Hughey Whetstone and Bird Stafford and Hughey Whetstone's daddy Jerry.

Bird Stafford is about Nashville, Tennessee I think. Jerry Whetstone is dead and those darkies I don't know where they are. Hughey Whetstone lives here in 6th District. I understand Henry Gore is in Arkansas.

Ques: What is your occupation?

Ans: Farm work.

Ques: Are you not also a minister of the gospel?

Ans: I don't claim to be a minister of the gospel. I have spoke a few times in public.

Ques: What was the Federal case in Cookeville.

Ans: I was under bond to appear in Federal court at Cookeville. Somebody had reported me for making whiskey, Wash Chapman I suppose - he told me he did. I wasn't guilty. I started into trial and saw they was going to outswear me and I submitted. I didn't submit I had done the crime but just submitted to take three months in jail. I stayed 103 days. One Government witness was Porter Masters and another by the name of Clem. Mr. Clem said he was just over here from Alabama and was the first raid he made here. Porter Masters lives I think in Putnam Co.

Ques: What do you mean by "infant" in your bill.

Ans: My understanding infant is a young child. My wife was about 17 when we married. We were not married when the first raft was run we were when the last was run.

We moved to the land in 1890 [or 1891; writeover]. The grant [to Uriah Stafford] says there are 295 1/2 acres. I lived with my father in 1887, in 1888 with Aunt Patsy Stafford, in 1889 and 90 on the Kirkpatrick farm... about two miles.

Ques: Why did you wait so long to collect from Wash for the timber?

Ans: I didn't know I had any right.

Esq Abb Pharris is the first one told me the old lady didn't have a right to sell the timber.

Ques: Has Esq. Abb Pharris been dead 12 - 15 years?

Ans: I expect he has.

I came right straight to the Court House and advised with General Butler about a suit and was discouraged in bringing it.

/s/ G. W. Stafford

Mrs. Eliza Stafford about 48 years old the 25th of next February. I live out there in what they call Tick.

Ques: State your full name before you married.

Ans: Eliza Walker Gipson Heady before I was married.

Ques: How old were you when you married.

Ans: About 17.

Ques: Where were you living when Uriah Stafford died?

Ans: Virginia - came here about a year after, stayed with Aunt Patsy Stafford pretty near all the time.

Mounce Butler read the will and said my daddy was my agent and he had a perfect right to sell it. It has been five or six years since I talked to him. Abe Hestand told me he didn't see how I could be knocked out and said see another lawyer. I went to see John Gore. He said he'd read the will and would write me a letter but he never did. I was mighty discouraged. Then I went to see [D. B.] Johnson there.

Abb Pharris was the first said Patsy Stafford didn't have the right to sell the timber. He was there doctoring one of our children, Lillie Mai I think. She was about six. She is going on 15 now.

Five or six years ago when I talked to John J. Gore one of my girls was present - Lizzie Brown, now.

Eliza [her X] Stafford

BILL OF COMPLAINT of A. C. Stafford against Mary Stafford. Married in Jackson Co., TN 25 April 1863, together until December 1897, defendant abandoned him. He told defendant he was going to rent a place for him and his family to move to, she replied he need not, that she would not go with him. 7 October 1911

[Note: A. C. Stafford did not sign; J. M. Dudney stated he would be security for costs - mlj].

BILL OF COMPLAINT of A. C. Stafford against Polly M. Stafford. Married 25 April 1863, together as husband and wife to December 1895. They were living in the house with his mother Roda [sic] Stafford. Petitioner and his mother had some differences and could not get along, asked his wife to move... defendant refused. At various times he has requested her to live with him... June 12, 1897.

/s/ A. C. Stafford

BILL OF COMPLAINT of Annie Stafford against Cleveland Stafford, both of Jackson Co. Married Jackson Co. 4 March 1900, together until last July when he deserted her... failed to provide... never bought or provided a dress or a pair of shoes or knife and fork nor made any effort to go to housekeeping... forced to seek a home with her father where she is presently living... asks divorce, name changed to Anna York.

This is not made out of levity or collusion with defendant... due to her extreme poverty she is unable to bear expense... Feby 1st, 1901.

Annie [her X] Stafford

ANSWER [of Cleveland Stafford]: True they married as stated... Complainant told him she would not live with him... said she would get a divorce and marry George Huff, that she cared more for the dirt under George Huff's fingernails than she did for Cleveland.

Cull Huff and Geo Huff have... been the prime cause...

She has told him she did not want any support from him.

BILL OF COMPLAINT of Darthula Stafford against John Stafford a non-resident citizen of the State of Arkansas. Married in Jackson Co. 6 September 1873, together as husband and wife when he abandoned her September 1877 without cause, left her and little children without necessary subsistence... After eight long months he returned, she forgave... made fair promises. September 1879 he again abandoned her. He has been guilty of cruel and inhumane... administered corporal punishment... unsafe to cohabit.

Has two children Mary age 4 and Lucy age 2 the issue of said marriage. Asks divorce, name changed to McComack her maiden name... care, custody and control of children... he be enjoined from interfering.

This is not made out of levity or collusion with defendant... owing to poverty she is unable to bear expense of this suit. 30 September 1879.

Darthula [her X] M. Stafford

[Note: There is a small sheet of paper, followed by these names - mlj:] S_______ ["Security" or "Summons" or ?] Frank Bailey, Henry Stafford, James Pryor, Dow Stafford, W. D. Stafford.

DECREE issued 17 January 1880.

ANSWER of R. B. Stafford. Admits marriage, denies he struck her or is about to dispose of property, admits owning property listed except a mule. 15 March 1909

DECREE: Allegations sustained by proof, bonds of matrimony be dissolved... name Emily L. Hamlett restored, defendant pay cost.

COMPROMISE: Division of property March 15, 1909 [detailed].

/s/ R. B. Stafford, Emily [her X] Stafford Witness: /s/ A. B. Hamlett

BILL OF COMPLAINT of Emily L. Stafford against R. B. Stafford, both of Jackson County Tennessee. Married in Overton County, TN 10 March 1909, she having to run away to another county being under age 16, together till last Saturday. He struck her with a switch and she left him. Last Saturday a week ago about 5 March he struck her with his hand... divers times after.

Above is true, not made out of levity or collusion with defendant... owing to poverty cannot bear expense. This 15 [No month] 1909.

/s/ Emily L. Stafford

DEPOSITIONS 20 December 1911:

Allie Brown age 52, live Flynn's Lick, 11th District. I know the parties. Complainant is my daughter and defendant is her husband. They lived on our place some... Got along well until five or six years before they separated... defendant abusive... cursed her, threatened to kill her with an axe but only hit her with his fist... She came to our house to rest and said Tom the defendant would not let her sleep.

Allie [her X] Brown

M. J. Davidson age 58, live 11th District. Complainant worked the crop and plowed and done all kind of work. I have heard him curse and abuse her.

M. J. [his X] Davidson

GUARDIAN SETTLEMENT 22 January 1914 with Henry Stafford, guardian of Jasper.

GUARDIAN SETTLEMENT February term 1884 with John B. Stafford, guardian of Joseph [sic] and Amanda, minor heirs of James Stafford. Rents for year 1883 of $140 + $8.40 interest. Amount allowed guardian for clothes, etc. of $143.60, less recording fees, balance due heirs $0.00.

GUARDIAN SETTLEMENT 25 September 1895 with J. B. Stafford, guardian of Jasper & Amanda Stafford, Lunatics...

GUARDIAN SETTLEMENT Feby term 1879, with John B. Stafford, guardian to Amanda & Jasper Stafford, Lunatics and heirs at law of James M. Stafford. Rent for year 1877, $140...

GUARDIAN SETTLEMENT 4 February 1915, Henry Stafford, guardian of Jasper Stafford.

DEPOSITIONS:

W. R. Stafford [his X] and J. W. Stafford [signed]. Need to sell timber on property - some struck by lightning, some endangered by fire, provide income for Jasper and Amanda Stafford. 3 November 1884.

BILL OF COMPLAINT of John B. Stafford against Jasper and Amanda Stafford, all of Jackson Co., Tennessee. Complainant and defendant are the only heirs of James M. Stafford who departed life in Jackson County intestate, bounded north by T. J. Stafford, east by Chapman and B____ known as the Kelly tract, south by Lans Robbins, west by heirs of Mounce Gore. Jasper and Amanda are idiots and Complainant is guardian, valuable timber subject to be destroyed, some has been. Asks court that they be allowed to sell timber to provide funds for Jasper and Amanda Stafford.

John [his X] B. Stafford

DEPOSITIONS:

Baylus Stafford, age 35. Know the land, was raised on the place. Best to sell timber for funds.

Baylus [his X] Stafford

John H. Stafford age 60, farmer and lawyer. Known land 40 years, lived more than four miles. About 250 acres, 140 acres tillable.

/s/ John H. Stafford

J. J. Stafford age 39, live 1st District, am a farmer. Lived adjacent most of my life.

/s/ J. J. Stafford

GUARDIAN SETTLEMENT with Henry Stafford, guardian of Jasper Stafford, January term 1916.

GUARDIAN SETTLEMENT with J. B. Stafford, guardian of Jasper and Amanda Stafford. January term 1891.

GUARDIAN SETTLEMENT with Henry Stafford, guardian of Jasper Stafford. 22 Jan 1917.

[Note: This case appears to be whether John H. Stafford as County Trustee or J. M. Lee lost/misplaced tax funds for the year 1888 - mlj].

UNPAID TAXES for the year 1888, District 5 placed in hands of J. M. Lee for collection:

Armstead, Mrs. M. T. $3.80; Apple, Adam $2.00; Allen, Wm $2.00; Apple, James $2.00.

Barnett, J. C. $3.15; Burton, A. J. $6.41; Burton, Richard $0.00; Byrne, Terrill $22.70; Birdwell, Henry $2.00; Bean, H. P. $2.00; Burton, Jeff $2.00; Byrne, W. J. $2.00; Brown, A. B. $2.00; Brown, J. H. $2.00; Barnett, Dillard $2.00; Buck, James col $2.00; Burris, James $2.00; Bell, George R. $7.05; Bell, Wm $2.00; Byrne, Allen col $2.00; Bowen, Porter $0.00; Bush, Scott $2.00.

Cooper, A. S. $25.95; Cale, John $4.55; Clements, A. $6._ _; Carter, Thaxton $1.9_; Collier, Alex $0.00; Clements, Pleasant $2.00; Clements, Charley $2.00; Clements, Leroy $2.00; Cannon, J. C. $2.00; Cale, Wm $2.00; Clements, Rose $2.00;

Duke, A. M. $2.00; Duese, Frank $2.00; Dismukes, Robt $2.00; Duke, Nancy $3.00; Duke, A. A. $22._ _; Dowell, J. M. $15._ _; Duke, Morgan $2.00; Duke, Robert $2.00; Dause, James $2.00; Duese, Sam $2.00; Daniels, Alex $2.00; Draper, James col. $2.00; Eller, J. H. $7._ _; Eller, Henderson $2.00; Eller, Susan $2.55;

Farley, Green $2.00; Ferrill, Payton $2.00; Ferrill, Sid $2.00; Ferrill, Fate $2.00; Ferrill, John col. $2.00; Ferrill, James $2.00; Fellers, Jase $2.00; Finn, Merida $2.00; Finn, David $2.00; Farley, Henry col. $2.00; Farley, Frank $2.00; Grissom, Mat $2.00; Givens, James $2.00; Gentry, W. M. $4.41; Gentry, John $2.55; Gipson, Joseph $2.00; Goodwin, J. L. $2.00; Grissom, Peyton $2.00; Grissom, ?U. M. $2.00;

Holliman, R. L. & others $0.65; Holliman, ?U. L. heirs $1.30; Hogan, Mary $4.41; Hargis, John $5.15; Holleman, G. R. $18.90; Holleman, Albert $2; Holleman, J. P. $2.00; Holleman, Bob $2; Holleman, George $2; Harris, Milton $2; Harris, Frank $2; Hall, Wm $2; Huff, George $2.00; Hardcastle, Son $2.00; Hardcastle, Wm $2.00; Holmes, Pres $2.00; Hutchison, Charley $2.00; Hardcastle, Lewis $2.00; Harress, James $2.00; Hardcastle, C. A. $?7.; Hogan, James $2.00; Horton, David col $2.00; Jones, Thomas $2.00;

Kent, Lon $2.3_; Keith, E. P. $2.00; Keith, Irskine $2.00; Kent, Thomas $2.00; Kidwell, Wesley $2.00; Kirkpatrick, Amos $2.00

Lee, T. J. $4.10; Kent, J. M. $34.15;

Lambert, Wm Bal [possibly "balance"] $11.38; Lambert, James $13.35; Lambert, Andy $2.00; Lambert, Thomas $2.00;

McKinley, T. C. Bal [possibly "balance"] $15.12; McKinley, J. D. $25.20; McKinley, G. W. $11.35; Manear, A. H. $12.10; McDonald heirs $25.20; McDonald, Alma $8.85; McDonald, Elizabeth hrs $15.15; Maxwell, W. H. $0.00; Montgomery, E. H. $2.00; McKinley, James $2.00; McCarter, Alfred $2.00; Mathews, Frank $2.00; Maxwell, Wm $2.00; Moore, Jas col $2.00; Moore, Scott col. $2.00; Morgan, Henry col. $2.00; McKinley, D. C. $12.60; Mitchell, Thos $2.00; Myres, Earl col. $2.00; Montgomery, L. H. $2.00; Myres, Newt col. $2.00; Maize, Andy $2.00; Manear, Mat $2.00;

Pharris, Susan & sister $6.3_; Pharris, A. W. $5.1_; Pharris, Elizabeth $6.3_; Pharris, Lafayette $2.00; Pippin, Henry $2.00; Philpot, Jim $2.00; Pate, McGuire, $2.00; Price, Alex $2.00; Price, John $2.00; Price, Sam $2.00; Pharris, Richard $2.00;

Reeves, Frank $2.00; Roberts, James $1.28; Rice, James ["James" marked through - mlj] $2; Rice [or Rees/Russ], Sam $2;

Sadler, H. F. $2.2_; Stanton, U. R. $3.8_; Stanton, Albert $12.6_; Smith, H. B. $75.9_; Smith, Wesley col $2.00; Spurlock, Melvin $2; Spurlock, Sid $2; Stanton, Henry col. $2; Smith, Henry Col. $2.00; Smith, Ed col. $2; Smith, Sid col $2; Stafford, Geo col. $2; Smith, Mike $2; Stockton, John 2; Smith, Gabe col. $2; Smith, James $2; Sadler, Jerry col $2; Smith, Fred col $2;

Trousdale, J. K. $12.75;

Veach, John $2; Vinson, Caleb $2; Vinson, Dave $2; Vantrease, John $2; Veach, Jeff $2;

Willaby J. L. $2.55; Wade, M. T. $3.80; Wade, L. C. $3.98; Wade, J. W. $8.30; Williamson, C. A. & J. M. $2.55; Williamson, J. M. $12.10; Wilkason, W. R.$3.80; Wade, Alex $2; Wheeler, Duggan $2; Whitefield, A. W. $2; Williamson, Andy col. $2; Williamson, Thos col $2; Williamson, Isham col $2.

Delinquent list of District No 5 Jackson County Line [As written - mlj].

Apple, Andy gone poll $2.00

Apple, James non resident 2 yrs $2.00

Bean, H. P. no such man $2.00

Burton, Jeff gone $2.00

Brown, J. H. gone $2.00, 3 yrs

Barnett, Dilliard gone $2.00

Buck, James gone 2 yrs $2.00

Bell G. R. gone $2.00, 2 yrs

Bell, N. M. gone $2.00, 2 yrs

Byrnes, Allen (col) no property $2.00 out the county over one yr

Bush, Scott, gone $2.00, 2 yr

Clements, Pleasant ?released $2.00

Clements, Charley no such $2.00

Clements Leroy no such man $2.00

Cannon, J. C. no property $2.00

Cale, W. M. ?released $2.00

Clements, Bose no such man $2.00

Duke A. M. Same as Maxwell Duke $2.00

DeNeise, Frank no such man $2.00

Dismuke, Robert non resident $2.00, 2 yr

Duke, Robert to Young as by_ _ _

Harly, Green gone $2.00, 2 yr

Ferrell, Fate no property $2.00

Ferrell, James no property $2.00

Fellers, Jase no such man $2.00

Fin, Merridy gone, $2.00

Farley, Frank gone $2.00

Givens, James [or Jones/Jonas] gone $2.00, 1 year

Gentry, W. M. could be _ M [This entry was marked through - mlj]

Gentry, John dont own land $2.00

Gipson, Joseph over age

Grissom N. M. same as [torn/fold, can't read - mlj]

Hagan [or Hogan], Mary no personal property

Hargis, John error should be John Harris $5.15

Holeman, J. C. no such man $2.00

Holemon, Bob same as R. L. Holeman $2.00

Harris, Milton no property $2.00

Harris, Frank gone $2.00

Huff, George no property $2.00

Hardcastle, Ben same as [can't read] $2.00

Hutchison, Charles gone

Hogan, James (col) gone $2.00

Horton, Dave col no such man $2.00

Jones, Thomas no property $2.00

Keith, E. P. no such man $2.00

Kinderell gone a preach of gospel $2.00

Kirkpatrick, Amos in Montana 2 years $2.00

Lambert, Andy ?released $2.00

McKinley, James gone $2.00

Maxwell, W. M. same as W. H. $2.00

Morgan, Henry no such man $2.00

McKinley D. C. dont own any land $12._0

Mitchell, Thomas over age $2.00

Montgomery, L. H. gone $2.00

Myres Newton col resident Putnam Co 2 yr $2.00

Maise, Andy gone 2 yr $2.00

Pippin, Henry no property $2.00

Price, Sam gone

Rice [No name] I know of no such man $2.00

Smith, Henry col gone 2 yr $2.00

Smith, E. D. no such man $2.00

Smith, Mike gone $2.00

Stockton, John same as John R. $2.00

Smith, Gabe over age gone col $2.00

Smith, James not entitle to pay in this co $2.00

Saddler, Jerry col gone 2 yr $2.00

Vinson, Caleb gone $2.00

Vinson, Dave under age $2.00

Veach, Jeff gone $2.00

Wade, Ellect paid W. E. Jones $2.00

Wheller, Duggin no property $2.00

Whitefield, A. M. no such man $2.00

Williamson, Andrew $2.00

Pate, McGuire no such man $2.00

Pharris, Richard gone 2 years $2.00

McDonald heirs no personal property $25.20

McDonald, Elizabeth no personal property $15.13

McKinley, T. C. ["no personal property" marked through], $15.13

TESTIMONY:

John H. Stafford, County Trustee. On Feby 15, 1889, I placed unpaid taxes for the year 1889 District 5 in hands of J. M. Lee for collection.

J. M. Lee, Constable 5th District 1888 and 9. Amount collected was paid over to J. H. Stafford May 6, 1889. Included were:

$40 school warrant payable to W. A. Hargis, $35 school warrant payable to R. J. Montgomery, $30 school warrant payable to Gord Lee, $9.56 county cert or school warrant payable to D. H. Armistead, J. P.

Ques: How much cash did you pay J. H. Stafford 6 May 1889.

Ans: I paid him $81 in cash. I paid it over at Mrs. Williams [M. A. C. Williams; operated a hotel in Gainesboro - mlj]. Mr. A. C. Ragland came up and spoke to me. I stepped back and John handed me the receipt Mr. Ragland spoke to me about a certain lady going to swear a bastard child to Mr. Stafford, said the papers were fixed up and that Mr. Stafford was in trouble. He asked me to speak to Stafford about it that the case was before Lewis K. Smith Esq. Stafford asked me to walk down to Smith's office. About that time Mr. Dawes called for me and I asked Mr. Ragland to walk down in my place.

Stafford complained of being sick and said he was in trouble. When I mentioned it to him he said he forgot his business. If he was drinking I don't know anything about it.

W. T. Dawes. J. M. Lee's character good, entitled to full faith and credit on his testimony.

D. H. Armstead age 49, live Granville, Jackson County, Tennessee, farmer. Under Tennessee School Law I am clerk of the Board of Directors of the 5th District.

/s/ D. H. Armstead

DEPOSITIONS June 28, 1890 [Testimony as to whether J. H. Stafford signed a paper - mlj]

J. M. Morgan, Gainesboro, Atty at law

M. B. Young

W. W. Draper age 30, Gainesboro, atty.

Lewis K. Smith, J. P.

A. J. Dudney, 38, Jackson County, farmer.

M. G. Butler, 42, Gainesboro, lawyer.

DEPOSITIONS:

L. K. Smith. Cullum Ragland and Plaintiff came to my office about May 6, 1889.

/s/ Lewis K. Smith

A. C. Ragland. Went with John Stafford to L. K. Smith's. There was a woman there while I was there the first time and she had a chap then with her and my understanding was she wanted to swear it to Ptff Stafford. I think it was May 1889.

/s/ A. C. Ragland

J. H. Stafford. I did see Mr. Ragland and we went to see L. K. Smith. I remember saying I had been sick and had forgotten my business. I meant that I had promised the woman some money and had forgotten to pay it - not that I had forgotten official business.

/s/ J. H. Stafford

J. M. Lee. I am charged with $785.22. I should have a credit for Richard Burton's taxes $6.78 paid to Stafford, Porter Bowen $2.00 to Stafford.

Paid to J. H. Stafford and charged to J. M. Lee: Alex Collier $2.00, W. M. Gentry $4.41, Road receipt G. W. McKinley 50 cents, J. M. Dowell 60 1/2 cents, G. R. Holleman 82 1/2 cents, Terrell Byrne 99 cents, James Roberts 15 cents.

/s/ J. M. Lee

EXCEPTIONS, cause of State of Tennessee for use of J. H. Stafford, Trustee vs J. M. Lee and Others:

The defendants W. B. Beck and William Watts, Administrators of the estate of J. M. Lee deceased except to C & M Report filed November 12, 1890.

Fails to allow full credit for receipt of $190.36; only allows $109.36.

Fails to give credit for due bill of $42.50 executed by J. H. Stafford.

Fails to give for road tax, Terrell Burn.

Fails to give credit for James Montgomery and Scott Montgomery, which were charged in the names of James Moore & Scott Moore.

Fails to give credit for A. S. Cooper, J. M. Williamson, H. Ellis, Thomas Lambert.

DECREE: State to recover of W. B. Beck and W. R. Watts, Administrators of Estate of J. M. Lee, deceased, Constable 5th District and T. J. Lee, C. W. Sadler, U. F. Sadler and H. F. Sadler securities $144.41 and $11.05 interest = $156.46 + 12 1/2% damages of $19.55 being $176.01 in the aggregate.

AGREEMENT TO DISMISS: J. H. Stafford to pay all costs. E. C. Fowler, M. M. Smith & Wm Lowery agree to pay taxes accrued in Circuit Court and $150 to J. H. Stafford.

/s/ John H. Stafford

/s/ E. C. Fowler, M. M. Smith, W. C. Lowery by E. C. Fowler

INJUNCTION: John H. Stafford this day filed against M. M. Smith, E. C. Fowler and W. C. Lowery, charging he is owner in fee simple of tract on Brimstone Creek in 13th District of Jackson County... begin at a ridge south of Brimstone Creek... Dry Branch of Brimstone Creek... defendants have gone on land... cut and removed logs.

CROSS-BILL OF COMPLAINT of M. M. Smith, E. C. Fowler and W. C. Lowery against J. H. Stafford that they own... On 14 May 1830, Entry Taker Office of Jackson County, Tennessee, Special Entry No. 1861 and 16 November 1838 was granted No. 6491 to Joseph Moss who [Blank date] conveyed to Alfred G. Moore and held for many years and died [blank] 1865 leaving Thomas D. Moore and Samuel A. Moore to whom land descended. 27 July 1885 Samuel A. Moore conveyed his undivided interest to P. H. Spear and his heirs. 17 December 1888 said P. H. Spears and wife Sarah E. Spears conveyed said undivided half to M. M. Smith, E. C. Fowler and W. C. Lowery.

On 5 November 1888 P. L. Wyatt, Jacob Arnold and Thomas D. Moore by deed conveyed the undivided half of said land which descended to Thomas D. Moore to M. M. Smith, E. C. Fowler and W. C. Lowery.

Said land was attempted to be assessed in the name of A. G. Moore heirs.

4 October 1887 the State of Tennessee and the County of Jackson filed against Newton Moore and his sister whose name was alleged to be unknown... alleged a resident of the State of Missouri... land in District 13 bounded north, south and west by the lands of the heirs of Mounce Gore, deceased, east by land now owned by M. G. Giddings... 75 acres and duly assessed for the year 1886... taxes $4.71. On 6 July 1888 land was condemned to be sold and 3 November 1888 sold to John H. Stafford for taxes and penalties of $27.00.

Thomas D. Moore and P. H. Spears of the State of Kansas and John H. Stafford entered unlawfully under a tax title. Orators say they tendered to John H. Stafford the full amount of his bid of $28.00 which he refused to accept.

POWER OF ATTORNEY: We M. F. Green and W. C. Johnson of Clay County, Tennessee appoint M. M. Smith of the same residence our attorney in fact... suit E. C. Fowler, W. C. Lowery & M. M. Smith against John H. Stafford filed in Jackson County, Tennessee

/s/s/ M. F. Green, /s/s/ W. C. Johnson [Acknowledged in Clay Co., TN - mlj].

SETTLEMENT 11 March 1915. Sale bill filed 1 April 1913, Administrator's Settlement Book D, page 439, $232.10. Also note on Felin [sic] Smith, no good, $35.00; note on G. T. Stafford, claims to have paid, $225.

RECEIPT: J. Mack Dudney for keeping and waiting on A. C. Stafford 12 days in his last illness until his death, feeding the stock, etc.

Dr. C. E. Reeves made affidavit was worth $10.00 per day.

Dr. E. W. Mabry, M. D. made affidavit was worth $15 per day.

Account allowed at $150.00 total.

INVENTORY & SALE OF PERSONAL PROPERTY [about 1 April 1913]:

Mare, J. J. Stafford, $130.

Buggy, A. J. Skimmerhorn, $36.50

Buggy, W. H. McCoin, $4.75

Man's saddle, W. B. Stafford, $10.50

Bed, Heryette [sic] Stafford, $5.00

Blanket, Lizzie Stafford, $1.00

Suitcases, Annie Lee Stafford, $1.00

Churn, Minnie Stafford, $.80

Plow stock, J. J. Stafford, $.25

Corn at J. M. Dudney's sold to Bill Williams

Lots of Corn sold to R. S. Dennis and Bill Harper

Notes on James Netherton and on W. M. and A. J. Skimmerhorn

DECLARATION IN EJECTMENT: Plaintiff sues to recover from James J. Buckhanan land on Roaring River in Jackson County, Dist 1... road leading from William Stafford to William Gray's old place... 126 acres more or less, which plaintiff was in possession and claiming in fee 1st January 1870... 15 January 1875 James K. Buckhanan entered upon...

PETITION: Came Winfield S. Burris and Eliza Jane Johnson and her husband Andrew Johnson... are the real parties interested in the action against J. K. Buchanan, he being their tenant... therefore ordered by the court that said Winfield S. Burris and Eliza Jane Johnson and husband Andrew Johnson be substituted as defendants.

COMPROMISE AGREEMENT: Suit dismissed and defendants recover of complainant the fee simple and absolute title. Defendants recover costs including cost of survey.

COMPLAINANT states Albert Rawley committed unlawful entry, dwelling house &c in 1st District, Jackson County on Morrison's Creek being the house lately occupied by Amos Pryor his tenant... about 20 acres of the southeast part of land purchased by J. W. Stafford of J. M. Gipson in his life time.

DEPOSITION 20 October 1914: R. V. Brooks age 71, live Smith County, TN. L. P. Wilson owes me $150.50, note dated 1 January 1912, security J. C. Long.

BILL OF COMPLAINT of James W. Stafford and John H. Stafford against L. P. Wilson and wife Alice Wilson; J. C. Long; R. B. Draper all of Jackson Co. and R. V. Brooks of Smith Co. L. P. Wilson became indebted, signed a mortgage deed to J. W. Stafford with R. B Draper as security. Seeks to foreclose on land in 2nd District bounded north by R. R. Sloan, east by Dock Craighead and Bill Forkum, south by George Sloan, west by Luther Sloan being 40 acres more or less.

AFFIDAVIT of J. T. Stafford [Cross-Bill of Complaint - mlj] against Martha Stafford. Plaintiff J. T. Stafford has had subpoena issued for Daniel Poston... believes he is lying out and evading process of the law. 18 Jan 1883. J. T. [his X] Stafford

AFFIDAVIT of Martha. Stafford. Lou Carlisle is a material witness for her... is now sick and confined to her room... has been since last July... can prove J. T. Stafford has been guilty of adultery with one Nancy Jourman... woman of lewd and bad charger. She can have her witness or deposition by next term, asks continuance. Jany 18, 1883.

Martha [her X] Stafford

POWER OF ATTORNEY to M. G. Butler. You are empowered to sign my name as security on bond, J. T. Stafford against Martha Stafford. 28 September 1882.

Rhody [her X] Stafford

BILL OF COMPLAINT of J. T. Stafford. Married in Jackson County, Tennessee [blank] April 1878. Alleges adultery on diverse occasions with divers individuals. August 1882 she was guilty of adultery with one Daniel Poston.

Complaint is not made out of levity or collusion with defendant. 29 September 1892.

J. T. [his X] Stafford

REQUEST TO DISMISS: Complainant and Defendant have gotten together [No date - mlj].

BILL OF COMPLAINT of Martha Stafford. Married in Jackson Co. 1878... he has forgotten the duties of a husband, failed to provide. She is now in an advanced state of pregnancy... left her destitute. Owns land 65-70 acres. [Note: John P. Murray's writing; could decipher but little - mlj].

Complaint is not made out of levity or collusion with defendant. Owing to poverty, cannot bear expense...

Martha [her X] Stafford

BILL OF COMPLAINT of Mary Stafford. Married [blank] July 1893 in Jackson County. Archibald is guilty of cruel and inhumane treatment... unsafe to cohabit... called her names such as nasty stinking old hussy, Nasty old strumpet, accused of adultery without foundation. 17 March 1897 he forcibly turned her out of the house... forced to go to a neighbor's house after dark and get a boy to carry her to her son's house...

[Lists personal property - mlj]... land in 1st District of Jackson County, Tennessee.

Turned her out bare headed... has had to borrow clothes.

Above is true, not able to bear expense of lawsuit, asks divorce, suitable support and that she be granted the Paupers oath... March 18, 1897.

Mary [her X] Stafford

CAUSE HEARD 23 September 1899. Defendant willfully deserted complainant without reasonable cause... divorce from bed and board. Title to all the property in bill be divested in Complainant... hogs, cow, chickens, victuals... Defendant A. C. Stafford will pay all costs.

1880 Sistler's printed index of Jackson County. P. 184: STAFFORD, Lee W. 51, Mary 25, Emaline 10, Adaline 8, Polly A. 5, Wm H. 3, Nannie B. 2 - mlj].

BILL OF COMPLAINT of Mary Stafford against Leroy Stafford, both of Jackson County, Tennessee. Married [blank] 18[blank], together until August 1889... whipped, abused, knocked her down... unsafe to live with him. Parents of following children to wit R. A. Stafford 17, Mary A. Stafford 15, Minnie Bell Stafford age 1_[smear], W. H. Stafford 12, Walter B. Stafford 8, D_____ [smear] Stafford 6, asks custody. [Lists personal property, asks it be attached]. 1st Monday in July 1889.

BILL OF COMPLAINT of Mary Stafford against Leroy W. Stafford. Married in Jackson County 25 years ago where they resided since. Following children the issue of their marriage to wit Adaline 20, Polly Ann 18, Wm 16, Bedford 11 and Mc age 9. Own land bounded by P. N. Dudney, Martha Netherton, J. S. Burris, George Harp and others [also personal property].

Defendant recently left home and fails and refuses to provide, whipped her most brutal, threatened her life... made indecent proposals to their daughter Polly Ann.

Makes oath not made out of levity or collusion... due to poverty she cannot bear expense of suit. 2 March 1893.

Mary [her X] Stafford

ANSWER of Leroy Stafford to Bill of Complaint of Mary Stafford filed April 28, 1894... marriage correctly set out. Denies that about four years ago he was so cruel she was forced to withdraw... she withdrew on her own account and abused your Respondent and on that occasion... visited her brother Jim Pryor to make an attack on Respondent with a ____ shovel and very severely injured him... he left to save his own life.

Denies he went to the bed of his own daughter and made indecent proposals...

Charges that complainant has frequently made arrangements for said daughter to meet men in privacy and submit herself to divers lewd acts with them... when he left home she drove him off with a drawn pistol and said if he ever came back she would shoot him.

Denies he threatened if she files a bill he would waylay her on the road and shoot her...

Denies she is the proper person to have custody... she was guilty of adultery with one Noah Chaffin first of January 1894.

Makes oath above is true, not made out of levity or collusion.

Leroy [his X] Stafford

INJUNCTION & ATTACHMENT: Whereas Mary Stafford filed this day against Leroy Stafford who were married 1869 in Jackson County... following property in 1st District...

BILL OF COMPLAINT of Mary Jane Stafford against W. W. Stafford. Married in Jackson County 12 November 1875, lived happily until some weeks ago he abandoned Oratrix... said he would never return or provide... at the time they intermarried he was a man of sober and temperate habits... since intermarried has contracted habitual drunkenness. [Lists personal property, asks it be attached]... marriage bonds dissolved.

Makes oath is true, not made out of levity or collusion... owing to poverty, cannot bear expense.

Mary Jane [her X] Stafford

BOND: We, W. W. Stafford as principal, W. H. Young, A. C. Stafford and James Stafford, security to Mary Jane Stafford... sum of $100... to release bay mule attached as the property of W. W. Stafford value $60 pending divorce action. 31 May 1876.

BILL OF COMPLAINT of Susan Stafford against Henry Stafford. Married in Jackson County 12 September 1875. Henry Stafford guilty of lewd acts with Mary Jane Taylor on Saturday, Sunday and Sunday night the 23 and 24 of October at one Milley Boles... left home Saturday evening and remained in company with said Mary Jane Taylor a woman of lewd and notoriously bad character... house of Miley [sic] Boles one of ill fame.

He has failed to provide... cursed and abused... They have as issue of their marriage a little girl child named Mary Jane about five years, a boy Merlin about 2... he is unfit for custody. [Lists personal property, asks it be attached]... asks divorce, custody of children.

Not made out of levity or collusion... due to poverty she is unable to bear expense. 25 Oct 1880.

[Note: This bill of complaint was in the Mary Jane Stafford vs Leroy Stafford file - mlj].

ORDER TO ATTACH personal property... including 15 acres of corn on the land of John Dock Stafford... land 25 acres in Dist. 1 in Jackson County between Talley's Hollow and Aaron's Branch bounded by Asberry Loftis and John Dock Stafford's land and others.

BILL OF COMPLAINT of Susan Stafford against W. H. Stafford. Married in Jackson County September 1875, two children Mary Stafford age 4 and Marlin Stafford age 1. Lived happily until 7 or 8 weeks ago defendant commenced leaving home at night... neglecting... adultery with Mary Taylor.

[Note: This is part of the case that began at the end of Reel #114 and continues at the beginning of this reel - mlj].

DEPOSITIONS October 16-17, 1912:

J. J. Stafford age 43, live 11th District of Jackson County. Am a grandson of Rhoda Stafford.

/s/ J. J. Stafford

Martha Burris age 47, live near Gainesboro, about 3 miles. Knew Rhoda. Last 5 or 6 months before her death she lived at Joe Stafford's, was bedfast part of the time. Would be worth $200-$300 to take care of her.

/s/ Martha Burris

Perry Jackson age 21, live 9th District, Jackson County. Acquainted with K. J. Stafford, Rollin B. Stafford, T. G. Stafford, Maggie Cofee [sic] Adeline Stafford. Rhoda said she wanted to give money to her grandchildren before she died.

Perry [his X] Jackson

J. J. Stafford [Recalled].

Ques: Say if you got any of the money she got from Wm Lynn when she sold him the Joe Stafford note.

Ans: She had about $40 or $50 in her pocket book - told me to get it - that she had reserved it for her burial expense. She sent by me to Gainesboro to buy her burial clothes. She came [to my house] the last of October or first of November, died February or March.

Ques: State what you know about Rhoda loaning money to Monroe Mabry.

Ans: She loaned it to Uncle Jim Anderson. Mabry wrote the note. She sold the note to get money to pay Uncle Babe's children.

Ques: State whether you paid off the notes she sold to Will Lynn...

Ans: I paid them to Billie Lynn son of Wm Lynn. Billie Lynn then lived in Clay Co. but now in Kentucky.

/s/ J. J. Stafford

Mrs. Mary Stafford. Will soon be 76, live on Jennings Creek near Whitleyville. I am J. J. Stafford's mother. Mrs. Rhoda Stafford was my mother-in-law.

Mary [her X] Stafford

W. F. Sadler age 39, live Gainesboro, occupation merchant since February 1891. Knew Rhoda and her sons A. C. Stafford and Joel T. known as Babe Stafford.

Ques: Are you acquainted with K. J. Stafford, T. G. Stafford, Roland B. Stafford, Robert Stafford, Maggie Stafford now Maggie Coffee.

Ans: For several years. Understand they are grand children of Rhoda Stafford.

/s/ W. F. Sadler

S. M. Tinsley. Am administrator ad litem of Rhoda Stafford. She was the mother of A. C. and Joel T. Stafford. Joel T. was dead and children surviving him were K. J., T. G., Roland B. and Robert Stafford and Maggie Coffee who intermarried with Robert Coffee.

A. C. Stafford age 66, live Gainesboro, am father of defendant and uncle to complainant.

/s/ A. C. Stafford

DEPOSITIONS May 29, 1911:

Martha Anderson age 84. Knew Rhoda Stafford about all her life. She had been here rite [sic] smart off and on. After she left she lived two or three weeks maybe longer. She went to Joe Stafford's.

Martha [her X] Anderson

Minie [sic] Stafford. I am J. J. Stafford's wife. Mrs. Rhoda Stafford lived with me and my husband from the 1st of October or last of September the year before she died until her death 14 March following.

Ques: What did she do with money from Wm Lynn.

Ans: Give J. J. Stafford's mother $50.

Gave Harve Stafford $75 also $2.50

Martha Harris children $10 each.

K. Stafford. He came in and said he owed Ed Ragland $3 or $4, don't know how much she gave him.

Adline Stafford $5. She was about to leave and Rhoda asked when she was coming back and she said she didn't know, and Rhoda gave her $5 which was the smallest she had in her pocketbook.

Bob Coffy's wife $2 or $3.

Maggie Coffee $5.

Sent by Bob to Maggie $20.

Martha Anderson $18 to be divided between her and Willie Anderson and his wife Avo Anderson.

Joe my husband $2.50.

My daughter Mary 50 Cents for Christmas and Lizzie 25 Cents.

She had $300 when she lived there - kept it in her trunk in her room, kept it locked most of the time.

She gave Joe a note on the land for $250 and a note for $13 on Willie Anderson for his troubles.

She gave a note to me for $18 to divide with my daughter Mary she said she wanted her to have a saddle. Pop Stafford heretofore spoken of is Mary Stafford...

Ques: Do you know Florence Anderson and Mary Ann Brown.

Ans: Yes they visited Mrs. Stafford during her last sickness.

Minnie [her X] Stafford

J. J. Stafford. The coffin and handles were about $30. /s/ J. J. Stafford

Jeff Reeves, merchant. J. J. Stafford got the oak finish coffin. It was $25.

/s/ Jeff Reeves

Will F. Maberry age 36, live Roaring River.

Ques: Did Rhoda Stafford transfer any of her land notes.

Ans: Yes all three. One to Harve Stafford, one to my wife Anga, one to Babe Stafford's children.

She had been living with me from the sale of the land somewhere one-two years. She was somewhere in the neighborhood of 79 at her death.

/s/ W. F. Maberry

R. B. Stafford, will be 30 in August, live near Gainesboro in the Haile hollow. Rhoda Stafford was my grandmother. The night after she died I was at Joe Stafford's where she died. Joe's wife whispered something to him, and Joe whispered to Mary and they got the trunk and took it in the back room. Minnie and Joe and Mary and T. G. was there.

/s/ R. B. Stafford

T. G. Stafford, age 28. [Basically same deposition as R. B. Stafford - mlj]... Minnie and Joe and Mary and B. was there.

Bob Coffee age 33, live 1st District. My wife is a grand daughter of Rhoda Stafford. Rhoda was at Martha Anderson's... present were Mrs. Anderson and her daughter Fannie.

Bob [his X] Coffee

Mrs. Mary Maberry age 24, live 9th District. I am J. J. Stafford's daughter. I was living with J. J. Stafford at Rhoda's death. I was there when she died. She died between 7 & 8 o'clock evening 14th of March. Matt Keith, Ann Brown and Florence and Dora Anderson, think J. J. Stafford was in the house.

I have two sisters the eldest something like 12 years old then, she was there.

Ques: Who dressed her.

Ans: Me and Florence Anderson and Ann Brown. Daisy Kinnard held the light. She had two new counterpanes in her trunk for that purpose.

/s/ M. J. Mayberry

John Kinard age 56, live 6th District. Stopped by Joe Staffords. Rhoda Stafford had just died. I stayed the night. I don't think they'd laid her out yet.

/s/ Jon Canrd [sic]

Daisy Kainnard. Will be 26 in June. I live with my father in the 6th District. I was at Joe Stafford's the night Rhoda Stafford died, helped to dress her.

/s/ Daisy Cinard

Mrs. Carrie Proctor. Will be 22 years old the 18th of June, live 6th District. Was at Joe Stafford's when Mrs. Rhoda Stafford died.

Ques: How old was you when your grandmother Rhoda Stafford died.

Ans: I was something like 13.

/s/ Carrie Proctor

John Lynn age 55, live 9th District, knew Rhoda and the land she sold Joe Stafford. I bought it from J. J. Stafford four years ago. Think I gave $1000.

/s/ John W. Lynn

PETITION of A. M. McCoin. His brother E. M. McCoin brought suit on a note executed by J. W. Lynn to T. G. Stafford, date 5 August 1911 for $1300. Note has been transferred to Petitioner.

DEPOSITIONS [Questioning was to determine whether the money bequeathed to individuals was distributed by Rhoda Stafford before her death. The court determined it was - mlj]:

T. G. Stafford. Rhoda Stafford was my grand mother. She gave Roland B. Stafford $15 in August before she died in March. He went to Mississippi on the money she gave him.

Ques: You spoke of your brother Roland B. Stafford not being here to give his deposition now, is the reason he is not here he was caught stealing corn and indicted for it and ran off before he was arrested and has never been back.

Ans: They said he was.

T. G. [his X] Stafford

Robert Stafford. I was acquainted with Rhoda Stafford in her lifetime. She was my granny.

Robert L. [his X] Stafford

Martha Harris.

Ques: Are you the mother of Adline Stafford.

Ans: Yes Sir. She is in very bad health and has been five or eight years. She can walk by someone holding her up. The Dr. said if her health didn't get better she would finally loose [sic] her mind. She went to see her grandmother a few times... just not able. Has not been to the store to buy anything since she was eleven.

Martha [her X] Harris.

K. J. Stafford. I was acquainted with Rhoda Stafford in her life time. She was my grandmother.

K. J. [his X] Stafford

Bob Coffee age 33, farmer. I married Maggie Stafford.

Ques: Was she a daughter of T. J. Stafford and a sister to K. J. Stafford and his other brother and sisters and a grand daughter of Rhoda Stafford.

Ans: Yes sir.

Robert [his X] Coffee

Will Lynn. Live on Spring creek in this county, am age 69. Joe Stafford is my soning [sic] law. I paid J. J. Stafford's notes that he had given her [Rhoda Stafford] for land. I paid her $280. Joe paid some $10 or $12 and the balance was paid by note, some sixty or sixty five dollars which I executed to Rhoda Stafford.

William [his X] Lynn

William Anderson. Live 9th District, am age 38. I owed $13 to Rhoda Stafford at her death, since paid it to J. J. Stafford.

DEPOSITION 28 December 1911:

Monroe Maberry, live 9th District, age 40. I borrowed $18 or $20 from Rhoda Stafford for J. W. Anderson and he signed the note and I went his security. J. W. Anderson said it was paid. He is dead.

/s/ Monroe Mabery

REQUEST TO REVIVE: In the cause of Lee Sadler vs John M. Burris, Plaintiff suggested the death of John M. Burris who died intestate and asked that this case be revived against William Denis, Administrator of John M. Burris, deceased and his heirs to wit Cheatham Clark, Bessie Clark, John Clark, B. Smith, Cheatham Burris, Sallie Burris, and his widow Rhoda Burris.

DEPOSITIONS 22 January 1867 in the cause of William Stafford, Elizabeth Stafford and Elijah Burris vs Elizabeth Burris, W. S. Burris, Eliza J. Burris and James R. Burris:

Absolum Pharris age 45. I have known Wm Stafford, Elizabeth Stafford and Elijah Burris about 35 years. Knew John M. Burris about 28 years before his death. John M. was the father of Elijah Burris and Elizabeth Stafford and father in law of William Stafford.

I have known the land where Elijah Burris and William Stafford live. Elijah Burris has moved twice to keep out of the water but still lived on the same tract all the time. They lived on the same tracts from when I first knew them up to this time.

In the fall of 1852 I was at John M. Burris' and he pointed out to me where he had marked out land for Elijah Burris and William Stafford. The road [leading from Gray's] was the dividing line. Elijah Burris' land was the lower end on the north side of Roaring River. Suppose there is something like 140 acres in Stafford's and 125 or 130 of Elijah Burris.

In 1853 John M. Burris asked me who was going to take in a list of taxable property and I told him I thought my brother James Pharris was. After my brother's death I found strips of paper in John M. Burris' hand writing directing how each of J. M. Burris' older children should be taxed or the amount each one had to pay...

Ques: State if you had a conversation with John M. Burris in March 1861 before he died next winter.

Ans: He came to my house about a judgment he had against William Smith for $5 or $6, said Smith was going to run away. I told him he was just going to Nashville... his debt was staid [sic; stayed]. Burris said he was going to Gray's mill... that Calep Lemings was going to keep [run/operate] the mill and if he didn't go back he'd steal all his corn.

July or August of the year he died, I saw him next to Toliver Kirkpatrick's store... he must have been 75 years old, maybe older... My opinion is that his mind was very frail and at that time I did not think he was capable of transacting business.

Ques: State if you saw John M. Burris after October 5 1861 and in his last sickness...

Ans: I saw him a few weeks before he died... said he was very low...

Ques: State if you were well acquainted with John M. Burris from your earliest recollection... State the names of his children from his first marriage and from his second marriage.

Ans: His children by his first marriage are Elijah, Betsy now Betsy Stafford, and William by his first marriage. The children by his second marriage are Winfield S. and Eliza Jane. Five in all. I don't know the date of the second marriage but think it was 1856.

The lands in litigation are in Dist. 1 on the north side of Roaring River and the land of J. M. Burris lies on the south side. I expect all together worth $7,000 or $8,000.

I know Elizabeth Burris the widow of John M. I have known her since they married about 1856. I think she is a woman of very fine since [sic; sense] - a sharp shrewd woman. I would say she was about 43 or 44 at the time they married... am just guessing. I suppose she is the mother of Winfield S. and Eliza Jane Burris. That is my understanding.

I was acquainted with him 28 or 29 years he was a Singular kind of man - he was a man pretty much to himself. He was a man that would not talk a great deal.

/s/ Absolum Pharris

Samuel Johnson age 56. I was intimately acquainted with John M. Burris... knew him at least 30 years. J. M. Burris came to my house a short time before he disposed of his lands... asked advice. I advised him to provide for the raising and education of his younger children, make them equal to his older ones and to provide a support for his widow during her lifetime. I told him he should make a will... married twice... about 75. While there he got sick and laid down on some shavings. I got him to the house and he laid on a pallet. I asked him to stay the night but he refused... I never saw him but once after that and that was on his death bed. He died a few minutes after I got there.

Ques: Say if you ever heard John M. Burris say anything about complainants Stafford and Burris paying taxes.

Ans: I heard John M. Burris say he was going to have William Stafford and Elijah Burris and William Burris' lines run out, that they must pay taxes.

Elizabeth was the widow of John M., deceased. I would think Burris was 70 or upward when they married. She said she was 42. She has two children by her marriage with Burris their names are Winfield S. and Eliza Jane.

/s/ Samuel Johnson

R. C. Kirkpatrick age 40. Acquainted with John M. Burris 25 years. Think he died fall or winter 1861. A short time before he died he fell down in my counting room. He seemed to be powerful sick. After he got better he told me he had come to make a settlement. I judged he was 75 or 80 at the time of his death... don't know his age. I would value his land at $12 per acre which would make it $7680 if there is 640 acres.

Mrs. Burris his widow says he died 26 Decr 1861.

/s/ R. C. Kirkpatrick

Uriah Stafford age 66. I expect William Stafford has lived about 35 years on the tract where he now lives. Elijah Burris has lived on his ever since 1830 I think he built in that Spring. I came there about 1831 to live with William Stafford and croped [sic; cropped] with him 12 or 14 years. We croped [sic] together and I got one-third of the crop. The year I lived at Allen Lynn's he rented a portion to Nicholas Hail and Andrew Dudney. I think there was 400 acres including the Wm Stafford and Elijah Burris tract.

I am cousin to Uriah Stafford.

Uriah [his X] Stafford

W. R. Kinner. I knew him [John M. Burris] 35 years. I was the family Physician of John M. Burris and have been since or 5 years after I came here and I came here in 1827. I don't know his age but he was quite an old man. He was an old man in 1827.

He said he had treated his first children with injustice and particularly Bill - He said he had turned Bill off. I told him it was not to [sic] late and he said it was too late that he had the matters fixed up and he was not going to pester it that he was too near wore out.

William Burris, Elizabeth Stafford and Elijah Burris are the names of his first children and he had two by his last wife. I don't know their names. Elizabeth Burris is the widow and the mother of the last.

He did not call a Physician very often it was not a custom to take much medicines. It was a disease of his lungs and liver that he died with.

/s/ W. R. Kinner

Toliver Kirkpatrick age 50. Knew John M. Burris since 1834, moved to within one-half mile of his house in 1834 and lived within one-half mile to his death. I never was well acquainted until I moved here in 1854, suppose he was between 70 and 80 when he died. He showed me how he had divided his lands and in my opinion he had given his son William as much as he had given both his other children.

In the winter of 1856 after he married the last time he and his wife came to my house... said William Burris' family had stole his knife and forks... on another occasion at a log rolling at his son Elijah Burris' he said someone had put a hog head in his spring and that he'd like to know who it was that he'd make them suffer.

Ques: State... whether he was sound or unsound mind 5 October 1861.

Ans: My opinion is that he was not. I did regard him of unsound mind during all the time from 1856 until his death... as he advanced in ages... became worse.

Ques: State the names of John M. Burris' children by his first and last marriage.

Ans: Elijah Burris, William Burris and Betsy Stafford are children by his first marriage. Winfield and Eliza Jane by his second. Believe his widow Elizabeth had a great deal of influence on him. They married about the last of the year 1855. I suppose he was 75 or 76.

There was some difficulty between John M. Burris and his children before his last marriage... increased after his last marriage... a fight between William Burris' wife and the old man's wife about which there was a lawsuit and afterwards John M. Burris lawed William Burris off the land.

There was a falling out of his older children and immediate neighbors after John M. married. He was mad at all his older children and Absolum Pharris and Nathan Pharris and myself.

/s/ Toliver Kirkpatrick

B. B. Washburn. I am an attorney. With partner Denton, were attorneys for John M. Burris in ejectment suit against his son William. William Stafford and William Burris both claimed their land by gift from John M. Burris and Stafford claims under the statute of distribution as an heir of John M. Burris, his wife being a daughter. John M. Burris at the time he died... about 80 years old. John M. Burris died as I have been informed 26 December 1861.

/s/ B. B. Washburn

Thomas Smith age 64. Acquainted with John M. Burris thirty odd years, he was somewhere in Seventy pretty close to eighty when he died in 1861. He said he sold his sheep to William Burris after his first wife's death... after he married said he must have six or eight or twelve back... that he could raise a flock.

Thomas [his X] Smith

Wm T. Buris [sic] age 23. Elijah Burris is my father. Elizabeth Stafford is my father's sister and Wm Stafford is her husband. John M. Burris was my grand father and Elizabeth Burris was his wife and now his widow. W. S. Burris is my uncle. Eliza Jane Burris is my aunt and the children of William Burris are my cousins. I was often with John M. Burris the last four-five years of his life. I lived about one-half mile from him.

Ques: Say if he called from his house to yours... loud enough to hear who he was calling.

Ans: He has called my brothers Sam and John and frequently called my father...

I live at my father Elijah Burris.

William T. [his X] Burris

EXCEPTIONS: Defendants except to the foregoing deposition of Thomas Burris, because he stated positively in answer to a plain question by defendants that "John M. Burris said if his father Elijah Burris did not sign a paper agreeing to pay rents he would put him off of the land where he lived and if he would sign said paper he would not put him off." This was written down by the commissioner and plainly read over to the witness and assented to by him as correct, and upon further examination ?for [or on] the same point said witness did not recollect having made said statement, said if he did make it he was mistaken _____ or at the instance of the atty for the cplts the witness has his deposition changed before he signed it and defendants except to it because complainants questions are generally leading and irrelevant and they therefore except to it generally. /s/ Cox, Murray, DeWitt & Morgan [Verbatim - mlj].

DEPOSITIONS 13 May 1867.

Samuel Burris age 29. I was passing the road with grandfather John M. Burris... and he pointed out the property of Elijah Burris, William Stafford and William Burris.

Ques: Did you then know where your father Elijah Burris, William Stafford and your uncle William Burris then lived....

Ans: They each lived on the respective tracts pointed out by him....

I went to Missouri and Arkansas in 1858 and returned about 17 September 1861.

Ques: About the time your grand father would call you and your brothers September to December 1861 and you went, what would he say.

Ans: I did not hear him call John at that time for he was in the army. When I went he would say he hadn't called.

Uncle William Burris went off of the land when I came back from Missouri... I suppose grand father was in possession of that part of the land at his death.

I live in the house with my father. I am a single man and have never been married.

/s/ Samuel Burris

Ellis Carlisle. In 1856 or 1857 John M. Burris took me on the land and I helped stick up some stakes in the line between William Burris and William Stafford. He said he and Mr. Morgan had made a line and he was not satisfied and we staked it off at a different place.

May 1858 he asked me to help cut a tree. I took the axe and started chopping. He lay down and started moaning and groaning... said he had pleuresy [sic] and wished he had some camphor. I went to the house and got some camphor. He put it to his mouth and said it was not camphor that it was some of John Carlisle's damned No. 6 [and I wish I knew what No. 6 was - mlj].

Ques: Say if you married a daughter of the complainant Elijah Burris, does Elijah Burris live on the land John M. Burris conveyed to James R. Burris, Elijah's youngest son in 1861.

Ans: I did marry a daughter of complainant Elijah Burris and Elijah Burris does live on the land that John M. Burris conveyed to James R. Burris, Elijah's son.

Ques: Do you think John M. Burris of sound mind in 1861.

Ans: I do not.

He was a man of temperate habits. I don't know about medicine.

Ellis [his X] Carlisle

John M. Burris age 28.

Ques: State how long you knew your grand father [John M. Burris] before his death...

Ans: I knew him from my earliest recollection. I lived one-half to three-fourth miles... from the best information I have he was 78 or 79 years old when he died. I was with him every 2 or 3 days from 1856 up to about May 1861. I lived with him part of the year 1858 or 1859.

I was with my grand father and his second wife think on new years day after they married. Something was said about deer hunting and his wife said he was to [sic] old... he said he was not that he was suple [sic] as a deer... could run over the hills like a Buck.

About two weeks before I went in the army he called me... I went over and asked what he wanted... he said nothing... said he didn't call me. I left here on the 14 day of May 1861 to go into the army. The last I saw him I think was the last of June first of July 1861. I understand he died in Dec 1861... feeble... dont think of sound mind.

I know the land where Elijah Burris and Wm Stafford live... are still living. I suppose the land where my father now lives was willed to my youngest brother and my father still lives on it...

Ques: Are you the son of Elijah Burris one of the complainants.

Ans: I am.

Ques: Did you rent land from your grand father a short time before the war.

Ans: I did... he made contracts...

/s/ John M. Burris

John W. Stafford age 27. I knew John M. Burris in his lifetime... acquainted with the land. Elijah Burris had no land other than what he lived on and he got that from his father John M. Burris.

William Stafford had 50 acres besides the tract he lived on. He got the tract he lived on by John M. Burris giving it to him.

I knew him ever since I knew any person. He was my grand father. I lived within three-fourths - one mile of him. Mother had some guineas that had just hatched. He came to our house in June 1856 and said to my mother "Bettie how many white guineas have you got". She said four. He sat down, doubled up his arms about his breast and said "Bettie how many white guineas have you got"... kept asking the same question...

I think he was 78 or 79 when he died... very frail and weakley [sic]... I dont think he was of sound mind from 1855 to his death.

His second wife is still living... had great influence [over him - mlj]. She told John M. Burris that if he did not put Wm Burris off the land that she would leave, that one of them had to leave and John M. Burris did put William off the land.

About the first of October or last of November 1861 I was coming to Gainesboro... I overtook him, says you have made your will have you Grand pap and we walked 8 or 10 steps before he spoke when he said yes I made my will just to please my old woman...

I am the son and only child of complainants Wm and Elizabeth Stafford. My mother is a daughter and heir at law of John M. Burris deceased. My father and mother are both far advance in years. They first moved on it [land where they live] in 1826. I was not then born. The old man told me he had given it to him in 1826...

I am 27 years old. I was born the 21st day of February 1840.

He told me at his house before his last marriage that he had given the place where my father lives to him and that he had given Elijah a good home and that he had given William a good home and that he wanted to see how well they would do. Uncle Wm Burris' wife and daughter Mary and his son John was present at the time.

Ques: You say the old man was no stock raiser. Is it not the fact he raised some verry [sic] fine horses.

Ans: There was some very fine horses raised there but my old grand mother raised them.

Ques: When did your old grand mother die...

Ans: I think she died in 1853. My grandfather remained a widower up to 1855. He married the second time in 1855.

Ques: You say your grand mother... took care of the horses in her lifetime... say whether or not... she was afflicted with a cancer in her breast.

Ans: She was afflicted with a cancer on her breast for some three years before her death and she died of said cancer. I dont think she was confined but a short time.

/s/ J. W. Stafford

Caleb Lemons age 55. I reckon it was 1 mile or 1 1/2 that I lived from John M. Burris the last years of his life. I worked for him occasionally on his farm... moved into the neighborhood in 1857, moved away the latter part of 1859, and moved back in March 1861 and lived there until he died... failure of mind in old man Buris [sic] in the summer or fall before he died.

I came to Gainesboro with him when he wanted to see J. P. Murray about writing his will... he lay down on the platform on his blanket in front of B. E. Williams store a while... got up... said he would go see Murray... came back, said Court was not for two more weeks... Murray was not there. When he got home he could not get off his horse I helped him down and carried him in the house... said he did not know that he would get to go again that the said pleuresy [sic] and consumption would kill him. I reckon he was 78 or 79 years old when he died.

He said he was 75 years old when the twins was got. He said was it not the devil that a man 75 years of age could get twins - He was not very healthy I dont [sic] think - He was always complaining and much afflicted and he complained about pleuresy and consumption. Summer and fall of 1861 I do not think he was of sound mind... He had his second wife and she is said to be the mother of the twins Winfield S. and Eliza Jane Burris. I think she had right smart of influence over him She said if he did not put his son Wm Burris off the land she could not nor would not stay there and he put him off.

I think he told me the greater portion of his land cost $400 and it was then worth $1200.

He spent most of his time hunting and fishing and trapping for otter and bee hunting. This was in the old days. He had some stock but not a great deal to own such a farm as he did. I dont think he was much of a worker...

CROSS-EXAMINATION by Defendant:

Ques: You state you worked for him in 1861 and 1862... how did he pay you in 1862...

Ans: He paid bacon and pork and a ?tun or two of wheat.

Ques: When did he die?

Ans: I reckon 1863 on the 26 day of December.

Ques: What ways did Elizabeth Burris influence him.

Ans: She wanted him to make rails for ____ and he said there was no use and later he hired King Flatt and she said hire me and he did. She said she would have a house and he would have nothing more to do with Flatt and he could hire me to do it and he did... I think that Darcus and Virginia McClaren was present... He appeared to obey her very well and I reckon he loved her.

Calep [his X] Lemons

PAUPER AFFIDAVIT: Cause of Wm Stafford and wife Elisabeth Stafford vs Elisabeth Burris, Eliza Jane Burris, Winfield S. Burris, James R. Burris, Dan'l M. Morgan, Mary E. Crabtree formerly Mary E. Burris, John Burris, Missouri Burris, Cravan Burris, Ollive [sic] Burris and S. W. Cassetty.

Wm Stafford and wife Elisabeth Stafford make oath... owing to their poverty they are unable to bear the expense of the appeal to the next term of the Supreme Court at Nashville to decision rendered by Chancery August term 1869...

/s/ William Stafford, Elisabeth [her X] Stafford

COPY OF DEED: I, John M. Burris of the County of Jackson and State of Tennessee for and in consideration of the love and affection I have for my [sic] Eligah Burris and his wife Susan Burris and my Grandson James Renoe Burris... convey unto James Renoe the following tract.... Roaring River... to the heady place and a corner of Lot No 1 being the place deeded to my son and daughter... corner of a field now occupied by Wm Stafford... Kirkpatric corner... Elizabeth McClelans place and corner... 154 1/2 acres - also a portion of the 50 acre tract... road leading to the heady place containing 6 1/4 acres more or less in all 160 3/4 acres with these reservations - that his father and mother heretofore mentioned to live on said land during their natural lives... enjoy rents... neither Eligah Burris nor his wife to have power to sell... 5 September 1861.

/s/ John M. Burris Witness: /s/ Danl M. Morgan, /s/ Joel W. Settle

Registered 3 January 1862.

[Note: Wife Elizabeth did not sign - mlj]

ANSWER of Daniel M. Morgan and Sampson W. Cassetty, Administrators of John M. Burris, deceased to Bill of Complainant and also answer of Elizabeth Burris widow of John M. Burris, Eliza Jane Burris, Winfield S. Buris by guardian Elizabeth Burris & Daniel M. Morgan next friend of Elizabeth Burris, Eliza Jane Burris and Winfield S. Burris.

John M. Burris died 26 Dec 1861 in Jackson County Tennessee and complainant Elizabeth Stafford, wife of complainant Wm Stafford and Elijah Burris and Wm Burris were children by a former wife of John M. Burris... Respondents have no personal knowledge Wm Burris son of John M. Burris is dead but there is some expectation in the family... or whether his daughter Mary married to Crabtree or whether he is living or dead but that is the expectation in the family... names of children of Wm Burris are correctly stated and they are grand children of John M. Burris.

5 September 1861 John M. Burris executed Last Will. Respondent Morgan was present was a subscribing witness... has been admitted to probate... Daniel M. Morgan and Sampson W. Cassetty are administrators... executor named in the will refusing to qualify and act... admit execution of deed to James R. Burris... deed to Winfield S. Burris and Eliza Jane Burris and his widow Elizabeth Burris.

True about 1826 complainant Stafford married a daughter of John M. Burris the complainant Elizabeth Stafford... said Burris deceased allowed them to live on and cultivate... as his tenant at will... and Elijah Burris to live on and cultivate... as his tenant at will.

Admit said John M. Burris was near 80 when he executed said deeds that he was in his 75th year when he married. Respondent Elizabeth says she was 42 when she married and is the mother of Windfield [sic] S. Burris and Eliza Jane Burris that they are twins and the only offspring of said marriage.

BILL OF COMPLAINT of Wm Stafford and wife Elizabeth Stafford and Elijah Burris citizens of Jackson County, Tennessee against

Elizabeth Burris, Eliza Jane Burris, Winfield S. Burris, James R. Burris, Daniel M. Morgan and Sampson W. Cassetty of Jackson County, Tennessee and

Mary E. Crabtree formerly Mary E. Burris, John Burris, Missouri Burris, Craven Burris and Olive Burris citizens of the State of Missouri defendants.

John M. Burris departed life in Jackson County, Tennessee 26 Dec 1861 leaving defendant Elizabeth Burris his widow, complainant Elizabeth Stafford intermarried with William Stafford, Elijah Burris, Wm Burris and defendants Eliza Jane Burris and Winfield S. Burris his only children.

Since his death his son William Burris died leaving defendants Mary Crabtree, John Burris, Missouri Burris, Craven Burris and Olive Burris his only children and who are grandchildren of John M. Burris.

5 September 1861 John M. Burris executed a paper writing purporting to be his Last Will and Testament... a deed conveying land to James R. Burris... another deed to Winfield S. Burris, Eliza Jane Burris... Elizabeth Burris to receive one-third of the rents.

7 April 1862 Winfield S. Burris and Eliza Jane Burris who are minors by their next friend Daniel M. Morgan and defendant Elizabeth Burris commenced action of ejectment against Wm, Stafford [torn] July 1866....

CAUSE HEARD 10 August 1869... proof does not sustain allegation of complainants... bill dismissed and they pay costs...

ANSWER of Missouri Burris and Craven Burris by their guardian ad litem A. B. Botts... Respondents charge John M. Burris was of unsound mind at the time he executed... deed... Respondents are grand children of John M. Burris, are minors... court to guard and protect their interest.

AGREEMENT: I, Elijah Burris agree that all the land I have in possession in Jackson County lies within the calls or lines of a deed made by John Nichols, Nancy Dupree and Keziah Wooldrige to John M. Burris 6th August 1834 registered in Jackson County, Tennessee 15 August 1834, Book D page 492... John M. Burris has legal title... 6 May 1858.

Elijah [his X] Burris

AGREEMENT: I, William Stafford... land on Roaring River District 1, Jackson County, Tennessee including the place where I live... title in John M. Burris. I will hold the same as his tenant... 22 June 1858.

/s/ William Stafford

DEPOSITIONS 19 July 1869 to 21st if necessary, cause of Wm Stafford vs Elijah Burris et al:

Daniel M. Morgan. I made a survey of the land for John M. Burris, making a line between the land where William Stafford, William Burris, and Elijah Burris lived. He didn't tell me the purpose. I thought it was for a future deed. I lived 1 1/2 miles of John M. Burris, were frequently together... very temperate... a man that generally kept his secrets, strong prejudice and great firmness.

Elizabeth Burris wife of said John M. Burris became prejudiced against myself and family and though she was very bitter against us John M. Burris continued the same toward us as before showing no difference whatever... I concluded that she exercised no undue influence on John M. Burris...

Ques: State if David K. Flatt who has given his deposition is related to William Stafford or any member of his family...

Ans: David K. Flatt is father in law to John W. Stafford the only child of said complainant William Stafford the said John W. Stafford having married said Flatt's daughter.

Ques: State the circumstances preceding John M Burris' last marriage.

Ans: John M. Burris lived alone from about harvest time or the latter part of June until his marriage late in December having been abandoned by his son Wm who the old man had taken into the house with him to care for him... but he Wm Burris and the old man fell out... Wm moved off... no one to cook...

The old man said his cupboard ware and kitchen and household furniture were missing on Wm Burris leaving his house that he had to purchase a resupply... occurred in the year 185_ [cut off in filming - mlj]... John M. Burris was about 73 years old. He died 26 December 1861 and had he lived to his birthday in the following year would have been 80 years old in Feby. He was subject to spells of pleurisy before his death.

In 1843 I leased [John M. Burris] land. I first settled with John M. Burris and I then paid rent to Eligh [sic] Burris.

In 1842 I rented of Wm Stafford and the contract was with Wm Stafford...

John M. Burris told me he intended to give land to Elijah and Wm Burris and Elizabeth Stafford wife of Wm Stafford... never told me had had done so. He spoke of the folly of old men who had given their land to their children.

Wm Stafford has been living where he now lives about 45 years, about 162 acres and Elijah Burris has lived on the place claimed by him about 37 years. All the Burris home land on Roaring River is about 645 acres, about $15 per acre.

I am now the sole administrator of John M. Burris... except for a $9 note on Watson M. Cooke, now in the hands of the guardian.... there were unkind feelings of John M. Burris toward his son William from June 1855 prior to his last marriage late in December the same year.

DEPOSITION 16 May 1867 for Complainants at the residence of W. R. Kinner in Gainesboro, Jackson Co:

Jane Kinner age 57. John M. Burris came to our house a short time before he died... said he had done his children a great injustice especially Bill in the disposition of his property...

He said there had been slip gaps made in his fence and he first thought Bill had done it... stock got in, ... crops destroyed... ascertained it was some [sic] his family... His family consisted of his wife and his step daughters Virginia and Dorcas McClairen - the twins [Winfield and Eliza] were very small. Bill was his son but had a family of his own and was not of the old man's family. I told him it was not too late, but he said it was. 16 May 1867.

/s/ Jane M. Kenner

DEPOSITIONS 29 July 1868:

Benjamin Chapman age 52. I was in Gainesboro, think the year John M. Burris died... had a conversation with him... said something had been put in his Spring... accused Wm but found he did not do it... accused him of slip gaps in his fence... satisfied he did not... said he treated Wm wrongly....

Ben [his X] Chapman

David K. Flatt age 56. Acquainted with John M. Burris 12 - 15 years, lived 3 1/2 miles or closer... worked for him... Sawed a house pattern for him the summer or fall before he died and raised it...

David [his X] K. Flatt

DEPOSITIONS 18 January 1868:

P. J. Dudney age 55. Had a conversation with William Stafford after John M. Burris had ejected William Burris and turned him out, was on the day of sale of William Burris... He wanted me to talk to John M. Burris... if the old man turned him out it would run him... said he had every right.

/s/ P. N. Dudney

William Loftis age 67. Knew John M. Burris 30 years.

/s/ William Loftis

James Y. Putty age 39. Knew John M. Burris 12 - 15 years before he died.

/s/ J. Y. Putty

J. W Settle age 48. I was acquainted with John M. Burris from 1836 up to his death, lived some 3 or 4 miles from me. Witnessed deeds from John M. Burris to W. S. and E. J. Burris. I believed him to be of sound mind.

/s/ Joel W. Settle

DEPOSITIONS 20 July 1869:

William Stafford age 61. John M. Burris died 26 December 1861. I had been acquainted 45 years or more... he was not quite 80 years old when he died, he wanted a month and 20 days if it. I married the daughter of John M. Burris about 45 years ago. I received the land where I lived as a gift from John M. Burris.

Elijah Burris age 61. John M. Burris was near 80 when he died. I was John M. Burris' son I lived in about one-half mile of him after I married. I lived with my father before I married. I was with him after my mother became unable to shave him, twice a week up to the time he died. I have been married about 35 years.

I had to shave him from 1851 or 2 up to the time he died which was in 1861.

I have lived on the land where I now live about 34 years. I received said land from John M. Burris as a gift.

John M. Burris had three living children by his first marriage. I don't know if he sent his first children to school enough to learn to read and write or not I know very well they didnt learn it. He worked me very hard but did not work the others so hard... believe we assisted by our labor in paying for it... worked all his first children hard enough.

John M. Burris came to the field with Mr. Washburn. Mr. Washburn said he had a peace [sic] of writing he wanted me to sign... I asked what it was and he said it was nothing to take my land away... that it was for a little support if the old man should need it in his old age thereupon I signed it. Washburn told me I would never be put out of possession that J. M. Burris would either give me a deed or give it to me by will.

I registered the deed from John M. Burris to James R. Burris. I did not intend to file a suit. William Stafford came to me about joining in the suit. I then joined in the suit.

Elijah [his X] Burris

[Note: John M. Burris' will was not microfilmed - mlj].

END OF REEL #115