Jackson Co., TN Loose District/Chancery Court Papers Reel #78
Gore, M. - Graham

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

[Note: Part of this case is also on Reel #77 - mlj].

DEPOSITIONS about 26 Feby 1883:

R. W. Allen age 55. Known island since 1847 or 1848, lived 2 1/4 or 3 miles from the place. There were two ponds between the Chaffin farm and the island. In 1865 there came a freshet that washed away part of my mill. In 1847 and 48 lived about four miles from Mounce Gore; 1850 & 1860 about ten miles. About 1862 I moved to Blackburn's fork, lived there since. /s/ R. W. Allen

W. H. Dudney age 35. Raised in 3/4 miles of the island. Father lived on the land now owned by Chaffin in 1856 and I lived with him. It is my understanding it belonged to [Nimrod] Johnson heirs. /s/ W. H. Dudney

W. J. Young age 51. Was raised on Roaring River about a mile from said island. Was acquainted with river and the island until I moved away about 25 years ago. Noah Lane taught school there I think 1841; in 1842 I went to school to Wash Whitacre; in 1843 to William Gore and in 1844 and 1845 to Murphy as I remember. The school house stood very near the bank at the head of the island on the south side of the river. On the south side the slough went dry except for some holes and ponds and I went swimming in them - one was right below the school house about 60 yards long, the other was nearly round about 10 or 15 yards long.

Question: Was Jake Johnson a son of Nimrod Johnson.

Ans: Jake Johnson was called a son of Nimrod. Nimrod owned the south side of the river. Don't know if Jake bought, or rented from his father.

Chaffin told me he got as many rails off the place as he wanted, and gave Saml Johnson and some others rails to fix their fences.

The river cut off the south bank... made the Hugh Stafford island get bigger. I helped Stafford fence his island I think 1848 or 1849. /s/ W. J. Young

David Loftis age 51. Was born & raised on Morrison's Creek in Jackson County, Tennessee. The creek runs into Roaring River from a half to five miles from the island. Geo Ruff Loftis married Abner Chaffin's daughter. I was at said Chaffin's a short time after G. R. Loftis married at a public working for the purpose of fencing land for G. R. Loftis. We hauled rails off the island... fenced for G. R. Loftis on the south side of the river. /s/ David Loftis

James H. Loftis age 44. Was raised on Morrison's Creek, nearly four miles from the island. /s/ J. H. Loftis

William Johnson age 65 or 66. Was born and raised on Roaring River. I am a son of Nimrod Johnson, deceased. My father owned the Chaffin land since I can remember up to his death... said the island was his. He sold Saml Johnson the upper 50 acre tract & Sam went there to get rails and my father sent me there to forbid him from getting any more. My father sent his Negroes and got rails off the island.

Question: In what year did your father Nimrod Johnson die.

Ans: I don't know.

Question: Were you & Uriah Stafford & your brother Sam Johnson together since this suit commenced.

Ans: We talked about it some...

Question: What Negroes did your father own and send or to haul for him in the days of slavery?

Ans: Wilson and Newton... they are of good character, can be believed in a court of law. William [his X mark] Johnson

James J. Stamps. Will be age 49 next September. Raised until nine years old on Doe Creek, Jackson County. The balance of time until grown lived on Roaring River where Sam Johnson Sr. now lives, above the mouth of Morrison's Creek, from 1844 to 1853. The dwelling house was about one-half mile from the island.

Ques: Were you well acquainted with Abner Chaffin in his lifetime? How were you related.

Ans: We were brothers-in-law. We married sisters.

[About the time Abner Chaffin bought] I was in Overton County a while and then at the head of Tally's hollow a while. Nim Johnson's tenants got wood and rails... Jake Johnson and Dave Johnson when they lived there. /s/ J. J. Stamps

ADJOURNED to Feby 27, 1883

Louiza Reed age 63. Was born at the mouth of Morrison's Creek on Roaring River. I am a daughter of Nimrod Johnson. Raised two or three miles from the island in dispute, never lived over three miles from and now live about that distance. Acquainted with the island and river as it formily [sic] ran for at least 44 or 45 years.

Question: Say whether you and your husband John Reed lived there near two years after you married.

Ans: We lived at the upper end of Dady's [sic; Daddy's] 50 acre tract near said island for the first two years after we married. I have been married about 41 or 42 years to the best of my recollection. Father would get all the rails he needed and give Mounce Gore leave to get some. They were neighbors and good friends from earliest recollection to their deaths... never any disputes.

I am first cousin to Elizabeth Chaffin.

Question: Is the island part of what your father sold to your brother Sam Johnson.

Ans: Don't know what he sold to Brother Sam.

Ques: What is the difference in your age and your brother Samuel Johnson.

Ans: Bro Sam is older... don't know how much... the record of our ages has been lost. I expect 10 or 12 years older. Louiza [her X] Reed

George R. Loftis age 34. Was raised on Morrison's Creek, a tributary of Roaring River. Have been married to Abner Chaffin's daughter, a party to the suit, about 18 years. Lived on Abner Chaffin's land about two years after we married, made two crops there.

I think Spring 1865 I had a public working... got rails off the island to fence said land. In the fall of that year we hauled about 2000 rails off the island and fenced our wheat.

ADJOURNED and continued to 1st Monday in March 1883.

Ques: How long did Abner Chaffin live after you married his daughter

Ans: He lived three or four [sic; probably years].

It has been 22 or 23 years since I've been fishing there. Passed it [the island] since I was a little boy going to and from Gray's mill.

DEPOSITIONS 2 March 1883:

George M. Puttie [Putty], age 63. Known island 30-40 years. [Testimony regarding river course, property lines - mlj]. /s/ G. M. Putty

Newton Johnson 52. I was a slave before the late war. Belonged to Nimrod Johnson until he died then to Ab Pharis who sold me to Thos. K. Harris. I was in my 10th year when I went to Nimrod Johnson. He owned one other colored man named Wils.

Mr. Gore stopped us from getting rocks a little below Johnsons land before Mr. Chaffin died.

Understand the [land] dispute was submitted to arbitration and one of the men was old man John Stafford. He is dead. Not positive there was an arbitration... was talked of and think it was done. Don't know who selected Stafford, but think it was my old master. Newton [his X] Johnson

Sam G. Gore age 37. Known island 26 - 27 years, lived within 3/4 mile. My father claimed it in his lifetime, then my mother. /s/ S. G. Gore

M. L. Gore age 42. The school house stood on the south side of the south slough on a high bank. I went to school to Natan [sic] Murphy... was before the big freshet in 1847 which washed the school away.

Did not find all the title papers after father died. A deed from Elijah Ewing to John Crawford covered most of the river lands... believe it was registered... before the court house burned.

Believe his land was in seven tracts besides the Hill Lands for which we found no title papers.

I am informed John Crawford was my Grand father, my mother's Father and his land descended to my mother and her brothers and sisters.

I know Marion Chaffin.

I have seen a deed, Nimrod Johnson to Samuel Johnson bearing date Aug 26, 1851 for 50 acres. Nimrod was the owner and in possession of the Ben Johnson tract.

I know Asel Duncan. He lived on Nimrod Johnson land known as the lower or Ben Johnson tract in 1851... remember it because that was the year my Father was elected to the Legislature.

I was the oldest Boy at home at the death of my Father and I managed the Farm and attended to mother's business.

Abner Chaffin said in 1865 he thought he had bought the island in the sale of Johnson land but thought Father's title might be best.

Mother died in 1878 or 9, cannot be positive. /s/ M. L. Gore

Job M. Morgan age 48, am a party to suit, am a practical surveyor. /s/ J. M. Morgan

CAUSE HEARD: J. D. & W. H. Goodpasture against John R. Chaffin ["Elizabeth Chaffin, Marion Chaffin" marked through], B. B. Chaffin ["Labin Loftis" marked through], Eliza Loftis, G. R. Loftis, Sallie Loftis, F. M. Loftis, Mary Loftis, Martha Brown and her husband J. H. Brown, James Chaffin, ["T. E. Chaffin now Loftis" and "Pierce Loftis" marked through], Noah Chaffin, Luke Chaffin ["Mary Elizabeth Chaffin" marked through].

Defendants are indebted to Complainants in the sum of $100 with interest from 28 January 1887... agreed by counsel for Complainants to accept $75... appealed to Supreme Court at Nashville, case of Elizabeth Chaffin and others against M. L. Gore and others... tract of land recovered by defendants herein... lien declared by Goodpasture for their services. Land in 1st District, Jackson County, on Roaring River.

DEPOSITION [Blank] August 1885:

Vanoy Fowler. Known S.[Samuel] H. Cunningham, Joshua Chapman and S. [Smith] T. Cunningham a long time. Was present when there was a settlement between the parties. Smith Cunningham was indebted to Sam Chapman, Joshua Chapman was indebted to Smith Cunningham /s/ V. M. Fowler

S. H. Cunningham. Know Joshua Chapman and S. T. Cunningham. S. T. Cunningham had notes on Joshua Chapman. Vanoy Fowler came to my store in Gainesboro... Joshua Chapman owned me money... I got an interest in his wife's father's land... settled indebtedness... the share was valued at $500. Sam Chapman made the proposition. I wrote the deed and the same day took it to N. B. Young as Deputy County Court Clerk and G. B. Murray and James Green as witnesses. I went to Mrs. Herod where Chapman and his wife was and Chapman and Mrs. Chapman executed the deed.

Question: State if you are acquainted with John, Wash and Andy Chapman and with Sam Chapman in his lifetime and if you are acquainted with the Gray lands sold as part of the estate and laid off by John Chapman and the Kelly tract.

Ans: Known them 10 - 12 years, knew Sam Chapman before his death, knew him about ten years before he died. Know both tracts of land. Josh and Wash Chapman both live on said lands... have had a considerable amount of personal property [lists here - mlj]. I was the clerk at M. L. Gore & Co. store. Josh and G. W. Chapman had accounts. Andy charged on them. /s/ S. H. Cunningham

NOTICE TO SHERIFF: Cause of S. H. Cunningham vs Jack Herod vs M. A. Herod and others pending in Chancery Court at Gainesboro... the death of Saml Chapman was suggested and admitted... suit is still pending and Sallie E. Chapman is his widow and Daizy Chapman and Samuel Chapman Jr. are his only children and heirs at law... ordered by court to appear first Monday in March 1887 for Daizy and Samuel Chapman Jr. to appear... show cause why suit should not continue against them. Dated 1st Monday in September 1886.

ANSWER & CROSS-BILL of Jack Herod, colored, to Bill of Complaint against him and Joshua Chapman by S. H. Cunningham.

True he purchased the lands mentioned in the Bill of Complaint of his co-defendant Joshua Chapman, price of $1200. Respondent as paid about $511... executed several notes for balance.

Said Joshua Chapman and wife Alice executed a deed... contract subject to good title, but is now informed legal title is in one M. A. Herod.

Said tract of land was willed to M. A. Herod by her father James G. Cunningham who is dead... Legal title is in her but that by verbal contract she sold or gave same to defendant Joshua Chapman and his wife Alice and to Howard Herod and Gipson Herod and Saml Chapman and his wife Sally and that Howard Herod and Gipson Herod and perhaps Saml Chapman have sold and conveyed to said Joshua Chapman their undivided interest and received the consideration price... with knowledge and consent of M. A. Herod.

Respondent went to see M. A. Herod who told him it was alright to make the trade. Respondent is illiterate and unlearned and knows nothing of the law. He went to see M. A. Herod, his former mistress... respondent acted in good faith... relied heavily [on her advice - mlj]. M. A. Herod is the mother in law of Josh Chapman.

ANSWER: Margarett A. Herod to Bill against her and others by S. H. Cunningham filed 15 August 1881. She was and is owner of the 1st tract. The 2nd and 3rd tracts belonged to her husband at his death and descended to her children. She is the widow of Henderson E. Herod and her children are eight in number... named as charged in the bill.

She owned the interest in the Bob White farm and still owns same... deeded to her by her father.

The heirs at law of her husband are her children.

Her land has not been troublesome... except she has been troubled by those who want to get it away from her.

She has never said anything about giving her land to her children as she has already stated in deposition on file... case of Samuel H. Cunningham vs Joshua Chapman.

Admits the marriage of two of her daughters to Chapmans as charged, denies she was ever in partnership with them as charged. Admits she is friendly with her sons in law, never unfriendly with her sons Gipson and Howard [Herod].

As to the charge she placed Joshua Chapman in possession... read what's on file... no need to reiterate.

Respondent denies she is not entitled to dower.

Respondent denies conversation with Jack Herod as charged... all she said to him is stated in her deposition. As to the alleged transaction with Smith T. Cunningham she knows nothing.

Knows nothing about five judgments against Joshua Chapman. If there were six, her land still should not be taken to pay them. 21 March 1882. s/s Margret A. Herod

DEMURRER of C. M. A. Herod, cause of S. H. Chapman vs

Jack Herod, Joshua Chapman Samuel Chapman and wife and M. A. Herod to Supplemental Bill of Complaint filed August 15, 1881.

Defendant Samuel Chapman has no wife Alice.

C. M. A. Herod demurs to that portion that seeks to subject her land to the payment of debts of another, asks the suit be dismissed.

BILL OF COMPLAINT of M. L. Gore of Jackson County and S. H. Cunningham of Sumner County, Tennessee against

Joshua Chapman, Andrew Chapman, G. W. Chapman and H. W. Williams of Jackson County and John Chapman of Clay County.

Orators will show Joshua Chapman is indebted to S. H. Cunningham... several judgments against defendant Joshua Chapman on 6 March 1878... Joshua Chapman is entitled to credit on 15 March 1878 of $500 for his wife's interest in the Old Bob White Farm conveyed by Chapman and wife to Orator Cunningham. Balance of judgments with accrued interest is $338.35. Samuel Chapman has deceased since the filing of this bill and he now has no administrator of his estate. 28 September 1881 M. A. Herod filed her answer.

Said defendant Joshua Chapman is owner of tracts in 1st District, Jackson County:

Tract bounded by Roaring River, John Van Hooser, J. A. Williams, Rhoda Stafford, on which Joshua and G. W. Chapman now live.

Tract bounded by lands of J. ?Z. Beck formerly owned by F. K. Kelly, Lansden Roberts & perhaps others which lands were sold by court order... case of T. H. Butler vs Martha Lee and others.

Tract bounded by both above tracts, Rhoda Stafford and perhaps others, same previously owned by F. K. Kelly and others.

Defendant Joshua Chapman is largely indebted... years 1877 and 1878 bought large amounts of [live] stock, drove or shipped off, pocketed money and came back and pretended to be broke. At that time Andy Chapman was a very young and a very poor man. His father was dead and died a bankrupt. After the said Joshua his brother swindled... pretended to [be] broke, Andy Chapman grew up like a mushroom financially... bought the 2nd tract above...

The 3rd tract above was conveyed by H. W. Williams to Andy Chapman. Defendants Joshua and G. W. Chapman having negotiated the trade.

Asks that all property be sold and creditors paid. 23 January 1885.

DEPOSITION:

S. H. Cunningham. Never told Alice Chapman that if she would deed me her land it would settle everything between me and Josh Chapman.

Question: State whether you ever had any such contract with Joshua Chapman and his wife Alice.

Ans: Never did...

Ques: State circumstances deed executed.

Ans: Some time in the forepart of March 1878 I had Josh Chapman arrested on a charge of forgery and on the morning of the day it was set for trial Sam Chapman came in the store... made the proposition that Josh and Alice would make me a deed to her share in the Herod land if I would drop the matter and not prosecute and they would let it go as a credit and he would pay the balance if I gave him a chance.

Ques: Are you now on friendly terms with your father-in-law John P. Murray?

Ans: I don't have anything particular against him. We don't have anything to do with each other. March 1878 I lived in Gainesboro with John P. Murray, never had any differences. /s/ S. H. Cunningham

ANSWER of Andrew Chapman, Joshua Chapman, G. W. Chapman and John Chapman to Bill of Complaint against them by S. H. Cunningham and M. L. Gore filed 24 Jany 1885.

S. H. Cunningham came to Respondent Joshua Chapman and wife Allice Chapman (formerly Alice Herod) ... asked they make him a deed... to patrimony left by her father H. E. Herod... deceitfully said would give him a receipt. They asked S. H. Cunningham for a receipt, he said he'd give it the next day. Went next day and S. H. Cunningham then wanted a deed to his father's old home place... would not agree, and never got a receipt. Respondent's wife is the niece of S. H. Cunningham.

Respondent Joshua Chapman ... was not in partners with Sam Chapman... shipping stock... His brother Sam... squandered the money and came back broke and died wholy [sic] insolvent. Joshua Chapman was security. Respondent admits that he hired to his brother Andy at $10 per month plus a house and garden and to feed his family.

Respondent alleges M. L. Gore bought the notes at a Heavy Shave [deep discount - mlj] which is illegal... defrauded County and State Treasury.

Defendant G. W. Chapman states he has no interest... his brother Joshua Chapman. Respondent asks to be dismissed.

Respondent John Chapman states he has no interest whatsoever... did bid off the tract where Josh and G. W. Chapman now live. Respondent gave his own notes for said land, and not one of the other Chapmans are on said notes. Respondent found he was much indebted, needed to raise money to pay on his home place in Clay Co., and therefore sold his bid to his brother Andrew Chapman in good faith.

Respondent Andrew Chapman denies everything... hired his young, single brother G. W. Chapman... to assist in getting out logs. His brother Joshua on account of sickness has been unable to work... he has nevertheless furnished said Joshua and his wife and five children a means of support.

Denies any of the property attached [by Complainants] belongs to Josh or Wash Chapman... in fact it is his. [No date, signed for Defendants by their Solicitor - mlj]

DECREE 19 Sept 1893: The bill of S. H. Cunningham of Sumner Co., TN & M. L. Gore of Jackson Co. as Security is dismissed and Cunningham and Gore to pay all costs.

ANSWER of Allice Chapman as Administrator of Joshua Chapman to Bill of Complaint of S. H. Cunningham and M. L. Gore filed 8 March 1888 against her intestate Joshua Chapman. Denies at the time of his death he owed Complainant one cent. If he ever did, statute of limitations of six and ten years apply...

Respondent denies Jack Herod was or is insolvent.

S. H. Cunningham took said Jack Herod notes at a discount of $100 without recourse on Joshua Chapman. Note for $110 given to S. T. Cunningham dated 1 March 1874 due one day after date... bill filed 15 August 1871 therefore barred by statute of limitations of six years.

Proof could amply be made that M. A. Herod did consent to sale of land to Jack Herod... She and her husband had bought the shares of Gip T. and Howard H. Herod & Sallie Chapman and paid for the same which constituted the part or parcel of land sold to Jack Herod and for which the $600 in notes was given by Jack Herod. Dated 8 September 1891. /s/ Alice Chapman

DEPOSITION:

M. A. Herod age 54. S. H. Cunningham is my brother. Joshua Chapman is my son in law. Have known Sam since he was born. Have known Joshua Chapman 16 or 17 years.

I remember Joshua and Alice Chapman conveying her interest in said land to S. H. Cunningham. Josh and his wife lived at my house at the time.

S. H. Cunningham came over after dark about 8:00 or 9:00 to get the deed to Alice's share in her father's land signed and I was in bed upstairs. I recognized Ban Murray's voice, heard Sam Chapman and Sam Cunningham talking. They told me N. B. Young was along. Ban Murray is Cunningham's brother in law. /s/ M. A. Herod

ADJOURNED to Aug 22, 1888.

Mrs. Alice Chapman age 32. I am the wife of Joshua Chapman. We have been married fifteen years. I am S. H. Cunningham's niece. I am an heir of Henderson C. Herod, deceased, entitled to a share of the real estate on the north side of Cumberland River in Jackson County. I conveyed my share to S. H. Cunningham. There were eight shares and the others sold for $500 each. It was settled for my husband's debts. Uncle Sam and I did not have any certain price on the land.

G. B. Murray was present and representing his brother-in-law S. H. Cunningham. Pole [Napoleon B.] Young was there, Sam Chapman and Jim Green. Sam Chapman and Jim Green are dead. Pole Young took my privy exam. Cunningham took the deed, gave no receipt. They were out in the yard leaving, and Josh called that he had not given a receipt. It was Sam Cunningham's voice said to come in to town next day and he'd write one. Josh went into town and Cunningham said he owed $80 more and would not give a receipt and wanted Josh to sign him a deed to his father's land and he would not do it. I think I signed the deed January or February 1878.

Question: Did you file a bill for divorce and alimony against said Joshua 25 November 1879.

Answer: Yes sir. /s/ Alice E. Chapman

N. B. Young age 45. Took the privy exam of Alice E. Chapman. /s/ N. B. Young

DEPOSITIONS 14 June 1890.

Smith T. Cunningham. About 19 November 1877 I lived at Celina, Clay County, Tennessee. I am the brother of S. H. Cunningham. Josh Chapman was indebted to me, I was indebted to S. H. Cunningham. /s/ S. T. Cunningham

NOTICE TO SHERIFF: First Monday in September 1890, death of Joshua Chapman suggested and admitted, Alice Chapman appointed Administratrix.

DEPOSITIONS July 1 - 13, 1885:

Wayman Hawkins age 32. Know G. W., Joshua and Andy Chapman. Joshua is about age 37. Andy 25 or 26. Wash is about 34.

I am of kin to the Chapman boys. The Chapman boys mother and my mother are half sisters. I am not related to complainants. /s/ Wayman Hawkins

Asa Johnson. Known the Chapman boys ever since they were born, lived about two miles from Andy. His mother is my half sister. /s/ Asa Johnson

J. P. Whitaker, am acquainted with the Chapmans, my wife and their mother being half sisters. Andy lived with his mother at the old place up until he married. The mother of the Chapman boys lived with Andy or Andy lived with her... heard Mrs. Chapman complain about how Andy would keep up her wood... she went to live with Wash Chapman. /s/ J. P. Whitaker

J. T. Smith. Known the Chapmans since they were little boys, lived something like a mile from them for sixteen years. Joshua was a man of good judgment and business tact. Same way with Wash Chapman. Andy was younger than the others. /s/ J. T. Smith

J. M. Loftis Sr. age 53. Sam and Wash owed me money, signed a note. Andy and Josh weren't signed on it. Sam paid me some of it then Sam died. I went to Wash and Josh, they said to hold on, they'd pay me. I sold the note to M. L. Gore. /s/ J. M. Loftis

James Lynn. [Nothing new - mlj]. /s/ James Lynn

Sam'l L. Johnson age 41. Known the Chapman boys all their life. Talked with John Chapman. He said Andy had bought the 90 acre tract and he bought the home tract and put the boys to work and said he'd do right by them. John lived in Clay County. Seen Josh and Wash working there. /s/ S. L. Johnson

Daniel N. Johnson age 38. Know Josh, Wash, Sam & Andy and John a long time. John is older than I am. Josh has had work done at my shop... blacksmithing in part of work done on log wagons. /s/ D. N. Johnson

ADJOURNED to June 3, 1885.

Lafayette Washburn age 52, occupation merchant. Know Joshua, G. W. and Andy Chapman. /s/ Lafayette Washburn

COPY OF NOTE dated 31 May 1884: Andrew [his X] Chapman, /s/ Josh Chapman, /s/ Wash Chapman

DEPOSITION:

J. H. Stafford. I moved near the Gray farm in 1878 or 1879. Josh and Wash moved on what was known as the Gray farm in 1877 and lived there til Fall 1883 about one mile. Sam Chapman logged. Don't know if he did anything else or not. /s/ J. H. Stafford

ADJOURNED to July 4, 1885.

D. W. Hawes age 68. Know G. W., Josh and Andy, knew Sam in his lifetime until he died. Don't recollect how long he has been deceased. Boarded with me 2, 3 or 4 years until a short while before his death.

Ques: Say at the time Sam boarded with you there was a saloon or grocery in Gainesboro owned or run by Andy Chapman.

Ans: That was my understanding. /s/ D. W. Hawes

ADJOURNED to July 7, 1885:

W. H. Whitaker age 61. Knew Josh, Sam and Wash Chapman in the winter of 1877-1878. /s/ W. H. Whitaker.

John M. Burris age 46. Known Josh from boyhood, lived 6-8 miles from them. Josh sold cattle to Hugh Tinsley in Clay County. /s/ J. M. Burris

H. G. Tinsley. Now live near Celina, Tennessee. In 1877-8 I lived at Butler's Landing in Clay Co. /s/ H. G. Tinsley

J. A. Prewitt age 60. Know Joshua, knew Sam in his lifetime. /s/ J. A. Pruett

H. H. Loftis age 45. Know Joshua, G. W. and Andy Chapman, knew Sam in his lifetime. /s/ H. H. Loftis

ADJOURNED to July 9, 1885.

Napoleon B. Young. Know G. W. and Andy Chapman. Have been acting J. P. of Jackson County from 1875 to present. /s/ N. B. Young

DEPOSITIONS 28 October 1882:

Jesse Heady age 45, live in the Free State, Jackson County, Tennessee, am a farmer. Known Josh, G. W. and Andy Chapman 8 - 9 years. I bought a note on Josh and Sam from G. R. Loftis, my brother-in-law. /s/ Jesse Headely

Mrs. Lucinda Crabtree... for plea in abatement... her land which Complainants are seeking title and possession lies entirely in Clay County, Tennessee. Jackson County has no jurisdiction. 4 December 1903.

ANSWER of A. W. Crabtree, Sam Crabtree, Frank Crabtree, Mrs. Sarah York and Elizabeth Muncie who are children and heirs of Lucinda Crabtree who since filation [sic] of the bill died and the bill was revived against her children. Said bill filed 24 October 1903 by M. L. Gore and S. G. Gore.

Defendants deny the allegation that Complainants are owners of land and entitled to immediate possession.

Defendants Sam Crabtree, A. W. Crabtree, Frank Crabtree, Mrs. Sarah York and Eliza Muncie have held land peaceably where timber was cut since 1855. Denies the land is in the 4th and 13th Districts of Jackson County, but aver it lies in Clay County, TN.

BILL OF COMPLAINT of M. L. and S. G. Gore of Jackson Co. against Lucinda Crabtree of Sumner Co., TN, John Shoulders and Logan Sadler, C. B. Jenkins in his own right and as agent of Lucinda Crabtree and Alex Lemons both of Clay County.

Complainants they own tract in 4th & 13th Districts, Jackson Co... begin corner 5000 acre survey of Michael Stone's... what is called the Matthews line... west along Jennings Creek... 500 acre survey of Johnson W. Hutchinson... containing some 5000 acres.

Complainant owned said land since 1892 and defendants [Blank] 1903 took possession of the north boundary and cut trees.

DEPOSITIONS:

Robert Pedigo age 55, am the practical surveyor for Monroe County, Kentucky, reside there. Present when I made a survey for defendants were Brock Jenkins, Dr. R. F. Crabtree and I think a Mr. West, another one or two. Used the Grant of Hiram Crabtree of 1700 acres. /s/ Robert Pedigo

R. F. Crabtree age 46, am one of the defendants, live Monroe Co., Kentucky, am a physician. Met Capt. M. L. Gore on Pine Lick Creek. W. D. Meador, the County surveyor of Monroe County run the survey line... Gore was not satisfied. He had his surveyor run it and I was not satisfied. It became evident we could not agree.

W. B. Rody, live Monroe Co., KY, am a lawyer. Once owned the land where the beginning corner of the 1700 acre tract... Grant by Commonwealth of Kentucky was to me, not to Carie [Cary - a male] Cherry. /s/ W. B. Roddy

C. B. Jenkins, am a defendant. Cut timber off land in litigation, been all over it. Knew Hyram [Hiram] Crabtree in his lifetime. He is dead. He is the father of Crabtree defendants, been dead about eleven years. Found a marked tree claimed as a corner... Those who said it was were Geo Brotherton, Wat Allen, LoLo [or could be SoSo or JoJo] Jenkins, Sam Clark, Andy Stafford, Elijah Landry. Geo Brotherton or Alex Bilbrey said it may be in the Mathis [Matthews] Line. /s/ C. B. Jenkins

J. H. West age 63, live 12th District of Clay Co., TN for nine years. J. H. [his X] West

E. A. Lemmons age 53, live 12th District, Clay Co., am a [lumber] mill man. Dealt in lumber logs 35 years. /s/ E. A. Lemmons

General Cherry age 51, live Clay Co., Tennessee. Bought some land from Hyram Crabtree near the Kentucky Spring. He run it out [surveyed - mlj]. At the time he sold it he owned on both sides of the Matthews line. Was 17 years ago. He was an old man at the time. /s/ G. Cherry

Elijah Lundry age 68, live in Clay Co., own land said to be in the Matthews line... joins Watt Allen. /s/ E. lundery

S. W. Allen age 34, live Clay Co. Had a conversation with Geo Brotherton in his lifetime. He had me summoned to go to Gainesboro. /s/ S. W. Allen

A. D. Stafford age 3?2, live Clay Co. /s/ A. D. Stafford

M. A. Bilbrey am some 30 years old, live Jackson Co. M. A. [his X] Bilbrey

ANSWER of Grady Gore, C. C. Gore, Virgil Gore and Clyde Gore, all minors of tender years by their guardian John J. Gore.

True their grand father C. C. Gore died, owner of lands... Dated 21 Oct 1919.

BILL OF COMPLAINT: Charles C. Gore and Mrs. Elizabeth Gore, widow of C. C. Gore deceased of Overton Co.; Wm Gore of Davidson Co.; John Gore & wife Bertha Gore, Allen Gore & wife, Mounce Gore & wife Nancy Gore, Jim Gore, Catherine Gore, Mollie Bennett & husband Bob Bennett, Maggie Petty and husband W. B. Petty all of Smith Co.; Fannie Mitchell widow of Sam Mitchell deceased of Davidson Co.; Bettie White and husband John White of Wilson Co. - Complainants, all of Tennessee against

Grady Gore of Overton Co., C. C. Gore and Virgil Gore and Clyde Gore of Smith Co, being minor heirs of B. L. Gore deceased.

C. C. Gore of Smith Co. died intestate on Saturday Sept 14, 1912... land 6th District of Jackson Co. on Sugar Creek south side of Cumberland River being 560 acres more or less being land purchased by us of Elvira Poteet, I. B. Pickett, F. M. & J. M. Morgan, Mounce L. Gore and other Gore heirs composed of three tracts and a fourth tract bought of J. R. M. Kinnard [gives boundaries, mostly trees - mlj].

Said C. C. Gore deceased had the following lawful children [numbering theirs]:

1. Charles Gore

2. William Gore

3. John Gore

4. Allen Gore

5. Jim Gore

6. Mounce Gore

7. B. L. Gore now deceased, represented by heirs Grady, C. C., Virgil and Clyde Gore, minors.

8. Mollie Bennett, formerly Gore, wife of Bob Bennett.

9. Fannie Mitchell, formerly Gore, widow of Sam Mitchell, deceased.

10. Betty White, formerly Gore, wife of John White.

11. Maggie Petty, wife of W. B. Petty

Surviving is widower Elizabeth Gore, entitled to 1/3 interest as dower.

Ask land be sold and guardian be appointed for minor children.

PLEA of Charles C. Gore, one of those named in the bill, states he filed at Livingston, Overton Co., on September 20, 1912 for sale of same land, asks bill filed in Jackson County, Tennessee be dismissed.

CAUSE HEARD... judgment against all defendants except W. J. Gray and the heirs of Richard Gray, deceased and William Myers and Jonas Myers, heirs of Richard Gray deceased are entitled to recover funds on deposit in this court of $83.33. W. J. Gray entitled to recover $41.66. Defendants Jonas and William Myers entitled to recover $15.15.

ANSWER of R. H. Goodnight and H. P. Goodnight to petition of M. L. and S. G. Gore filed 27 Feby 1895 against heirs of S. S. Gray and perhaps others.

Richard Gray is dead and was dead at filing of bill. His heirs and distributees are R. H. Goodnight and H. P. Goodnight who reside near Coal Hill, Arkansas.

At the sale of S. S. Gray lands 18 May 1878, Complainants purchased what is known as the long branch land, shown by the record to contain 320 acres... believes contains 420 acres.

Land was surveyed by William Gore, a brother of Complainants, who made a mistake. Price bid was only $738. /s/ R. H. Goodnight, H. P. Goodnight

Ackowledged State of Arkansas, County of Johnson September, 1895 by Clerk of Court.

PETITION of M. L. Gore and S. G. Gore against John Gray, Richard Gray, J. B. Gray, G. W. Gray, W. J. Gray, Sidney S. Gray of parts unknown unless they reside at Macon County, Tennessee; Angelina Chapman of Jackson Co.; William Myers, Sallie Myers, John Myers, Jonas Myers and Susan Myers of parts unknown; Clay Reeves and M. G. Butler of Jackson Co. and Vina Ragland who was the widow of Henry Myers who was one of S. S. Gray's heirs and who died some time ago. Said defendant Vina is the regular guardian of her children by S. S. [sic; note she was wid of Henry Myers - mlj] Myers to wit Charley Myers, Fred Myers, Martin Myers, Annie Myers; and H. H. Cason, Administrator debonis non of deceased [Admr debonis non is administrator of property not previously distributed - mlj].

Many years ago there was a suit to sell land of S. S. Gray for the purpose of distribution of funds to heirs... decree M.D. "H". The Clerk & Master, 18 May 1878 proceeded to make said sale. Sale made of Tract 2, long branch tract, reported September 1878

COPY OF Last Will & Testament of William Gray [Note: Both his will and that of his son Samuel S. Gray have been transcribed verbatim, are on at least one other reel which deals extensively with both these estates, not repeated here. One reel was #54. William Gray's will was dated 14 June 1852 - mlj].

INVENTORY of personal property William Gray owned at death... came to hands of Samuel Gray, Executor of his Last Will & Testament:

Negro man George about 65.

Negro woman Phobe about 65.

Negro man Lazarus about 40.

Negro woman Elza about 36.

Negro girl Jane about 17.

Negro boy Willis about 13.

Negro girl Amanda about 11.

Negro boy John about 8

Negro girl Matilda about 6.

Negro boy Frank about 9.

Negro girl Patience about 5.

Negro boy Willie about 20.

[Personal property also included notes, furniture, farm implements, etc. - mlj].

[Note: This case is very confusing, few documents, few relationships given, but mention cases in other courts which may, if found, clarify a great deal - mlj].

DEMURRER of John Officer, Sam Johnson & wife Fannie Johnson. Ask bill be dismissed.

TO SHERIFF of Maury Co. Summons H. P. Figures & wife L. D. Figures to appear 3rd Monday in March 1896 to make defense to Bill of Complaint of M. L. Gore et al vs John Officer, et al.

TO SHERIFF of Overton County. Summon John Officer & Jack Ray 3rd Monday in March 1896...Bill of Complaint of M. L. Gore et al vs John Officer, et al.

BILL OF COMPLAINT of M. L. Gore, S. G. Gore, Wm Gore, I. B. Pickett, J. M. Morgan and wife P. M. Morgan and E. L. Gardenhire of Jackson Co. and Elvira Poteet of Overton Co., Benton McMillin of Smith Co. and George H. Morgan, D. H. Morgan, Mamie Morgan & Edgar Morgan of Putnam Co, Tennessee

against H. P. Figures and wife [blank] of Maury Co., TN and John S. McMurray and wife [blank] of Trousdale Co., TN, M. G. Butler of Jackson Co., John Officer of Overton Co. and Sam Johnson & wife [blank] of White Co. and Jack Ray of Overton Co.

Complainants state it is impossible to supply record of H. P. Figures and wife and John S. McMurray and wife. Both Figures & McMurray are attorneys.

Complainants state they brought suit 15 August 1884 in Circuit Court of Putnam County, Tennessee against

Cicero B. Duncan, William A. Officer and defendant Jack Ray to recover possession of 10,000 acre tract granted by State of Tennessee to John Allred and Mounce Gore dated 30 August 1849 founded on entry dated 16 October 1830.

Case was prosecuted, judgment had, was appealed to Supreme Court of Tennessee. Complainants ask injunction against land being sold, and involves heirs of William A. Officer, deceased, which are numerous [not listed - mlj].

ANSWER of John S. McMurry & Carolina D. McMurry to Bill of Complaint of M. L. Gore and others. Knew nothing of action of Supreme Court of the State of Tennessee affirming decree of Chancery Court dismissing Complainant's bill in the case of M. L. Gore and others against John Blaylock and others from Chancery and Circuit Courts of Putnam County.

Respondents and other heirs of C. B. Duncan were not before the Supreme Court... there are many heirs of C. B. Duncan, costs should be spread. 25 March 1896.

ANSWER of W. R. Poston to Bill of Complaint against him and W. A. Overton by M. L. Gore and M. G. Butler filed 12 September 1907. Admits he and J. C. Copeland purchased land, states it was paid for.

BILL OF COMPLAINT of M. L. Gore and M. G. Butler against W. R. Poston and W. A. Overton of Jackson Co. Complainants on 19 September 1899 sold to Poston & Copeland for $1100 land in 9th & 6th Districts of Jackson Co... begin at a stake in Asa Lynn's 300 acre tract... Jackson's 50 acre tract... 100 acre tract entered in the name of John Gaw and ?Acting Hawkins... Greenwoods 300 acre tract. Said J. C. Copeland on 29 November sold his part to W. A. Overton.

BILL OF COMPLAINT of Mounce Gore, Wm Gore, S. G. Gore, I. B. Pickett, Pauline Morgan & her husband Job M. Morgan, M. G. Butler, W. B. Butler, citizens of Jackson County; Elvira Poteet of Overton Co; D. H. Morgan, Edie [Edward] Morgan and Mamie Morgan, minors by their regular guardian Geo H. Morgan of Putnam Co.

against Pole Pyron and James Lynch of Clay County.

Complainants are joint owners of land 13th District Brimstone Creek, bounded north by Mathis [Matthews] line, south by land of B. G. Keeling, east by [blank] Cherry formerly known as the Kirk Moore place and the land of Montgomery Hufhines and west by land of heirs of Mounce Gore deceased.

December 1890 defendants entered onto land, cut logs... [No relationships - mlj].

CAUSE HEARD [July and August marked through] 1852. About 31 January 1846 Complainant sold Defendant lands... executed Bond for Title. Defendant is indebted to Complainant for said lands... waters of Cumberland and Roaring River... west side of Hutchisons fork of Mill Creek... northeast corner of Hampton old tract, on the south side of Fiske road running south with the Overton County line... crossing Hoppers Creek on the east side of Gaws road crossing Fiskes road and Sugar Creek... east with Loves line, crossing the road that leads from Cumberland River by way of Antioch meeting house... near William Lovells 50 acre tract... Thomas Ridley indebted for $450 on notes due 25 December 1848, 1849, 1850.

DEPOSITIONS 18 November 1891:

John [?I. or J.] McCoin. Know land on Pine Lick fork of Jennings Creek adjoining land formerly owned by W. B. Roddy & others. Heard Roddy say he sold timber taken off to J. M. Burris. 28 August 1891. /s/ John ?J. McCoin

[Note: When written in documents, McCoin's initial looks like "I". When he signs, look like "J". McCoin was also spelled McKaughan by others - mlj].

S. G. B. Allen. Don't have ill feelings against M. L. Gore, but don't think he treated me exactly right in the way he commenced lawing me. S. G. B. [his X] Allen

John M. Burris [No age, no relationships]. /s/ J. M. Burris

Filmore Roddy.

Question: Did you or your father ever bring a lawsuit against Wade McCoin or John I. McCoin?

Ans: We did not. W. H. McCoin brought suit against us... judgment in our favor.

Ques: Don't you know when the survey was made... it was ascertained to be on the land of W. B. Roddy... you and your father to have judgment for logs in controversy.

[Roundabout affirmative answer hints he is the son of W. B. Roddy, but doesn't say so definitely - mlj]. /s/ Fillmore Roddy

W. B. Roddy age 57. Sold John M. Burris timber in 1878. Was to pay me when he run the timber and got the money for it.

BOND: W. B. Roddy and Fillmore Roddy, Principals and H. H. Herod, Security to M. L. Gore and other Gore heirs, $150... 12 March 1887.

ANSWER of William B. Roddy and Filmore Roddy to Bill of Complaint of Gore heirs... logs they cut were on their property. 15 March 1887. /s/ W. B. Roddy, Fillmore Roddy

PETITION of T. B. Murray and John J. Gore against

James Stewart and wife Emily Stewart of Jackson County, Tennessee.

Petitioners show on 18 Feby at her special request they filed bill for divorce of Emily Stewart against James Stewart alleging cruel and inhumane treatment... attachment issued [personal property listed].

Petitioners are entitled to a reasonable fee for filing. 19 March 1896.

BILL OF COMPLAINT of Emily Stewart against James Stewart, both of Jackson County. Married Jackson County, TN 18[blank]. Defendant struck her with his fist... cursed... abused.

They have had nine children, all of age except two, Asberry age 19 and Thomas age 14. She is proper custodian.

CAUSE HEARD 19 November 1896... attorney fee to be $15.00.

ANSWER of James and Emily Stewart. They filed order to dismiss cause of divorce on 29 February 1896.

ANSWER of James A. Green and Etta Green by guardian ad litem Wm M. Pickett to Bill of Complaint of M. L. Gore.

True his wards own jointly with W. B. Green one undivided half of a town lot &c. 23 September 1879.

ANSWER of Z. VanHooser and J. B. Mansel to Bill of Complaint of M. L. Gore, guardian and others.

True Etta and James Green are minors and M. L. Gore is guardian, and that James A. Gaines died in Jackson County many years ago.

W. C. Gaines' interest was sold as alleged. Admit to the death of Rufus Gaines. Their co-defendant Labon Loftis purchased same.

Respondent Z. VanHooser owns an interest said to be 1/12 which he purchased from Peter G. Cox in conjunction with B. E. Williams, registered Jackson Co., Book A, pages 37 & 38.

REPORT OF C & M. Death of Labon Loftis is suggested and admitted in open court. H. H. Loftis, Administrator of Labon Loftis, deceased, who was a defendant in this case agrees to pay cost... no more litigation. [No date. May be more on another reel - mlj].

DEPOSITION 20 October 1902:

Wm Gore, age 78, am a plaintiff. Was a party to suit of I. B. Pickett and others. [Nothing new. Concerned estate of Mounce Gore - mlj].

SUMMONS: Bennett Minor and James Cherry of Jackson Co. and Thomas Weaver of Clay Co. 12 February 1874.

SYNOPSIS: Act of Trespass, Complainant and Defendant settled, each agreed to pay half of costs. No relationships given.

Complainant and Defendant both of Jackson Co. Married in Jackson Co. 188[blank], together until about three weeks ago... deserted her, said he was not going to maintain Complainant and her little children any longer... that he thought more of ?Didaine Julians (a base prostitute) little finger than he did of Complainant's whole body. Believes him guilty of adultery with said ?Didame Julian.

[Personal property listed, includes eight acres of corn on land of Sam Putty in District 12, Jackson Co.].

Two children of their marriages age seven and 7 named Jim and Mc. She is the proper person to care for them. 25 June 1895. Nettie Jane [her X] Grace

BILL OF COMPLAINT of Netty Jane Grace. Married 188[blank] in Overton County, Tennessee. Three children of their marriage James 10, Mc 7 and Jesse aged 2. 26 April 1899. Netty J. [her X] Grace

[Note: Confusing, part may be missing. Appears to be one of the cases interrupted by Civil War and court house fires. Many relationships at end of documents - mlj].

ANSWER of M. C. McKinley to Bill of Complaint of Jared H. Graham.

Respondent admits he has had land in his possession since about the last of 1846... raised a crop there in 1847... denies he is tenant in common with complainants, claims under adverse possession.

Admits he knew contents of James Roberts will before he made the purchase... was then in litigation... bought the interest of heirs at law of said James Roberts.

Respondent was advised that if said will should be set aside that he would only be entitled to 5/8 of said land. If said will was sustained and the whole was devised to six of Testator's children as a class and one of the six had died in the life time of the Testator and before the will took effect... testator having died previous to the act of 5 February 1842...remainder of the class entitled to the whole...

Whether the legacy to Aletha Graham the mother of Complainants is legal or not is a matter of law to be decided by the courts... does not know what James Roberts may have advanced to his children.

PETITION: Cause of Garrett H. Graham [Jared] et al against Mathew C. McKinley, et al. Came parties by attorneys and suggested the death of defendants James Buchanan and Letty Buchanan and Shepherd Holliman... introduced Albert Stanton who said Shepherd Holliman died 1861 or 1862 and that James and Letty Buchanan died 1866 or 1867... cause continued until next term.

DEPOSITIONS 20 December 1876:

James M. Richmond age 56. Was tax collector of Jackson Co. 1858, 59 and 60. Land in Dist. 15 assessed to M. C. McKinley:

1858, 800 acres, value $4000, taxed $.38 per $100.

1859, 950 acres, value $7000, taxed ditto.

1860, 960 acres, value $6000, taxed $.30 per $100.

Taxes were paid those three years, don't know who paid them. /s/ James M. Richmond

F. M. Price age 44 or 45, was Tax Collector 1861 through 1871 [Note: Court house closed, no taxes collected during Civil War]. Land in District 15 assessed to Matthew C. McKinley:

1865, 960 acres, $5500.

1866, ditto.

1867, ditto.

1868, ditto.

1869, ditto. Total amount of taxes $61.88.

1870, value $4000, 810 acres.

1871, value $6600, 810 acres.

All taxes were paid. /s/ F. M. Price

CAUSE HEARD 7 December 1885, before Supreme Court at Nashville. Decree of Jackson Co. Chancery Court of 26 April 1872 affirmed.

Rent that accrued in lifetime of M. C. McKinley and the shares of the heirs of Aletha Graham and Elizabeth Holeman is the same, are properly chargeable against the estate.

Heirs of Aletha Graham are entitled to 1/8 of 1/6 being $188.08 5/8. Heirs and distributees of Elizabeth Holleman are entitled to 1/8 of 1/6 being $188.08 5/8.

While T. C. McKinley has been in possession and claiming for self and for shares of Aletha Graham and Elizabeth Holleman... properly chargeable to him....

Ridley Roberts' heirs and distributees or their assignee T. C. McKinley... in order to make said Elizabeth Holleman and Ridley Roberts equal with other heirs of James Roberts, deceased.

DEPOSITIONS:

Job M. Morgan age 26. Knew land... dry fork of Martin's Creek near Granville, Jackson County. /s/ J. M. Morgan

Wm. B. Holmes age 49.

Question: State whether you are familiar with the land M. C. McKinley purchased of John K. Sadler and his wife Celina Sadler, James B. Buckhannon and his wife Lettie Buckhannon, James Sadler and wife Patsy Sadler, Zedock B. Roberts and Buckhannon W. Roberts, devisees of James Roberts, deceased... James Roberts owned at death on Dry fork of Martin's Creek, on which said McKinley now lives, near the town of Granville.

Ans: Known land since 1836, live one mile. /s/ William B. Holmes

James Pharris age 55. Am a farmer, knew land. James [his X] Pharris

David G. Shepherd [No age]. McKinley has cleared land where he lives, planted an apple orchard. I was not present at the distribution of the personal estate of James Roberts, deceased. /s/ D. G. Shepherd

Albert Stanton age 50. Know land. /s/ A. Stanton

John Hughes age 51.

Ques: State if you know the children of James Roberts, deceased. How much John K. Sadler and wife Celina, James Sadler and wife Patsy, James B. Buchanan and wife Letty, Zadock B. Roberts and Buchanan W. Roberts have been advanced.

Ans: ... B. W. Roberts received $500 to make him equal with the others. Since the death of Letty the Negroes were divided and each one of the above children received [Illegible] in Negroes including the children of Aletha Graham deceased, $1466.25 being six parts in addition to $500 each.

Know land where James Roberts lived and died, where Matthew C. McKinley now lives.

Ridley Roberts and the Holleman children received $293.75 from the assets of James and Letty Roberts. /s/ John Hughes

James D. McKinley. I am the son of Matthew C. McKinley, was residing and still reside at my father's. /s/ James D. McKinley.

TO SHERIFF OF JACKSON CO, TN: On 22 August 1860 Jared H. Graham, Administrator of Aletha Graham deceased filed a Bill of Complaint against M. C. McKinley, James Buchanan, Letha Buchanan... still pending.

March 1879, the death of James and Letta Buchanan was suggested and proven.

Alex Buchanan, J. H. Buchanan and George Buchanan, Ada Paine, Carolina Buchanan and James Ross, a son of a deceased daughter of James and Letta Buchanan are their only children and heirs at law. John Ross is a citizen of your county.

TO SHERIFF OF DIXON CO, TN: On 22 August 1860 Jared H. Graham, Administrator of Aletha Graham deceased filed a Bill of Complaint against M. C. McKinley, James Buchanan, Letha Buchanan... still pending.

March 1879, the death of James and Letta Buchanan was suggested and proven.

Alex Buchanan, J. H. Buchanan and George Buchanan, Ada Paine, Carolina Buchanan and James Ross, a son of a deceased daughter of James and Letta Buchanan are their only children and heirs at law. J. H. Buchanan is a citizen of your county.

DEPOSITIONS regarding value of land, no date:

A. J. Vantrease. /s/ A. J. Vantrease

Leonard Huff age 45. Leonard [his X] Huff

John Backmon age 49. /s/ John Backmon

CAUSE HEARD: 19 March 1867. Aletha Graham died before testator... law as it then existed, legacy to her lapsed. James Roberts, the testator, died intestate.

By laws of descent, title to 1/6 of land in controversy passed to his heirs, and that children of Aletha Graham are entitled to 1/8 of 1/6.

Ridley Roberts and Elizabeth Holeman are entitled to 1/8 of 1/6.

M. C. McKinley under purchase and deed is entitled to the interest of

Celina Sadler

Lettie Buchanan

Patsy Sadler

Zadock B. Roberts

Buchanan W. Roberts

ANSWER of James Sadler and wife Martha Sadler to Bill of Complaint of Jared H. Graham and others... parties named in bill are children and grand children of James Roberts, who died about 1842 leaving to his wife Letty the whole of his estate real and personal during her lifetime. The mother of complainants Letta Graham died several years before said Roberts. At the death of the widow all personal property was sold.

ANSWER: Matthew C. McKinley to Bill of Complaint of Jaret H. Graham, James R. Graham, Thos R. Graham, Frederick H. Graham and Michael Graham.

James Roberts died in Jackson Co, TN, will proved October 1840. Said Roberts had daughters Elizabeth who married James Holiman and Aletha married John Graham. Elizabeth and Aletha died several years before their father.

Elizabeth [nee Roberts - mlj] Holiman left children

George Holiman and

William Holiman, defendants named in this bill and also many other children that are not named, viz

Letty the wife of Gideon Mahan

Candis the wife of Benjamin Burton

Alexander Holleman

Granville Holleman

Shepherd Holleman, all of Jackson County, Tennessee and

James Holleman of parts unknown.

Aletha [nee Roberts - mlj] Graham left children surviving her

Jaret H. Graham

James R. Graham

Frederick H. Graham

Thomas J. Graham and

Michael Graham named as Complainants and

Hannah Graham named as Defendant.

It is not believed Hannah Graham is or was a minor at the commencement of this suit.

James Roberts had three other daughters,

Celina [nee Roberts - mlj] the wife of John K. Sadler,

Patsy [nee Roberts - mlj] the wife of James Sadler,

Letty [nee Roberts - mlj] the wife of James Buchanan

and three sons

Ridley Roberts

Zadock B. Roberts

Buchanan W. Roberts.

All survived him except Aletha and Elizabeth. The will was dated 17 August 1835 and James Roberts died about 28 August 1840. Will proved in Jackson County October 1840. The bill stating James Roberts died 1842 is false.

Respondent states about the fall of 1846 after the death of Testator's widow, he purchased certain interests in land which James Roberts died seized and possessed, except the place where White Myers lived in 1853, which had been sold by court order. 13 January 1857. /s/ M. C. McKinley

AMENDED BILL OF COMPLAINT: Graham heirs of Aletha [nee Roberts] Graham, all citizens of Marion County, Tennessee against all defendants in original bill and... [all of Elizabeth Holleman's heirs not in original bill are now included, all of Jackson Co. except James Holleman of parts unknown - mlj].

END OF REEL #78.