Jackson Co., TN Loose District/Chancery Court Papers
Reel #90, Lawless, - Loftis
Vol: 1839-1915

Cases indexed alpha by Plaintiff. Although there is a cross-index reel at TSLA by Defendant, there is no 'everyname index', so there is no hint of what reel actually contains. Genealogical extractions in order they appear on each case. Sometimes depositions not dated. The purpose is not to find who did what to whom, but how they were related. 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

Deposition taken: no date, filed Oct. 14, 1911.

DEPOSITION: G. G. HAILE.

I have been practicing law about thirty years.

/s/ Geo. G. Haile

Deposition taken: no date.

DEPOSITION: HARLAN LAWLESS.

I am one of the parties to this [suit] and a son of Thomas Lawless, deceased, and a brother of J. P. Lawless. My father has been dead about eight years I think.

I am 49 years old.

Quest. How many children and heirs at law did your father have at the time of his death? State their names and residence as near as you can.

Ans. There was ten children in all. William, who is dead, leaving two living children. I don't know their names, of Jamestown [?] Kentucky, Granville, Mayfield Kentucky, Jessie Lawless, Van Buren Arkansas, Millard Lawless who lives here near Gainesboro. Belle Lawless also lives here. Harlin Lawless who lives here. Jim Lawless who is now dead. Luther Lawless. Texas Branch. One died when he was small. Sarah Lawless, making ten in all and two of them dead leaving no heirs which left eight living at his death.

Quest. Do you know the lands in the pleadings?

Ans. Yes, Sir. I guess I have known it and have lived on it ever since my father and Jess Lawless bought it, which has been something like thirty years.

Quest. When did J. P. Lawless leave this county?

Ans. He has been left about twenty odd years. He came back once on a visit while he lived in Kentucky, which was a short time after he first left, and he has never been back since . . . His part of the land was sold for his debts and Alex Hawkins bought it. My father, Thomas Lawless, redeemed said land. He borrowed the money of the Sparta Bank with which to redeem it.

. . . the time Jess left, 1885 . . .

/s/ Harlin Lawless

DEPOSITION: LUTHER LAWLESS.

I am 41 years old. I live in this district and a farmer.

I am a son of Thos. Lawless and brother of Jess Lawless.

[My father] died in Feb., 12th day 1902, eight years ago.

Quest. You are the same Luther Lawless that married a woman that was pregnant by another man, and you lived with her, didn't you?

Ans. Yes, Sir. I married a woman in that condition but I didn't know it at the time and when I found it out I left her, and my friends persuaded me to go back to her and I did so, and lived with her as long as she lived, and she was a nice woman as long as I lived with her.

/s/ Luther Lawless

DEPOSITION: WILLIAM S. BRANCH.

I am 35 years old and I am a farmer.

Quest. Are you a party complainant in this suit, and husband of Texas Branch . . .?

Ans. Yes, Sir.

Quest. How long have you been married?

Ans. I have been married 13 years this Nov. if I am not mistaken.

Avo Lawless, son of J. P. Lawless . . .

/s/ W. S. Branch

REPORT OF THE CLERK & MASTER.

1 Dec. 1910.

Summary: those entitled to share in the distribution of the Thos. Lawless land fund:

Granville Lawless, a son.

Harlin Lawless, a son.

Luther Lawless, a son.

Bell Lawless, a daughter.

Sarah Lawless, a daughter.

Texas, a daughter who intermarried with Wm. Branch.

Millard Lawless and Jess Lawless, two sons who sold their shares to J. A. Montgomery and D. B. Johnson.

Wm. H. Lawless, a deceased son who left surviving him three children, Clenny who intermarried with Ed Sidwell, Otha Lawless and Lena Lawless. Clenny Sidwell is dead, leaving surviving her two children, Uri O. Sidwell and Nettie Sidwell.

Depositions taken: 19 Aug. 1909.

DEPOSITION: JOHN MANARD.

I am 48 years old I suppose. I live in the 13th District of Jackson Co.

Rented some of the Lawless land in 1890. -bp.

/s/ J. H. Maynard

DEPOSITION: JIM TROBOUGH.

I am nearly 72 years old. I live in the 13th District of this county.

I just rented a house [from Thomas Lawless], that is, me and John Maynard rented the house and John rented the land and we lived there together in the house. [He doesn't remember the year. -bp.]

John got sick and didn't cultivate it.

I got sick myself.

James Trobaugh (his mark)

DEPOSITION: JOE WHITAKER.

I am 30 years old. I live in the 1st District of this county.

I have lived on the farm adjoining the Thomas Lawless heirs for many years.

Quest. What are you following for a livelihood?

Ans. First one thing and another.

/s/ Joe Whitaker

DEPOSITION: JOHN JACKSON.

I live in the 1st District of Jackson Co.

Quest. Where did you move to when you left the Free State?

Ans. I moved on Roaring River with Wash Chapman. I lived there on his land two years I think. I moved from there up to what is the Alice Chapman place.

I have been away [from the Free State] some 17 years . . .

John Jackson (his mark)

DECREE, TENNESSEE COURT OF CIVIL APPEALS.

4 Jan. 1912.

. . . there is no reversible error in the decree of the Chancellor, dismissing the original bill and the amendment thereto; and sustaining the cross-bill of J. A. Montgomery & D. B. Johnson . . .

An excellent typewritten summary of the case follows. -bp.

AFFIDAVIT.

18 Jan. 1924, Russell Co. KY.

James M. Selley testifies that U. O. Sidwell is at least 26 years old. -bp.

POWER OF ATTORNEY.

12 June 1923, Mason Co. Illinois.

. . . I, Nettie Sidwell, now Nettie Sidwell Neely, of Mason Co. Illinois, a daughter of Clennie Sidwell and grand-daughter of Thomas Lawless . . .

POWER OF ATTORNEY.

18 Jan. 1924.

. . . I, U. O. Sidwell of Esto, Russell County, KY . . .

POWER OF ATTORNEY.

30 Jan. 1915, Russell Co. KY.

We, Granville Lawless and Otha Lawless . . .

Deposition taken: no date.

CROSS-EXAMINATION: M. F. LAWLESS.

/s/ M. F. Lawless

[New folder, but continuation of the previous case. -bp.]

DEED.

5 Nov. 1907.

Summary: J. P. Lawless of Van Buren, Arkansas, sells to J. A. Montgomery & D. B. Johnson, for $100, the interest he has in a tract of land he purchased with his father, Thomas Lawless, located in District 1 in Jackson Co. TN, beginning at the mouth of Hunter's branch and containing about 162 1/2 acres. He also conveys his rights in his deceased father's portion of this land.

/s/ J. P. Lawless

/s/ A. S. Lawless

Deposition taken: 24 Aug. 1909.

DEPOSITION: J. P. LAWLESS.

I am 56 years old and resided in Van Buren, Arkansas. I am a farmer by occupation.

I have lived in Arkansas for the past 19 or 20 years. I once lived in Tennessee. I left there about 1887.

Quest. Did you and your father, Thomas Lawless, buy a tract of land in the Free State from the Woodfork [Woodfolk] estate, on Cumberland River near the Free State?

Ans. Yes.

I received a letter from my mother, Amanda Lawless, dated Gainesboro, Nov. 1902 . . .

Deposition taken: no date.

DEPOSITION: D. B. JOHNSON.

/s/ D. B. Johnson

DEPOSITION: J. A. MONTGOMERY.

The conversation took place on the street of Gainesboro just a little above Quarles' Saddler and Quarles' Dry Goods Store, between that store and L. Washburn's Dry Goods Store.

/s/ J. A. Montgomery

REPORT OF LAND SALE.

12 Nov. 1910.

Summary: Sold to J. A. Montgomery and D. B. Johnson, for $500, the Thos. Lawless home tract involved in this case (Luther Lawless et. al. vs. J. A. Montgomery, et. al.) -bp.

ORDER OPENING BID.

No date, entered 10 Dec. 1910.

Summary: Petition asks that the $500 bid be set aside. The complainants offered a bond putting the bid at $600. The Court ordered that the sale to Montgomery & Johnson be set aside and the biddings be re-opened. -bp.

Deposition taken: 23 Oct. 1909 at Van Buren, Arkansas.

DEPOSITION: A. S. LAWLACE [LAWLESS].

Age 26.

Quest. Are you a son of J. P. Lawlace [Lawless] and grandson of Thos. Lawless, dec'd?

Ans. Yes.

/s/ A. S. Lawless

Deposition taken: 28 Aug. 1909.

DEPOSITION: OLIVER TATE.

I am 49 years old. I live in the First Civil District of this county.

I live on [part of the Thos. Lawless land] about 1894 or 1895. I was not to pay any rent. I built a house on it and was to have the use of the house and garden two years for furnishing the material and building it.

/s/ J. O. Tate

Depositions taken: no date.

DEPOSITION: MILLARD LAWLESS.

I am 55 years old and I reside in this District and what is known as Free State. I am a son of Thomas Lawless and a brother of J. P. Lawless.

Quest. State whether or not Thomas Lawless sold you a part of J. P. Lawless' land . . .

Ans. He sold me half the Jess Lawless tract. He told me that he had a right to sell it; that Jess had made him a Power of Attorney.

It has been something like 23 or 24 years since I bought the piece I purchased of Thomas Lawless.

/s/ M. F. Lawless

DEPOSITION: FOREST HAWKINS.

I am 26 years old and am a farmer. I live in the 14th District of Jackson Co.

I cultivate the place [the Short Hollow tract] two years, lived on it four years . . . I rented it from Harlin Lawless in 1902 . . .

/s/ W. F. Hawkins

Depositions taken: 18 March 1910 at Van Buren, Crawford Co., Arkansas.

DEPOSITION: J. P. LAWLESS.

/s/ J. P. Lawless

DEPOSITION: AVO LAWLESS.

/s/ Avo S. Lawless

Deposition taken: no date.

DEPOSITION: W. S. BRANCH.

/s/ W. S. Branch

THE BILL OF COMPLAINT OF HARLIN LAWLESS ET. AL. VS J. A. MONTGOMERY, ET. AL.

Jan. 1908.

Thomas Lawless departed this life in 1902 and his widow survived him until March 1907 when she died.

At the time of his death said Thomas Lawless was seized and possessed and the owner in fee of the following described tracts or parcels of land, to wit, first tract, bounded on the North by the lands of J. A. Montgomery, on the East by Cumberland River, on the South by the lands of Millard Lawless and on the West by the lands of T. G. Smith and Curry Hawkins, containing by estimation 60 acres more or less. Second tract known as the Short Hollow tract, bounded on the North by the lands of Millard Lawless, on the East by Cumberland River, South by the lands of W. H. Dudney and on the West by the lands of Curry Hawkins and Thomas Fuqua, containing 50 acres more or less.

MORTGAGE DEED.

11 Oct. 1888.

Summary: Thomas Lawless mortgages one large yoke of oxen, his entire crop of tobacco, being about 3000 pounds & about 50 barrels of corn to L. S. Anderson, to cover a note executed this day at the Sparta Bank for $160.00.

/s/ Thomas Lawless

DECREE FOR DIVORCE.

Stanton Hunter and Nannie Hunter.

8 Dec. 1910.

Divorce granted on grounds that she deserted him and refuses to live with him. This document seems to be misfiled. -bp.

AGREEMENT.

23 July 1910.

Summary: it is agreed that the lands mentioned and described in the pleadings in this case are all covered by and included within the boundaries of Grant No. 935, issued by the State of North Carolina, to one James Gloster Brehan, assignee of Thomas Joiner, on the 18th day of May 1789. -bp.

THE ANSWER OF J. A. MONTGOMERY & D. B. JOHNSON to the Amended Bill filed against them.

Respondents here insist that Thomas Lawless, as the agent and trustee of J. P. Lawless, entered into the possession of said tract of land under a power of attorney executed by J. P. Lawless to said Thomas Lawless, which is set out in the pleadings in this cause, under which Power of Attorney Thomas Lawless took possession of said tract of land about the year 1887 and continued his possession as the agent and trustee of J. P. Lawless; the said J. P. Lawless being a nonresident. That the said Thomas Lawless continued his possession under said Power of Attorney until his death in the year 1902, and complainants have recognized and acknowledged the title of J. P. Lawless since the death of Thomas Lawless and prior thereto by repeated propositions to purchase said tract of land from J. P. Lawless.

Deposition taken: 26 Nov. 1909.

DEPOSITION: JAMES COFFEE.

I am about 70 years old and I live in the First District of this County and I am a farmer.

He says he rented land from Thomas Lawless. -bp.

I lived there three years. It has been about fourteen years since I moved from there.

James Coffee (his mark)

Deposition taken: no date, filed 26 Aug. 1909.

DEPOSITION: W. W. DRAPER.

I live at Gainesboro TN and am a lawyer by profession and was appointed Deputy Clerk and Master in Feb. 1888 and served until H. W. Williams went out of office, in 1889, I think.

/s/ W.W. Draper

SALE ON OPENED BIDDINGS.

10 Dec. 1910.

The Thomas Lawless home tract was sold to J. A. Montgomery & D. B. Johnson for $1040.00.

Deposition taken: 2 Sept. 1909.

DEPOSITION: TECKLEY BRANCH.

I am going on 38 years of age.

I am a daughter of Thomas Lawless, deceased, and a sister of Jessie Lawless.

I am married to W. S. Branch and I have been married something like 13 years.

Quest. Where have you lived for the past twenty years?

Ans. Part of the time I have lived where I now live, on a part of the Thomas Lawless home place and part of the time I have lived in the Haile hollow and part of the time in the Scott hollow.

/s/ Teckley Branch

Depositions taken: 7 Sept. 1907.

DEPOSITION: A. B. LAWLESS.

I am 53 years old. I live on the Thomas Lawless home place in the 1st District of this county. I am a daughter of Thomas Lawless, deceased, and a sister of J. P. Lawless.

[My father] died in Feb. 1902.

Quest. Who cultivated the Short Hollow tract . . .?

Ans. Jim Coffee cultivated it a while but I don't know how long. Forest Hawkins lived there four years, but he didn't cultivate it all by himself. John Maynard lived there a while, but I don't know if he cultivated it or not.

Mother . . . died in 1907.

/s/ A. B. Lawless

MORTGAGE DEED.

18 Sept. 1900.

Summary: Thomas Lawless and his wife Amanda Lawless mortgage forty acres to pay a debt they have of $40.00 to a firm of merchants and a debt their son, H. Lawless, has of $44.65 to Butler & Montgomery, a firm of lawyers, by a Judgement. -bp.

Deposition taken: 10 Aug. 1909.

DEPOSITION: T. G. SMITH.

I am 67 years old. I live in the 1st District of this county and am a farmer.

I knew [Thomas Lawless] in his lifetime and we lived about 3/4 mile apart.

/s/ T. G. Smith

Deposition taken: 11 Aug. 1909.

DEPOSITION: M. A. PATTERSON.

I am 48 and am a farmer. I live on Buck branch in the 1st District of Jackson Co. I live in about a mile of them [the Thomas Lawless family].

M. A. Patterson (his mark)

Depositions taken: 12 Aug. 1909.

DEPOSITION: J. G. DUDNEY.

My age is 59 years and am a farmer. I live in the 1st Civil District of this county in the Free State.

/s/ J. G. Dudney

DEPOSITION: J. R. FUQUA.

I am 75 years old. I live in the Free State in this 1st District and am a farmer.

I know the land [in dispute]. I have known it for forty years. I live about 1/2 mile of it.

J. R. Fuquay (his mark)

THE PETITION OF FOBY JANE LAWSON VS. P. R. HOOVER, both of Jackson Co. TN.

24 Jan. 1895.

. . . W. T. Lawson departed this life intestate in Jackson Co. TN on [blank] the [blank] 1894, leaving surviving him your Petitioner as his lawful widow and also four minor children, to wit, Thomas Lawson, Sherman Lawson, Sallie Lawson and Nancy Lawson. The said W. T. Lawson in his lifetime was the owner in fee simple of the following described tract of land lying in the 11th Civil District of Jackson Co. TN, on the water's of Flynn's creek and bounded as follows . . . north bank of Flynn's creek, J. M. Johnson's corner . . . the farm that James E. Wheeler died possessed of . . . White's Bend School House . . . Edward Pate's line . . . containing fifty acres, more or less.

. . . the defendant P. R. Hoover swore [?] out a writ of unlawful detainer against your Petitioner . . . Justice Ragland . . . gave Judgement in favor of said P. R. Hoover and against your Petitioner for said premises . . .

Faby Jane Lawson (her mark)

ORDER TO THE SHERIFF.

11 Jan. 1895.

Summary: the land described in the above Petition is said to belong to P. R. Hoover, and was rented to Albert Pate for the year 1894.

GRAND JURY FINDING.

March Term 1895.

. . . present that D. B. Johnson, Feriba J. Lawson and Thomas Lawson, on the first day of Feb. 1895, in the County and State aforesaid, did unlawfully, knowingly and willfully oppose and resist one W. T. Davis, Constable of Jackson Co. TN, in serving and attempting to serve a certain writ of possession . . . and to remove the said Feriba Jane Lawson . . .

DEED.

18 April 1856.

Summary: Curry Lee sells to John Lee, for $1000, two tracts of land.

First tract, in Jackson Co. TN on Blackburn's fork of Roaring River, Beginning at a stake at or near Nimrod Johnson's South boundary line . . .crossing said fork . . .southeast corner of a 640 acre tract granted to Sampson Williams . . . southwest corner of a 50 acres survey in the name of John Stafford . . . boundary line of Jessee Gentry . . .which tract of land was granted to Curry Lee by the State of TN on 8 May 1857 by Grant No. 5176, which includes "four several tracts" containing 120 acres and which was also deeded to Curry Lee by John C. McCruon by his attorney in fact Sam G. Smith on 11 July 1828, containing 200 acres.

Second tract, also in Jackson Co. TN and adjoining the above described tract, Beginning . . . boundary line of a forty acre survey granted by the State of TN to McCernan . . . dividing ridge between Benjamin Flatt and Curry Lee . . . boundary of a 300 acre survey of said Flatt's . . . crossing Blackburn's fork . . .a forty acre survey in the name of McCleran called the lower 40 acre tract . . . containing 100 acres, which tract Curry Lee purchased of Benjamin Flatt on 5 June 1855.

Witnesses: A. H. Morgan and Marien Morgan. -bp.

DEED.

Oct. 1863.

Summary: Rufus H. Allen of Jackson Co. TN sells to William B. Allen also of Jackson Co. TN a parcel of land lying in Jackson Co. TN in Civil District No. 9 on both sides of Blackburn's fork of Roaring River, bounded . . . Jones Mercer's tract on which he now lives . . . survey in the name of Sampson Williams . . . survey in the name of John Stafford now owned by Daniel Johnson . . . Maberry's corner . . . survey in the name of Benjamin Flatt . . . small tract of about 1 1/4 acres conveyed to Labon Loftis by John Lee . . . containing 136 acres. The amount of the consideration is blank, as is the day of the deed. -bp.

Deposition taken: 25 Nov. 1881.

DEPOSITION: ASA JOHNSON.

Aged 49 years.

It was just a few days before John Lee started off South the last time, from which he never returned. I think it was in the fall of 1865.

I heard that Lee was insolvent. I understood that he owed considerable money when he left this country.

My understanding is that he died in the fall of 1865 . . .

/s/ Asa Johnson

SETH MABERRY'S FAMILY RECORD.

[This was found in the papers of Daniel M. Morgan. Evidently written in preparation of a suit involving Seth Maberry. -bp]

Seth Maberry & Rebeckah T. Allen was married March [date is blank] 1844.

Seth Maberry was born July 10, 1817.

Rebeckah T. Maberry was born April 22, 1820.

Sarah J. Maberry was born Jan. 13, 1845.

Jesse C. Maberry was born Dec. 11, 1846.

Austin H. Maberry was born May 4, 1849.

Robert N. Maberry was born Nov. 11, 1851.

Martha J. Maberry was born March 8, 1854.

Amanda M. Maberry was born July 11, 1856.

Nancy A. Maberry was born Dec. 18, 1863.

Written by Dan'l M. Morgan, Feb. 13, 1868.

Deposition taken: 16 Jan. 1882.

DEPOSITION: A. H. MORGAN.

I am 68 years of age. I live in Jackson County on Roaring River. I have lived here all my life.

He says he is Austin H. Morgan. -bp.

I did agree for John Lee to redeem the land. John Lee got the land back by giving me a Deed of Trust on the land. Dr. Kenar [Kenner] was the Trustee.

W. R. Kenar [Kenner] sold the land and I became the purchaser.

Quest. State whether or not John Lee ever redeemed said land under said sale made by Trustee Kenner.

Ans. He never did.

I sold the land to R. W. Allen.

He, Allen, made himself responsible for all the debts that was on the land at the time.

I think, outside of Col. Murray's fee, the liability on the land was $700 . . .

/s/ A. H. Morgan

FINAL DECREE.

21 March 1882.

. . . complainants intestate and ancestor, John Lee, deceased, sold the lands in the pleadings described to defendant R. W. Allen on the first day of April 1863 at the price of $10 per acre to be paid in Confederate Treasury Notes or the currency of the Country when the same should thereafter be surveyed. That on said day the parties entered into a written contract or agreement signed by both of them which the Court holds to have been upon said Lee's part a Title Bond. That thereafter said Allen paid to Lee $3000 on said contract and took his receipt for the same, leaving the balance to be ascertained, if any, by a Survey of said lands.

Summary of remainder: a survey was made 1 Oct. 1865, the number of acres of the tract of land was determined to be 375, amounting to $3750, leaving $750 unpaid. Allen attempted to pay this in Confederate money, which Lee refused. A. C. Lee is the Administrator of the estate of John Lee. The sum of $750 plus interest remains due and unpaid and is a lien on the lands. The Court orders that A. C. Lee recover this amount from Rufus W. Allen.

The Court orders the sale of the land to pay this, plus Court costs. -bp

Deposition taken: 4 March 1882.

DEPOSITION: J. M. MORGAN.

Aged 48 years.

I am a son of Daniel M. Morgan. He died Aug. 19, 1872.

/s/ J. M. Morgan

QUIT CLAIM DEED.

23 Aug. 1865.

I, Austin Morgan, hereby quit claim to Rufus W. Allen all my interest in the following described tracts of land, lying in Jackson Co. TN in District No. 9 on Blackburn's fork of Roaring River, to wit, First Tract . . . Nimrod Johnson's (now William Johnson's) South boundary line . . . 640 acre tract Granted to Sampson Williams . . . 50 acre survey in the name of John Stafford . . . 50 acre survey in the name of Jessee Gentry . . . which tract of land was Granted by the State of TN to Curry Lee, on 8 May 1837 by Grant No. 5176, which includes four several tracts containing 120 acres and which was also deeded to Curry Lee by John C. McCruous by his attorney-in-fact Sam G. Smith on the 11th day of July 1828, containing 200 acres.

Second Tract, lying and joining the above . . . boundary line of a 40 acre survey Granted by the State of TN to McCown . . . 300 acre survey of Ben Flatt's, now Robert Allen's . . . crossing Blackburn's fork to the southwest corner of a 40 acre survey made in the name of McClennen, called the lower 40 acre tract . . . containing 100 acres, which tract was purchased by Curry Lee of Benjamin Flatt on 3 day of June 1855.

s/s A. H. Morgan

Depositions taken: 1, 2 & 3 Feb. 1882.

DEPOSITION: DAVID JOHNSON.

I am 50 years old.

He knew John Lee and R. W. Allen all of his life. The land in dispute joins his land. -bp.

I was in the war when Lee run the land [did the survey]. . .

/s/ David Johnson

DEPOSITION: WILLIAM GORE.

I am a practical surveyor.

/s/ Wm. Gore

DEPOSITION: SETH MABERRY.

I am 60 years old. John Lee and I was raised up boys together . . . I have known R. W. Allen ever since he was a boy.

I think he [W. B. Allen] died in April 1864.

I think I moved there [where he now lives] in 1859 . . .

Bart Allen [W. B. Allen] died in April 1864.

He died on Blackburn's fork, on the land that we run out [surveyed] to him.

Quest. Who claims that land since his death?

Ans. His widow occupied it until she sold it to George Allen, son of R. W. Allen.

Seth Maberry (his mark)

DEPOSITION: WILLIAM JOHNSON.

Aged about 65 years.

William Johnson (his mark)

DEPOSITION: THOMAS W. BERTLIN.

62 years old.

I am Clerk of the County Court of Jackson Co. TN, was appointed about 7 March 1881.

/s/ T. H. Bertlin

DEPOSITION: AUSTIN H. MORGAN.

68 years old.

/s/ A. H. Morgan

Depositions taken: 22 & 23 Feb. 1822.

DEPOSITION: T. J. LANGFORD.

I reside now in Jackson County. When the land was surveyed I lived in Overton County, a distance of about eight miles from the land.

I lived in Jackson County part of the time and balance in Overton in 1865.

Quest. Was not said land surveyed out after John Lee came home out of the Federal Army?

Ans. I don't recollect. I don't know whether he was in the Federal Army.

/s/ T. J. Langford

DEPOSITION: R. W. ALLEN.

53 years old.

I am the R. W. Allen defendant to this suit.

I have had continuous possession of the 75 acres asked of ever since I purchased of Lee.

After I found out that John Lee had no title to it, I entered it and got a Grant for it.

/s/ R. W. Allen

DEPOSITION: JAMES TERRY.

Aged 66 years.

I am acquainted with R. W. Allen and have known him all his life.

I lived on Roaring River in 1865, in the neighborhood of Lee and R. W. Allen, about 1 1/2 miles from them.

/s/ James Terry

DEPOSITION: GEO. M. PETTIE.

It was directly after I came back from Illinois and that was in Sept. 1865.

/s/ G. M. Petty

DEED.

Copy from Deed Book B, page 336.

No. 1879. 200 acres, Curry Lee, Cyrus Jackson Assignees of Duke Allen, surveyed 18 March 1838.

. . . boundary line of a 50 acre survey made in the name of Jesse Gentry . . . crossing the road that leads from the mouth of Blackburn's fork by the way of Dodson's Branch Meeting House . . . boundary line of a 100 acre survey of Rebecca Allen's . . . Rebecca Allen's 100 acre tract, No. 1874 [or 774 -bp], dated May 24th 1832. Surveyed 20 Feb. 1836 . . . southeast corner of a tract of land of the said Rebecca Allen's and in the north boundary line of a survey of Mounce Gore's . . . Book C, page 204 [or 264 -bp].

THE BILL OF COMPLAINT OF ANDREW C. LEE, who sues in his own personal right and as Administrator Debones non of John Lee, deceased, Adaline Lee, widow of said deceased, Curry Lee, Margarett Allen and her husband Columbus Allen, John W. Lee, Hessie Lee and William R. Lee, all of Jackson Co. TN and Asa T. Lee of the State of Missouri, complainants, of whom Hessie and Wm. R. are minors and sue by their next friend Andrew C. Lee, against Rufus W. Allen of Jackson Co. TN.

No date.

. . . on the 17th day of March 1867 John Lee died intestate in the State of Georgia.

. . . complainant Adaline Lee is the widow of said deceased. Your orator Andrew C. Lee and other complainants above mentioned, except the husbands of married women and said widow, are the only children and heirs at law of said deceased.

AMENDMENT TO ORIGINAL BILL.

22 April 1915.

Summary: she asks that her name be changed from Hallie Avo Lee to her maiden name of Hallie Avo Collier.

She is informed that her husband is "not just right mentally".

/s/ Hallie Avo Lee

THE BILL OF COMPLAINT OF HALLIE AVO LEE OF JACKSON COUNTY TN AGAINST ELLIE LEE OF CHICAGO, ILLINOIS.

3 March 1915.

. . . she and defendant were married in Jackson Co. TN on the 26th day of Feb. 1915.

Summary: they lived together about 24 hours, when defendant left and told a relative he might not ever hear from him again. She is 14 years old. They had only been acquainted about one week. Defendant is a man of 40, has had two previous wives, who are still living. This marriage was bitterly opposed by her parents.

She believes he has $430 in the Bank. She wants that attached for alimony. She believes he is going to Chicago. She asks for divorce.

/s/ Hallie Avo Lee

THE BILL OF COMPLAINT OF CURRY LEE of Jackson Co. TN against Thomas H. Butler, Austin H. Morgan, Curry Lee, Polly Lee, Margaret Lee, Asa Lee, John Lee, Rufus Allin & William R. Kenner of Jackson Co. TN, Andy Lee of Overton Co. TN, Adaline Lee, Hessee Lee & Russel Lee of the State of Georgia, W. H. Botts of the State of Kentucky.

No date.

John Lee departed this life intestate on the 1st March 1867 in the State of Georgia. At the time of his death his residence was in Jackson Co. TN.

. . . Thomas H. Butler was appointed Administrator . . . Adeline Lee is the widow and relict of said deceased. Curry Lee and Margaret Lee are the adult children of said deceased. Defendants Polley Lee, Asa Lee, Hessee Lee are the minor children of said deceased and have no guardian. These defendants are all the children of the deceased. Your orator states to your Honor that said deceased owed him on the 1st day of Aug. 1860 the sum of $703.27 . . .

Deposition taken: 3 Feb. 1870.

DEPOSITION: BENJAMIN CHAPMAN.

Aged 55 years.

I am acquainted with Curry Lee and have known him since the days of boyhood.

Benj. Chapman (his mark)

THE BILL OF COMPLAINT OF WILLIAM HARRIS AGAINST JOHN LEE, both of Jackson Co. TN.

6 Aug. 1860.

. . . defendant John Lee is indebted to him by Judgement . . . 1859 in the sum of about $140 . . .

. . . said Lee is in embarrassed circumstances, perhaps insolvent . . .

. . . sale of a Negro woman made by defendant Lee to said [Wm. R.] Kenner.

Your orator believes the Negro really belongs to defendant Lee and that when sold her proceeds will be more than sufficient to pay the debts . . . The Negro's name is Emily. She is about 26 years old . . .

Deposition taken: 28 Jan. 1870.

DEPOSITION: A. H. MORGAN.

/s/ A. H. Morgan

DEPOSITION: R. K. LEE.

Aged 30 years.

Curry Lee is my father and John Lee was my brother.

I don't know of my own knowledge that John Lee is dead. It is the understanding in our family that he is dead. I read a letter from his sister-in-law stating that he was dead.

/s/ R. K. Lee

FINAL SETTLEMENT.

Feb. Term 1883.

Rents of land belonging to ward: $66.66.

CHANCERY, 1843.

CONTRACT.

8 [?] July 1841

Summary: Sam E. Stone sells to Abraham Lee a tract of land lying in Jackson Co. TN on the North Side of Cumberland River on Cub creek . . .boundary line of Alexr. Miller's 50 acre tract . . .containing 50 acres and occupied by Sanders Sisco and formerly owned by Sanders Sisco, for a note of $159 due in two years. Sam E. Stone will give Lee a deed when the note is paid. -bp.

s/s Sam E. Stone

DEED.

7 Sept. 1840.

Summary: John Sisco sells to Abraham Lee, for $100, a tract of land in District No. 2 of Jackson Co. TN, containing 25 acres . . . fork of Bullard's creek . . . James W. Draper's east boundary line . . . and one other tract containing 11 acres . . . William Ray's west boundary line . . . More's north boundary line . . . James W. Draper's east boundary line . . . John Lock . . . -bp.

s/s John W. Sisco

Witnesses: Russel M. Kainard & John Swezea

CONTRACT.

28 Sept. 1841.

Summary: Abraham Lee sells to James R. Clark a parcel of land in Jackson Co. TN on the North Side of Cumberland River on Cub creek containing 50 acres and occupied by Sanders Sisco, formerly owned by Sanders Sisco, paid for with a note for $159, due 1 July 1843. When this note is paid, Lee will give Clark a deed for the land. -bp.

s/s Abraham Lee

DEED.

March 1840.

Summary: William Brooks sells to Abraham Lee, for $44, a tract of land bounded . . . William Scanland's west boundary . . . Lee's tract . . . Moor's old tract . . . containing about 22 acres. -bp.

Witnesses: Alfred [?, partially obscured by inkblot] M. Lee, John Lee (his mark).

CLERK & MASTER'S SALE OF THE LAND OF ABRAHAM LEE, DEC'D.

11 June 1844.

Summary: the 100 acre tract, the 27 acre tract, the 22 acre tract, and the 40 acres bought by Richard P. Brooks for $221. The 40 acre tract bought by James W. Draper for $58 and the tract sold by Sam E. Stone to Abraham Lee was repurchased by Sam E. Stone for the price of $82.00. -bp.

THE BILL OF COMPLAINT OF DANIEL LEE OF JACKSON CO. TN.

No date.

. . . about the 15 Feb. 1842 Abraham Lee departed this life intestate in said County and at March Term 1842 of the County Court of said County your orator was duly appointed by said Court Administrator . . .

The assets of the estate are insufficient to pay the debts of the estate. -bp.

Your orator also states that said Abraham Lee left his widow named Polly and his children Joel, Pryor, Sarah, Eliza, William, his heirs and distributees; the children are all minors . . .

The mansion house and outhouses are on the tract conveyed by William Ray . . .

JOHN KERNALL CREDIT 1840.

Jan. 1, Credit on a settlement for work. $5.00

July 20, 1841. Credit to 10 hundred and 50 bundles of oats. $10.75.

Sept. 1. Credit to 200 bundles of fodder. $ 2.00.

Sept. 10. Credit to the 6 part of a small piece of [unreadable]. $1.00.

Nov. 22. Credit to 11 barrels and 5 bushels of corn $12.00

Account of Lost Time of Work.

May 5. To 5 days lost time when his wife was sick. $1.87.

Sept. 5. To 8 days lost time when his father died. $3.10.

Sept. 13. To 1 day lost time at George Ray's. $0.37.

Sept. 20. To 1 day lost time when William Huffines was sick. $0.37.

Oct. 2. To 1 day lost time. $0.37.

Oct. 4. To 1 day lost time going to Gainesboro. $0.37.

Nov. 3. Did continue-business.

Nov. 15 & 16. Work two day.

Oct. 20. To a day lost time seeing of wheat at MacCauley.

Accounts for lost time. $9.85.

DEED.

5 Dec. 1840.

Summary: George Ray sells to Abraham Lee, for $100, a tract of land in Jackson County TN in District No. 2 containing 40 acres . . . east boundary line of a 50 acre survey that George Ray bought of Leonard Keeling . . . William Brooks line . . . -bp.

s/s George Ray.

Witnesses: Pleasant Henley, David Ray (his mark).

DEED.

21 Sept. 1839.

Summary: William Ray of Jackson Co. TN sells to Abraham Lee, also of Jackson Co. TN, for $300, a tract of land in Jackson Co. TN on the North Side of Cumberland Rive on a branch of Bullard's creek . . . Moor's north boundary line . . . containing 100 acres, including the improvement where William Brooks resides. - bp.

William Ray (his mark)

Witnesses: Wm. Scanland, William Brooks.

ANSWER OF JOHN H. PYRON TO A BILL OF COMPLAINT FILED BY JAMES H. LEE.

4 June 1855.

. . . some short time previous to the 1st of April 1853, respondent, William D. Pyron and complainant made an agreement to sell goods in partnership and it was agreed between said partners that respondent should purchase one acre of land from Cicero L. Murphy at or near the mouth of War Trace creek in the County of Jackson, on which to carry on their business and trade as merchants . . .

. . . the 8 day of March 1854, when respondent and said William Pyron sold said complainant their entire stock, the goods, notes and accounts, of said partnership . . .

Deposition taken: 9 July 1851.

DEPOSITION: JOHN H. SAVAGE.

/s/ John H. Savage

Deposition taken: no date.

DEPOSITION: G. W. MC WHIRTER.

/s/ G. W. McWhirter

Deposition taken: 14 Jan. 1851.

DEPOSITION: DAVID G. SHEPHERD.

Aged about 46 years.

. . . the Store of D. G. Shepherd . . .

/s/ D. G. Shepherd

Deposition taken: 12 Sept. 1850.

DEPOSITION: ALBERT STANTON.

Aged about 40 years.

/s/ Albert Stanton

DEED.

25 Feb. 1889.

Note: the handwriting in this document is very hard to read. The name Stout throughout appears to be Stoubt. -bp.

Summary: Robert Stout, Wm. Stout & Allen Sadler & wife Margaret Sadler, heirs at law of Charlotty Stout, sell to J. M. Lee, for $50 per share, their undivided interest in the lands of said Charlotty Stout, the lands lying in Jackson Co. TN and known as the old George Stout tract, and bounded on the North by Walker Vinson & G. W. Stout, East by G. W. Stout & Mrs. Deckard, South by Vitatoe, West by Wm. Stout.

Signed by mark: Robert Stout, Wm. Stout, Alen Stout, Allen Sadler, Margaret Sadler.

DEED.

30 March 1859.

Summary: Wm. Brown & wife Mahala Brown sell to J. M. Lee for $5.00 all their right and title to a tract of land in Jackson Co. TN known as the Charlotty Stout land, their interest being one third of one share.

Signed by mark: Wm. Brown & Mahala Brown.

THE SEPARATE ANSWER OF JAMES STOUT to the Bill of Complaint filed against him on 8 Aug. 1889 by J. M. Lee.

27 Jan. 1890.

Summary: he denies that Charlotta Stout died possessing any land. She did hold a title bond to the land, but being old and infirm, she sold it in 1882 to her sons James Stout and Robert Stout, on condition that the brothers take charge of the farm, pay the taxes and purchase money for the farm and support and take care of their mother. In 1883 Robert Stout sold his interest in the farm to James Stout.

Charlotta Stout died in Dec. 1888.

James Stout (his mark)

THE BILL OF COMPLAINT OF J. M. LEE OF JACKSON COUNTY TN against William Stout, Allen Sadler & wife Margarett Sadler, Robert Stout, W. M. Brown & wife Mahala Brown, G. W. Goolsby & wife Mary Jane Goolsby, James Stout, Calib Vinson & wife Harriette Vinson, John Vantreese & wife Margarett Vantreese, last named who is now dead, leaving the following heirs, to wit, Fannie Vantreese & Lassie Vantreese, who are all the heirs at law of Charlotta Stout, deceased, and the brothers and sister of the whole blood share equally in the distribution of her estate, being six in number, all of Jackson Co. except Calib Vinson & wife Harriett who reside in Sumner Co. TN & Allen Sadler and wife Margarett who reside in Putnam Co. TN & Wm. Stout of White Co.

8 Aug. 1889.

Your orator states and charges that Charlotta Stout departed this life on the [blank] day of [blank] 1888 in Civil District No. 7, Jackson Co. TN, lawfully seized and possessed of the following described tract or parcel of land by Deed of Conveyance from W. H. Botts, bearing date Jan. 15th, 1885 . . . Bounded on the West by the lands of Wm. Stout, South by the lands of T. W. King's heirs or widow, East by George Stout, North by D. H. Armistead . . .

He says that he bought the shares of several of the heirs, and wants the land sold and the profits distributed. -bp.

DEED.

18 May 1889.

Summary: G. W. Goolsby & his wife Mary Jane Goolsby sell to J. M. Lee their undivided share in the land known as the George Stout place, for $5.00.

Deposition taken:17 & 19 Jan. 1891.

DEPOSITION: S. W. VINSON.

Walker Vinson (his mark)

DEPOSITION: JAMES STOUT [defendant].

25 years of age.

Quest. How much was in the whole tract [owned by Charlotte Stout]?

Ans. 50 acres.

Will Stout, my oldest brother.

James Stout (his mark)

DEPOSITION: W. M. NEIL.

Aged 53 years.

Charlotte Stout was somewhere in 60 years of age at date of her death.

/s/ W. M. Neill

DEPOSITION: WALKER VINSON.

/s/ Walker Vinson (his mark)

DEPOSITION: WM. DAWS.

39 years of age.

I live adjoining same [lands in controversy]. I have known it all my life.

s/s W. F. Daws

DEPOSITION: MARION KEITH.

25 years of age.

Marion Keith (his mark)

DEPOSITION: GEORGE STOUT.

44 years old.

I am cousin to James Stout.

His [James Stout's] farm adjoins mine. There is a fence between us.

/s/ G. W. Stout

DEPOSITION: JOHN VANTREASE.

32 years of age.

[no signature]

WILL.

I, Mariah T. D. Holcomb, at present residing near Whitleyville in Jackson Co. TN being of sound mind and disposing memory and desiring to make the disposition herein after indicated of such worldly effects as it has pleased the Almighty God to bless me with, do hereby make, ordain, publish and declare this to be my last Will and testament, hereby revoking and making expressly void all former wills by me at any time made.

Item 1.

I will and desire that all my just debts be paid as soon after my decease as practicable out of any estate that I may own at my death.

Item 2.

I will and bequeath to Joseph H. Lee all the rest and residue of my property of every kind and description, including the property and real estate I own in Clay Co. TN.

I nominate and appoint Joseph H. Lee Executor of my estate without bond.

This March 10, 1906.

Mariah T. Holcomb (her mark)

DEED.

15 Dec. 1893.

Summary: R. W. Allen, as Guardian for Maggie Allen, sells for $202.57, to Jesse Allen a tract of land lying on the waters of Spring Creek and Roaring River in District No. 3 of Jackson Co. TN, bounded on the East & South by Jacob Phillips and West & North by A. H. Morgan.

/s/ R. W. Allen

THE JOINT AND SEPARATE ANSWER OF LODEMA ALLEN & ANDERSON ALLEN TO THE BILL OF COMPLAINT OF JONES W. LEE & WIFE.

5 Sept. 1902.

They admit that R. W. Allen was the regular Guardian of Maggie Allen at and for several years prior to her marriage with complainant Jones Lee but they say that said marriage occurred on the 21 day of March 1895 instead of on the 17 day of March 1896, as is falsely stated in the bill. They admit that said Maggie was 18 years of age at the [unreadable because of paper fold.-bp.].

Respondents say that on the 10th day of Dec. 1893 the said R. W. Allen by deed of that date sold and conveyed the land in controversy in this case to Jessee Allen, and he, the said Jessee Allen, immediately thereafter, took possession of said land . . . until his death, which occurred on the [blank] day of [blank] 189- and that upon his death his widow, the defendant Lodema Allen and defendant Anderson Allen, his son, for themselves and for the other heirs of Jessee Allen . . . took possession of said land.

Deposition taken: 15 Sept. 1903.

DEPOSITION: SY. SMITH.

/s/ Sy Smith

Deposition taken: 24 March 1902.

DEPOSITION: R. C. LEE.

I am 70 years of age and residence Jackson Co. TN.

Quest. Where did Jones Lee live in 1895 . . .?

Ans. About one mile from Roaring River on my land in a house to himself.

R. C. Lee (his mark)

DEPOSITION: MRS. MAGGIE LEE.

I will be 24 years old Oct. 17 next and residence Jackson Co.

I am the wife of Jones W. Lee . . .

He [Jessie Allen] became paralyzed sometime about three years before he died. He died two years ago, a little while before next Christmas.

Maggie Lee (her mark)

Deposition taken: no date.

CROSS-EXAMINATION: MRS. SALLIE ALLEN.

/s/ Sallie E Allen

DEPOSITION: W. C. TERRY.

57 years old.

. . . Jessie Allen . . . his sons, George and Anderson . . .

/s/ W. C. Terry

DEPOSITION: R. W. ALLEN.

Quest. When did Jesse Allen die?

Ans. He died in Nov. 1899, I think.

/s/ R. W. Allen

DEPOSITION: A. K. MOSS.

I am 52 years of age. Residence Jackson Co. TN.

Occupation farmer and stone mason.

/s/ A. K. Moss

Depositions taken: 11 Sept. 1903.

DEPOSITION: A. O. BIRDWELL.

I was elected [Register for Jackson County] in Aug. 1898 and held four years.

/s/ A. O. Birdwell

DEPOSITION: W. S. ALLEN.

I am a son of Jessie Allen. He is dead. He has been dead four or five years. My mother's name is Lodema. She is living.

. . . uncle R. W. Allen . . .

. . . uncle Aught Morgan . . .

[Austin Morgan] is dead.

/s/ W. S. Allen

DEPOSITION: G. S. ALLEN.

Quest. Are you a son of Jessie and Lodema Allen?

Ans. Yes, Sir.

. . . old uncle Austin Morgan . . .

/s/ G. S. Allen

Deposition taken: no date.

DEPOSITION: W. S. ALLEN

/s/ W. S. Allen

Deposition taken: 6 Oct. 1903.

DEPOSITION: JONES W. LEE.

J. W. Lee (his mark)

DEPOSITION: ANDERSON ALLEN.

Quest. Are you a son of Jesse Allen, dec'd?

Ans. Yes, Sir.

Quest. Say if she [Maggie Lee] is a daughter of your brother, Dock Allen.

Ans. Yes, Sir.

Quest. Is her mother dead?

Ans. Yes, Sir.

Quest. How old was complainant Maggie when her mother died?

Ans. I reckon she was about a year old. I don't know for certain.

Quest. Who raised her and took care of her after her mother's death until she married?

Ans. My father did, after she was two or three years old.

Quest. Where did she stay until your father took her, after her mother died?

Ans. She stayed at Noah Lane's.

Quest. How happened your father to take her?

Ans. Dock Allen, her father, wanted him to take her.

Quest. Who went after her and carried her to your father's?

Ans. I did.

Quest. How came you to go after her?

Ans. Dock, her father, wanted me to go after her and sent me on his horse.

Quest. Was she stout and healthy in her childhood and while growing up, or was she afflicted?

Ans. She wasn't very stout.

Quest. If she was afflicted, how was she afflicted?

Ans. She had something the matter with one of her arms and shoulder so that she couldn't use it.

/s/ Anderson Allen

DEPOSITION: JONES LEE.

. . . we move about so much . . . we move nearly every year.

Jones W. Lee (his mark)

Deposition taken: 8 & 9 Sept. 1903.

DEPOSITION: JONES W. LEE.

I am 31 years old. Live in 9 Civil District of Jackson Co. TN.

. . . my sister, (Mary Lee) . . .

Jones Lee (his mark)

DEPOSITION: ASA JOHNSON.

I am 70 years old. Live in 9 District of Jackson County TN.

Jessie Allen was telling me about Monroe Lane's [?] wife coming down. She was a sister to Maggie's mother . . .

/s/ Asa Johnson

Deposition taken: 18 Sept. 1903.

DEPOSITION: R. W. ALLEN.

[Maggie Lee] is an orphan. Her mother died when she was about two years old.

I think Jessie Allen took her and kept her from the time of her mother's death. Her father was not in a condition to take care of her at the time of her mother's death.

/s/ R. W. Allen

DEPOSITION: MRS. SARAH E. ALLEN.

Quest. Are you the wife of R. W. Allen?

Ans. Yes, Sir.

/s/ Sallie E. Allen

THE BILL OF COMPLAINT OF JULIA A. LEE AGAINST JESSIE LEE, BOTH OF JACKSON CO. TN.

20 Oct. 1874.

. . . she and the defendant was married in Jackson Co. TN on the [blank] day of [blank] 1873, that they lived together in said County from that date up to about the [blank] day of August 1874.

Summary: She complains of verbal abuse. In 1874, he took her to the house of her father, Thomas Speakman, left her there and never came back for her or sent anyone to get her, and has left her with no means of support for herself or their child, Mary Thomas Lee, who is about eight months old.

She says she is very young. She asks for a divorce.

Julia Lee (her mark)

THE BILL OF COMPLAINT OF JULIA LEE AGAINST JESSEE LEE, BOTH OF JACKSON CO. TN.

3 Oct. 1876.

. . . she and the defendant was married in Jackson Co. TN about the 22nd day of July 1873. They lived together until about a year since, about which time the defendant [began verbally abusing her].

Summary: the defendant struck and beat her on one occasion. He willfully deserted her and still fails to provide for his wife and child. Complainant has to work to support herself and their child. The child is Mary Thomas Lee, about three years old. She asks for divorce, alimony and custody of the child. -bp.

Julia A. Lee (her mark)

THE BILL OF COMPLAINT OF MARY LEE AGAINST W. H. LEE, BOTH OF JACKSON CO. TN.

27 Oct. 1899.

. . . she and the defendant were married on the 16th day of Oct. 1881 in Jackson Co. TN, in which State and County they have lived ever since, except about three weeks in the year 1894, they lived in Kentucky . . .

She states that in the year 1882 the defendant began a course of cruel and inhuman treatment [verbal abuse & threats of physical harm. He called her, among other things, "Black Melungeon hellion"].

. . . defendant's father [Haywood Hix] [sic] . . .

She complains of frequent physical abuse. -bp.

. . . oldest son Robert . . .

. . . their children, to wit, Robert, aged 17 years, Enna Bell aged 11 and Walter age 5 years. They are the owners of the farm on which they lived up to the separation, lying on South fork of Jenning's creek in the 4th District of Jackson Co. TN, adjoining the lands of Virgil Lovelady on the North and Rubin McCoin on the West, on the South by Rehorn & the East by Painter boys, containing about 600 acres . . .

. . . the girl, although 11 years old, can't talk so as to be understood except that she can say a few words.

She asks for divorce, alimony and custody of the children. -bp.

/s/ Mary Lee

THE BILL OF COMPLAINT OF MARY LEE AGAINST W. H. LEE, BOTH OF JACKSON CO. TN.

7 Feb. 1891.

Summary: they were married in Jackson Co. TN in 1881. They have lived together off and on. The defendant has been verbally and physically abusive. At one time, he went away and stayed at a house of ill fame, to wit, Milly Ball's on Mill Creek in Clay County. There were various lewd women living there at the time, among others was one Margarett Owens, who, it was reported, had a child by him before his marriage to complainant. He took the child, after the marriage, to their house to raise.

They have two children, Robert age 7 years and Enna Bell, 2 years old. -bp.

. . . they have accumulated the following property, to wit, one tract of land whereon the defendant now resides, lying in the 4th Civil District of Jackson Co. TN on the waters of Jenning's creek containing 300 acres more or less, bounded by the lands of Virgil Lovelady, G. J. Jenkins, George Strode and others, being the same bought from W. H. Botts. . .

She charges that he is also the owner of a tract of land of about 75 or 80 acres, being a part of the Vance Lee tract of land lying on the North side of Cumberland River, which has lately been laid off to him as his part of his deceased father, Vance Lee's, estate, which is bounded by the lands of Margarett H. Herod on one side and Cumberland River . . .

She asks for divorce, alimony and custody of the children. -bp.

/s/ Mary Lee

THE BILL OF COMPLAINT OF PRESTON LEE AGAINST CATHERINE LEE, BOTH OF JACKSON CO. TN.

2 June 1890.

On the [blank] day of [blank] 1866, complainant and defendant were married in Jackson Co. TN. They had as the issue of said marriage four children, three boys, William aged about 21 years, George about 18 years, Arkley aged about 17 years and one girl, Marth, aged about 24 years. About 12 years ago, defendant failed and refused to longer live with and cohabit with complainant [and continues to fail to do so].

She has been guilty of adultery with Thomas Ellis many times. -bp.

Complainant is the owner of the following land lying in Jackson Co. and bounded by the lands of Price Whitaker, George West, Stephen Lee and Thomas Lynn, being above 100 acres, that is, he owns one half of said land and he paid $100 on the other tract, but the deed was made to his wife by the vendor without his consent or approval.

The defendant has taken possession of all the personal property. He asks for divorce and the property. -bp.

Preston Lee (his mark)

This is two suits involving notes on land that Mounce Gore sold. Nothing specifically genealogical in the documents. -bp.

THE BILL OF COMPLAINT OF W. H. LEE AGAINST ELIZABETH LEE, S. A. LEE, JAMES WHITAKER & HIS WIFE EMALINE WHITAKER, ALL OF JACKSON CO. TN.

No date.

Your Petitioner will show that on the [blank] day of [blank] 1890, V. C. Lee, a citizen of said County, died intestate seized and possessed in fee simple of the following tracts of land, to wit,

First tract, lying in the 13th Civil District of Jackson Co. TN & bounded . . . bank of Cumberland River, M. A. Herod's northwest corner . . . Denton Moore's line . . . containing 195 acres . . . the same conveyed by T. [?] M. Fowler & wife to V. C. Lee by deed dated 12 Aug. 1874 . . .

Second tract, conveyed by Newton Moore to V. C. Lee on the 3rd day of Aug. 1877 . . . bounded as follows, lying in the 13th Civil District of said County beginning in the lane above said Lee's field . . . Andrew Vanhooser's line . . . containing 9 1/4 acres . . .

Third tract conveyed by A. A. Vanhooser & wife to V. C. Lee on the 5 day of Oct. 1878 . . . lying in the 1st Civil District of said County and bounded as follows, Beginning on Newton Moore's & Andrew Vanhooser's corner . . . containing 30 acres . . .

That V. C. Lee left surviving him at his death his wife, Elizabeth Lee, who is entitled to homestead of $1000 & dower of one third of the remainder of said lands; also the following children and heirs at law, to wit, W. H. Lee, S. A. Lee & Emaline Whitaker, who has intermarried with James Whitaker . . .

He asks that the lands be divided among the heirs. -bp.

COMMISSIONER'S DIVISION OF THE LANDS OF V. C. LEE.

No date.

Plat included.

Deposition taken: no date.

DEPOSITION: W. H. LEE.

Quest. Are you a son of V. C. Lee, deceased? Was you his Administrator?

Ans. Yes, Sir.

I was his Administrator.

Deposition taken: 15 Jan. 1902.

DEPOSITION: R. W. ALLEN. [evidently misfiled in this folder. -bp.]

73 years of age.

I am the same R. W. Allen who was appointed Guardian of M. M. or Maggie Lee. Her name was Maggie Allen before she married Lee.

Jessie Allen sued me for services for raising and maintaining Maggie Allen and got a Judgement before Sy Smith, J. P. of District No. 9 and I let him have the land in satisfaction of said Judgement against me as Guardian of Maggie Lee. I made Jessee Allen a Deed to the land I think. There was $459.62 that came to my hands as Guardian [of Maggie Lee] . . .

/s/ R. W. Allen

THE BILL OF COMPLAINT OF W. H. LEE, ADMR. OF THE ESTATE OF S. A. LEE, deceased, Jno. D. Lowe & B. K. Quarles, merchants doing business under the firm name & style of Jno. D. Lowe & Co., Clay Reeves & B. A. Butler, all of Jackson Co. TN against Z. W. Young, W. F. Young & Marion Davis, Chairman of the County Court and financial agent of said county, citizens of like residence.

No date.

. . . S. A. Lee died intestate in Jackson Co. TN on the [blank] day of [blank] 18 [blank] and complainant W. H. Lee was duly appointed, bonded and qualified as his Administrator . . . found that the estate both personal and real estate was wholly and helplessly insolvent . . . He had no real estate whatever available to the claims of creditors; he had however purchased a tract of land from H. H. Herod, but had paid only a small amount on same at his death and upon a bill filed to enforce the vendors lien, the same was sold by the Chancery Court . . .

THE BILL OF COMPLAINT OF G. W. STEPHENS OF MONROE CO. KY & R. V. BROOKS OF JACKSON CO. TN.

No date.

. . . S. A. Lee has died intestate in Jackson Co. TN leaving defendants W. H. Lee and Emiline Whitaker his only heirs at law - he having never married and died without issue. Emeline Whitaker nee Lee intermarried with the defendant James Whitaker.

DEED. 25 May 1894.

Summary: George W. Stephens and H. H. Herod and wife sell to Samuel A Lee, for $3000 [mostly with a note], a tract of land lying on the North side of Cumberland River in the First District of Jackson County TN, bounded . . . near what is known as the lower ferry . . . Lock land now Z. M. Young's . . . containing about 85 acres.

Deposition taken: 13 April 1874.

DEPOSITION: JAMISON BROWN.

Aged 68 years.

/s/ Jameson [unclear] Brown

Deposition taken: 13 March 1873.

DEPOSITION: JOSHUA HAIL.

Aged 58 years.

I had property all the time till I deeded my land in the year 1866 . . . In 1859 I had six Negroes worth six or seven thousand dollars and my land was worth six thousand dollars. I had stock on the farm worth three or four thousand dollars.

/s/ Joshua Hail

Depositions taken: 23 April 1873.

DEPOSITION: R. P. BROOKS.

66 years old.

I did purchase of my co-defendant Jimmerson Brown the land involved in this suit.

Quest. State why it was that Jamison Brown moved off the land after your purchase . . .

Ans. His wife had died and he said he was going to break up, that he could not keep house, that his children was small. My recollection now is that he removed off the land about three years before he moved back on the land. U. T. Brown, the son of Jimmerson Brown, and my son-in-law, told me that if I would let his father go back on the land, he, U. T. Brown, would buy it for him from me, and I did let him move back upon it. I never did charge him rent for the land for the reason that during the war he saved my life, as I think, and for the reason that his last wife was a relation of mine and for the further reason that his son married my daughter and for the further reason he is a very poor and crippled man and as I was able to do without the rent and for the further reason that when he broke up and moved off the land he went and lived with his son, U. T. Brown, my son-in-law, who lived on my land, and done a great deal of valuable improvements on the land in the way of making good and valuable gates and repairing buildings, etc. and did not charge anything for it and besides he is and has been doing work and taking good care of the land of mine he is now living on.

I was worth at the time I purchased the land one hundred thousand dollars or more, consisting of land, Negroes and personal property and my wife was worth at that time fifteen or twenty thousand dollars that I had the control of, consisting of land and money.

At a moderate calculation, I think I am [now] worth seventy five thousand dollars.

Quest. You will state the time that your son-in-law, Dr. [?] U. T. Brown, died . . .

Ans. He died about the 28 day of March 1870.

/s/ R. P. Brooks

DEPOSITION: ALEXANDER NEVILLE.

60 years old.

/s/ Alexander Nevill

Deposition taken: 1 Oct. 1872.

DEPOSITION: JAMISON BROWN.

Aged 66 years.

[Joshua Haile] owned a Negro man named Jerry [?], a blacksmith, between the years 1857 and 1861 . . .

Quest. State if U. T. Brown and [Haywood] Lee were not both sons-in-law of R. P. Brooks.

Ans. They were.

Quest. State if Brown and Lee were not partners, merchants in the retail of goods . . .

Ans. They were in the mercantile business together . . . the widow of Lee . . . Angelina Lee . . .

/s/ Jimmerson Brown

THE SEPARATE ANSWER OF R. P. BROOKS TO THE BILL OF COMPLAINT OF P. H. LESLIE.

No date.

Jamison Brown is a very poor man and a cripple, having unfortunately lost one of his legs.

DEED.

2 Dec. 1857.

Summary: Jimerson Brown sells to R. P. Brooks a tract of land in District No. 11 of Jackson Co. TN, for $1200, containing 101 acres, bounded . . . a ridge between the Dry fork of Flynn's creek and Ragland's branch and stone quarry . . . crossing the Dry fork Road . . . near Thomas Brown's barn . . . D. B. Hail's East boundary . . .

ORDER TO THE SHERIFF OF WHITE COUNTY.

April 1872.

Summary: the Sheriff of White Co. is told to attach interest in a tract of land that descended to him from his grandfather and his brother lying in White Co. TN about five miles from Sparta, adjoining or lying near the land of Simeon Wallace. -bp.

THE BILL OF COMPLAINT OF HARRIET LEWIS OF JACKSON CO. TN AGAINST JAMES LEWIS, WHO IS NOW OF JACKSON CO. TN & SIMON WALLACE OF WHITE CO. TN.

1872.

Your Petitioner or complainant has been born and raised in Jackson Co. TN. Some eighteen months or two years ago she intermarried with defendant James Lewis . . .

She complains that he has verbally abused her, and become an inebriate at all times when he could procure whiskey, and failed to provide for her. -bp.

The child your oratrix bore by him died at once.

She says that he has an interest in some land in White County. Asks for divorce and alimony. -bp.

THE BILL OF COMPLAINT OF WILLIAM P. LEWIS OF JACKSON CO. TN AGAINST JOHN HUGHES OF DAVIDSON CO. TN.

No date.

. . . on the third day of Oct. 1859, he purchased of the defendant John Hughes a tract of land lying in Jackson Co. TN on Martin's creek . . . the Kincher & Webb place . . .

The suit involves questions about a note, the number of acres involved and a clear title. -bp.

This suit was settled by compromise. -bp.

THE ANSWER OF JOHN HUGHES TO A BILL OF COMPLAINT FILED BY WILLIAM P. LEWIS.

20 Jan. 1871.

Respondent does not admit that the land he sold complainant is covered by a superior title. He knows of no such, and if an older claim includes any part of said land, Jamey Roberts, under whom respondent claims he had a peaceable and uninterrupted possession of said land under a deed of conveyance from James Clements, the Grantee, for more than seven years and complainant has had said land in possession peaceable and uninterrupted ever since the date of the title bond exhibited in his bill. The land is called the Kinchen & Webb place because they once lived on the land under James Roberts.

PLAT OF THE CLEMENTS TRACT.

11 Aug. 1871.

Contains 146 acres.

Begins at the north boundary line of a 640 acre survey in the name of Joseph Shaw. -bp.

THE BILL OF REVIEW OF JAMES W. LOCK AND JAMES D. BENNATT of Jackson Co. against Newton Moore & his wife Catherine F. Moore, Augustus S. Lock, Mary A. C. Eaton (alias now Mary A. C. Frost) of Jackson Co. TN & William Lock & John F. Sadler, William T. Sadler, Catherine F. Sadler, James Sadler, John Sadler of Texas, the said Sadlers are minors and children of Sally Sadler, deceased, without guardian known, also against James A. Sadler, surviving husband of said Sally Sadler, of Texas.

10 March 1880.

. . . Elizabeth Lock, the mother of complainant James W. Lock, died testate in Jackson Co., the place of her residence, in the year 1852 or 1853, leaving a last will and testament . . .

By said Will there were a number of slaves bequeathed to said James W. Lock for and during his natural life and after his death to his children, who were the defendants Mary A. C. Eaton, Catherine F. Moore, William Lock and Augustus S. Lock and Sally Sadler the mother of the defendants Sadler in remainder.

This document summarizes the Lock suits, which are in other folders. This document is very faded and difficult to read. -bp.

Complainant Lock is old and needs assistance, care and attention to himself and his business such as no person but [James D.] Bennatt is capable [of] providing. Bennatt is his brother-in-law and from his long association with him knows how to act for his benefit as no one else can; and Lock resides with Bennatt, he being without family or house and has no other place to reside in comfort, as his children are not prepared or disposed to take care of him and some of them are constantly litigating and harassing him.

James W. Lock is old, being about 64 years of age.

Deposition taken: 10 May 1881.

DEPOSITION: J. D. BENNATT.

I live at Red Boiling Springs, Macon Co., about 21 miles from Gainesboro.

Major [A. A.] Swope lived at Carthage, Smith Co. TN and W. H. Botts lived at Glasgow KY [in Sept. 1879].

/s/ Jas. D. Bennatt

AFFIDAVIT.

10 May 1881.

Personally came James D. Bennatt and makes oath in due form that since the Bill was filed in this Court and since the Sept. Term of the County Court of Jackson Co. TN that the defendant Mary A. C. Eaton (alias Frost) has intermarried with Thomas J. Williams. And that said Thomas J. Williams is a nonresident of the State of TN . . .

Deposition taken: 16 March 1881.

DEPOSITION: JAMES D. BENNATT.

Aged 55 years.

/s/ Jas. D. Bennatt

Note: this is a dispute about a boundary line. -bp.

Depositions taken: 22, 23 & 24 June 1843.

DEPOSITION: SAMUEL C. GRIFFITH.

Aged between 42 and 43 years.

I crossed at that ferry some few times in Brooks's time, the first ferry that was put in there.

In Brooks's time, I was small . . .

I crossed there when Montgomery kept frequently . . .

I crossed in Draper's time, when Draper was ferry man there.

/s/ S. C. Griffith

DEPOSITION: JOHN F. GRIFFITH.

Aged about 32 years.

Quest. Is William Griffith dead?

Ans. I saw a letter from his wife stating he was dead.

. . . Col. William Locke, the father of the present complainant . . .

/s/ John F. Griffith

DEPOSITION: JAMES M. HULSEY.

Aged about 27 years.

/s/ James M. Hulsey

DEPOSITION: GEORGE C. DARWIN.

At that time I had an idea of buying the land from McClennon . . . I think it was sometime in the year 1833 . . . a branch leading down from Geo. McKaughan's to where Hiram Nettles then lived.

/s/ Geo. C. Darwin

DEPOSITION: HARRISON MC CARVER.

Aged about 27 years.

. . . my brother-in-law Marshal Anderson. . . He had a saw pit . . .

He [Marshall Anderson] was alive the last time I heard from him.

/s/ Harrison McCarver

PETITION.

No date.

Your Petitioner, Bailey Peyton Loftis, most respectfully represents to your Worship that Milly Loftis is about 75 years of age and is physically very infirm and incapable of attending to her affairs or of earning a support. Your Petitioner states that she is afflicted with a Senile Dementia and she is thus so afflicted as to render her incapable of managing her estate with discretion. She is so afflicted as to be the easy prey of the designing. She has a dower interest in a tract of land lying on Spring Creek in Jackson Co. TN and known as the John Loftis farm, [and personal property].

He asks for an investigation to see if she needs a guardian. -bp.

ORDER TO THE SHERIFF.

No date.

A jury found Milly Loftis to be a lunatic and demented and she has been in this condition for one or two years. R. W. Allen was appointed her guardian. -bp.

SETTLEMENT.

Aug. 1875.

R. W. Allen, Guardian.

SETTLEMENT.

Jan. 1879.

Archibald Loftis, Guardian.

REPORT.

5 Sept. 1881.

The undersigned reports to the County Court of Jackson Co. that he was Guardian of Milly Loftis, that said ward has been dead two years . . .

Archibald Loftis (his mark)

There are several settlements in this folder, nothing else. They reveal no genealogical information. -bp.

NOTICE.

14 Jan. 1892.

To George Gentry, Oza Gentry, heirs at law of Tennessee Gentry, deceased.

SETTLEMENT.

29 Jan. 1892.

One receipt from S. S. Frederick for five sets tombstones for Tennessee Gentry, her husband and three children, dated March 1st 1890 . . .

RECEIPT.

18 Sept. 1902.

Received of G. R. Loftis, Guardian of Ozina Gentry, $183.35 in full of all claims that Ozina Harley and J. W. Harley has against G. R. Loftis, Guardian of said Ozina Harley, formerly Ozina Gentry.

DEED.

30 Dec. 1841.

Summary: William Gray sells to Abner Chaffin and William Chaffin, for $10.00, a tract of land in District 9 of Jackson Co. TN on both sides of Talley's Hollow, bounded . . . Joseph Chaffin's fence, it being a corner made by William Gray and James Draper in a conditional line made by said Gray, George Allen and said Draper . . . 640 acre tract of land Granted by the State of TN to said Gray & Allen . . . Young's line . . . 1500 acres survey in the name of Love . . . it being a part of said 640 acre tract Granted to said Gray and Allen, containing 200 acres.

/s/ William Gray

Witnesses: /s/ Robert Young, Nimrod Johnson (his mark).

THE BILL OF COMPLAINT OF MARION CHAFFIN, John Chaffin, Benjamin Chaffin, Labin Loftis and his wife Eliza Loftis, G. R. Loftis and his wife Sally Loftis, F. M. Loftis and his [wife] Mary Loftis, Martha Chaffin, James Chaffin, Elizabeth Chaffin, Noah Chaffin, Luke Chaffin, Elizabeth Chaffin, the latter five are minors who sue by their regular Guardians John Chaffin and Elizabeth Chaffin against Andy Way.

Filed 5 Sept. 1879.

The plaintiffs sue the defendant for the following tracts of land lying in Jackson Co., District No. 1.

First tract.

The same description as in the deed above. -bp.

Second tract.

. . . 15 acre tract in the name of John Parker . . . James Young . . . 25 acre survey in the name of James Young, Junior . . . Robert White . . . Joseph Stafford . . . 300 acre survey in the name of John Stafford . . .

THE ANSWER OF G. R. LOFTIS to a Petition filed against him in the Circuit Court of Jackson Co. in the case of G. R. Loftis et. als. vs. A. J. Way.

20 Sept. 1880.

It was Abner Chaffin's land and on his death it descended to his heirs, respondent's wife being one.

Labin Loftis' wife is an heir of Abner Chaffin and as such has an interest in the land, perhaps one tenth.

G. R. Loftis (his mark)

COMPROMISE.

18 Dec. 1880.

This case was settled by compromise. -bp.

END OF ROLL.