Jackson Co., TN Loose District/Chancery Court Papers Reel #107

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

PRICE, STEPHEN vs PRICE, EDWIN; 1850 Chancery Court, Jackson Co., T

31 December 1849, notice of depositions to be taken of George Miles, William Newberry, Wilson Cherry, Sport Cherry, William Wood, Sarah Miles, Archibald Plumley Senr, Luke Hale, John Allen, Tabitha Cherry, John Sanders, James Price, Joshua Lancaster, Jesse Vincent, Phine Cherry, at the house of William Plumley, Esq.

Also on the 4 day of January 1850 at the house of John Dixon, depositions to be taken of David Griffith, James Carnahan, Ezekiel Carnahan, Reuben Carter, Lana Dixon, David Myers, John Dixon, Booker Witcher, Tandy K. Witcher, Carrol Pursil, Alexander ?Cubbage, William Morrill.

Also 7 January 1850 at the office of James T. Quarles in Gainesboro, depositions of Calaway Sizemore and continuing day to day until all depositions are taken.

22 ?June 1850, following depositions taken by William Plumlee at the house of Plumlee:

Joshua A. Lancaster, age 4[?9]. ." Joshua Lancaster mentioned "My daughter Nancy". Stated he has known Stephen Price 20 odd years, live within 6-10 miles of him in Jackson Co. Stated Stephen Price's wife died in 1842. "...Saw him in the path from where Sport Cherry had his corn field to Wilson Cherry's about a year after the death of his wife...looked strange in his eyes. [Signed] J. A. Lancaster

John C. Allen age about 50 years stated he had known Stephen Price some 25 or more years and lived part of that time within 5 miles of him. Stated he had heard Edwin Price say Stephen Price was "gone distracted" [after the death of Stephen's wife]. Thomas Price was present. Stephen was "missing at home some days". Deponent signed. [Signed] John C. Allen

Hiram Crabtree stated "I am son-in-law to Edwin [Price]". [Signed] Hiram Crabtree

Benjamin E.? Caruthers age 30 gave deposition [no relationships given].

?Martin/Austin L. Co _ _ _ _ _ _ _ _ age ?27/?37 gave deposition. Signed.

James Carnahan age 52, gave deposition re size of property. James [X] Carnahan

Pleasant Hensley age 52, 'know land in dispute'. [Signed] Pleasant Hensley

Joseph Roddy age about 44 stated William Wood cultivated land at one time.

[Signed] Joseph Roddy

[Page or pages missing here]

Sarah Miles "I passed by there and could see him looking up towards the grave he got to talking about his daughter Nancy." Stated he did not act as though he really knew what he was talking about. "...he said he went to Mr. Lane's he said he seen somebody there dead but did not know whether it was his daughter or not." Further stated complainant's daughter died "I think at Mr. Lane's". Sarah [X] Miles

George Miles age about 48. Stated he knows Stephen Price, "I sold him that Little Place that I suppose Edwin Price bought of him..." Stated one of Stephen Price's boys asked him to hunt for Stephen; that he supposed he was dead, as he had gone into the woods and had been gone some days; that his wife died in 1840 or 1841 at the place, and thought it was after 5 November 1842 when he "left the place...for two or three years". Later saw him with his children and he was "a heap pearter and better and talked livelier". [Signed] George Miles

Luke Hale, age about 40, Constable of Jackson County, stated he knew Edwin Price but not well; had sold him some corn and hogs. [Signed] Luke Hail

William A. Smith age about 41 stated there were prior hard feelings with Edwin Price, but had settled their differences. [Signed] William A. Smith

Bill of Costs: William E. Newberry, James Price, Tabitha Cherry, Sarah Miles, George Miles, Luke Hail, Wm Smith were paid 50 Cents per Day for testimony in case; not all depositions were in file.

1 January 1851, Depositions taken by Wm H. Botts, Clerk & Master of the Court.

Allen W. DeWhitt aged 81 stated he was acquainted with Hiram Crabtree, who was of good character. DeWhitt was present when James Dixon's deposition was taken at John Dixon's office. Stated James Price was the son of Complainant [Stephen Price]; that James Price married two or three years ago and "he is not a minor now". Stated he was acquainted with Lemuel F. Short, Berry Woodard and Thomas Price, and their testimony in court should be entitled to credit. Acquainted with Tandy K. Witcher, and stated if he has prejudice, cannot give full credit to his testimony. DeWhitt stated Thomas Price was the brother of defendant [Edwin Price]. Stated Walter M. Clark was the father in law of Berry Woodward. [Signed] A. W. DeWitt

William A. Kinner, age 43, Physician. "I attended Stephen Price and wife and daughter in the year 1840". Stated there was nothing of derangement [of Stephen Price] at that time. Stated if everything he has heard of Tandy K. Withers is true...cannot give full credit". Kinner lived within 12-14 miles of Berry Woodard. [Signed] W. A. Kinner

Walter M. Clark stated he is acquainted with Hiram Crabtree, would give credit to his testimony.

[Signed] Walter M. Clark

Joseph R. Crabtree age 49 stated Tandy Witcher "came to my house last spring...asked if Montgomery Clark lived there...told him he did not." Joseph stated he was a son in law to Edwin Price. [Signed] Joseph R. Crabtree

26 January 1854:

Alexander Clark, age 40, stated property was selling low in 1842-1843. Occupation Justice of Peace of Jackson Co., TN. [Signed] Alexander Clark

Joseph R. Lane age about 30, stated Nancy Lane, daughter of Stephen Price was deceased.

[Signed] Joseph R. Lane

Jackson Perry, age about 35. Stated Stephen Price left his land in 1846; that he remembers because he married in 1844 and lived "with my father-in-law"; made a crop with him in 1845 and moved to myself in 1846. [Signed] Jackson Perry

Samuel Lane testified as to assignment of note from Stephen Price to his wife Nancy Lane that he learned of the assignment from wife Nancy and other members of Stephen's family.

[Signed] Samuel Lane

Jackson T. Wood age 30 stated Stephen Price left his land in the spring or summer of 1846.

[Signed] Jackson T. Wood

William R. Kinner age about 50 [no relationships given]. [Signed] William R. Kinner

Benjamin E. Williams age 52 [no relationships stated]. [Signed] Benjamin E. Williams

Ezekiel Karnahan age 36 stated he was acquainted with Stephen Price "for some twelve years",; lived seven miles and part of time nearer him. After the death of his wife, Price went in woods and stayed three days. When he next saw him, he looked wild and was sullen. Stated those hunting for him, included Thomas Price, Campbell Price and some other of the Prices, some of the Hutchinsons, Berry Woodard, "myself and many others - perhaps 50 men...I was then a Constable." Stated he [Ezekiel] married Stephen Price's daughter. [Signed] Ezekiel Karnahan

Thomas Price age about 52, witness for defendant stated he had been acquainted with Stephen Price about 30 years; that he bought the burial apparel for Stephen Price's wife from Sampson Cassety. Denied making a motion to the County to bind out Stephen Price's children while Price was deranged. "I am brother to Defendant". [Signed] Thomas Price

29 January 1850,

Bill of Costs: 50 Cents per day for Witnesses Elizabeth Ann Short, James Crawford, William Hudson, ?James ?G. Cunningham, James Kieth, Thomas Price; Walter Clark for serving notices $2.50 and taking depositions $6.00.

Stephen Price, affidavit states he believes following are material witnesses: David Griffith, Ezekiel Karnahan, William C. Pursell, Joshua Lancaster, Wilson Cherry, John Allen, John Sanders, Ruben Carter, William Wood. 1 April 1850. Stephen [X] Price

1853: PRICE, WM & WIFE vs GIPSON, TOBIAS ETAL, Chancery Court

William Price & wife Hetty of Jackson County, Tennessee vs Tobias Gipson, Randal Gibson, Joseph Woolbright & wife Polly all of said county and state; and Levi Gibson of the State of Missouri; George Horn & wife Peggy of the State of Louisiana. George M. Gibson departed this life at his place of residence in Jackson Co, TN, will proved August term 1841. Widow Patience received property which law allowed; $5.00 each to his children Tobias Gibson, Patricia Brewington, Nancy Brewington and Perlina Gibson. Balance to be divided between his other four children Randal Gibson and "your oratrix Hetty who is married to William Price". Gibson died possessed of 25 acre tract granted by State of TN #10882 to Jeptha West 4 Oct 1817 on W side Blackburns fork of Roaring river; 50 acres on Blackburn's fork...David Ritchey's boundary; Tract #3945 dated 7 September 1826 by State of TN to George M. Gibson...stake in ?Juner Watson's field. William Gibson, Administrator of Estate of George M. Gibson deceased...land sold to Tobias Gibson. Hetty was a minor under 21 at time of sale with no regular guardian or guardian ad litum appointed.

8 _____ 1853: We William Price and Hetty Price owing to poverty...unable to bear expense of suit. William [X] Price, Hetty [X] Price

25 February 1853

Tobias Gipson stated he had receipt for about $25.00 from Hetty Gipson as heir of George M. Gipson, but lost it. Tobias [X] Gipson

R. C. Dill states receipt was signed in his presence; Tobias, Hetty and their mother were there.

[Signed] R. C. Dill

Leon Flynn - recollection indistinct [no relationships stated]. [Signed] Leon Flynn

David Ritchie age about 64, known Hetty since she was a child, no record of age..."she nursed [cared for] my daughter when she was a baby and [my daughter] will be 21 next May...Hetty was 9 or 10 years old at that time. [Signed] David Richie

Rowland C. Dill age about 50, live District 1, Jackson Co., TN [Signed] Rowland C. Dill

[Page or pages missing here]

Patricia Gipson stated she has several children, kept their ages by memory. Has several grandchildren and great grand children. Patience [X] Gipson

25 February 1854

Leah Flinn age about 54, stated she was acquainted with Hetty..."sucked her mother same time one of mine sucked me...mine will be 28 the 10th day of next month...Hetty born in the fall before mine". "My child Jean Flynn...kept his age by memory. An other child was 21 last Christmas and she is nearly [Testimony stops; page or pages missing here; no signature].

Patricia Gipson age 60, stated "Hetty Price is my daughter she is now about 29 in last October". No written record, knows age by memory. Patricia [X] Gipson

13 July 1854

William Price stated he expects to prove by Randal Gipson that his wife Hetty was a minor when the land was sold. "She is confined and cannot be at court at present term". William [X] Price

PRITCHETT, DAVID vs CHITWOOD, WM, 1874 Chancery Court, Jackson Co., TN

Pritchett stated Defendant has been subject to fits and cannot attend to business; that he owns property in Macon Co. and Jackson Co., Tennessee. Summonsed were James Bennett, Joshua Hawkins, ?Gove W. Whitley, William Morning. 5 Sept. 1874

Bill of Costs: Joshua Hawkins and Hueston Smith of Macon County, Tennessee.

David Pritchett and J. W. Crabtree post $500.00 bond to administer property of Wm Chitwood, alleged lunatic. August 13-15 1874.

PRITCHETT, JAMES, Admr of MARY J. HUDSON, deceased. Contains long list of small mostly household items sold to various individuals. Note on Mary Hudson to William H. Chitwood. Expenses included medical services paid to V. M. Clark; paid March 1872 paid to Jones & Wakefield for shrouding; W. C. McClellan for making coffinpaid 21 April 1872.

PRUETT, W. P., appointed guardian of Jennie Pruett Heirs 1895. Named as Robert, Henry, Maggie and Sible.

PRYOR, ABBY vs PRYOR, SID, 1880 [Divorce]

Married in Jackson County, Tennessee on or about December 1878. During their marriage they lived in house of her father Ephraim Scott. Stated she was nursing their infant child five months old named William Bennett [Pryor] when her husband abandoned her. Abby [X] Pryor

PURCELL, WILLIAM C. vs DAVIS, URIAH, ETAL 1861 Chancery Court

1 January 1873

State of Illinois, Massack Co. Thomas M. Richmond & wife Sarah A. appoint Allen Dewitt to collect for distributive share of Sarah A. in her father William J. Dixon's estate.

[Signed] T. M. Richardson [Signed] Sarah A. Richardson

26 December 1832, John Dixon granted 250 acres ?Fanning Creek, Jackson Co., TN.

7 March 1876. James E. Dixon of Pike Co, AR appointed M. A. Butler to represent him as an heir of John Dixon. [Signed] James E. Dixon

12 February 1861, deposition of James W. Draper age 49 stated he was acquainted with John Dixon and land, which cannot be divided due to the number of heirs. [Signed] James W. Draper

Denton ?Man, age 62, testified as to value of land. [Signed] Denton Man

Browder Keeling age 44, testified as to value of land. [Signed] B. G. Keeling

William C. Purcell & wife Rebecca vs Uriah Davis & wife Margery; and ?Abegula Dixon of Jackson County, Tennessee; and Elby Dycus & wife Polly of Macon County, Tennessee; and William J. Dixon of the State of Kentucky; Lydia Hancock & Abner Hancock of Texas; John Hancock, Nancy Dixon, R. F. Robertson & wife Rebecca; Dr Evans & wife Mary Evans of the State of Arkansas; ?Fancy Speakmon & Josephine Speakmon of the State of Alabama.

John Dixon died intestate in Jackson County, Tennessee August 1857.

Rebecca Purcell wife of William C. Purcell is the daughter of said deceased. Margery Davis & Polly Dycus wives of Anola Davis & Eleb Dycus are daughters of said deceased. Defendant William J. Dixon is the son of said deceased. ?Fanny Speakmon and Josephine Speakmon are the children of Robert Speakmon who intermarried with Matilda daughter of John Dixon who bore the above children only and died and said Robert Speakmon is also deceased.

Widow of said decedent [John Dixon] is Louisy Dixon.

26 April, 1873, Pike County, Arkansas:

John T. Hissop & Lucinda S. Hissop as heirs appoint M. G. Butler, attorney, to collect from estate of John Dickson. [Signed] J. T. Hipp [Signed] L. F. Hipp

26 December 1811, Indenture: James Cook, Esq. [Sheriff of Jackson Co.] and Robert White. Judgement of $300.00 plus interest against 200 acres of John James of White Co., TN sold to John Dixon to satisfy judgement of Benjamin Clark.

PURSLEY, MARTHA vs PURSLEY, F. D. and JAMES W. STAFFORD 1881, Circuit Court

Martha stated she and defendant F. D. Pursley married in South Carolina 17 October 1844. He abandoned her, carrying with him Lucinda Cole, a lewd character, wife of William Cole. F. D. Pursley and Lucinda Cole lived in adultery in Kentucky. He returned, asked forgiveness which she granted. He "took up" with Lucinda again and assumed payment of doctor bills for bastard children. Martha and F. D. Pursley had two mules, one in her possession and one in possession of James W. Stafford. She has three minor children, Dock Pursley age 15, Verji An and Dora May Pursley [no ages given]. [Signed] M. A. Pursley

PATE, ENZIA [?EMSIRE] vs PATE, MINNIE 1902

Complaint of husband states they married in Kentucky about 1900. Lived Smith County, TN. After about 8 months she wrote her folks wanting to go home. They did not reply favorably. Stated Minnie went off with Will Flatt and Ab Jones.

PAYNE, LUCY vs PAYNE, ALVIN 1905

Married 24 December 1904. His mother was Betty Payne who lived on what was known as the Barsham Place 10th District of Jackson Co, bounded by Meritith Fox, Whad Ha_ _ _ _ _ _ , Burt Robinson and Clinton Lands. Alvin owned a 1/14th undivided interest in his mother's property. Lucy's maiden name was Ransom. She asked her maiden name be restored. [Signed] L. C. Ransom

PENNINGTON, DAVID W. vs PENNINGTON, JANE 11 September 1891

Jane Pennington states they were married in Jackson County, Tennessee about the year 1855. Lived together until about 15 years ago, when he abandoned her.

David W. Pennington stated they married February 1852. About twelve or thirteen years ago, she refused to cohabit with him as husband and wife. He left her, leaving "most everything they had" and bought another farm . David [X] Pennington

James Pennington and Thomas Pennington were summonsed to testify at J. W. Stafford's, Clerk & Master of the Court.

PETTY, TENNIE vs PETTY, JAMES 18 November 1913

Married Jackson County, Tennessee about 1894. They had eight children together, ages 1-19. She had a child prior to their marriage, which he was aware of. Lived in Jackson and Putnam Counties, Tennessee. She stated he owned land in the 1st District bounded by Dock Spurlock, Ben Hensley, Sug Martin, Kirk Steward, purchased from N. J. Baster. Rented for money in 114 by Sid Burgess. Also owned personal property. [Signed] John J. Gore and P. J. Anderson, Sols.

PHILLIPS, NOAH vs PHILLIPS, LUELLA 1888

Lueller Phillips was in parts unknown, but supposed to be a resident of the State of Tennessee. Married [blank] day of 18[blank]. Were happy for four or five months. Defendant took up with one [blank] Thomas on the [blank] day of [blank] 188[blank] and abandoned him. 19 March 1888. Noah [X] Phillips [Signed] M. G. Butler, Sol.

SARAH E. PHILPOT vs MARTIN PHILPOT 1905

Married in Jackson County, Tennessee in 1872. She alleges cruel and inhuman treatment for the past five or six years. In May 1905 they lived in 6th District. He owned tract in ?8th District bounded by Osel Dawkins; Hillhouse Lumber Co., Gaines Land Co., being about 50 acres. Also personal property. [Signed] Gailbreath & Morgan, Sols.

States she is unable to bear expense of suit. Sarah E. [X] Philpot

PIPPIN, AMERICA vs PIPPIN, J.P. 5 February 1891

Married in Jackson County, Tennessee in 1866. Asks custody of minor children Milton E. Pippin, Richmon C. Pippin, Joseph L. Pippin and America C. Pippin. Own personal property, tract of land [description not included in suit]. [Signed] America Pippin

PIPPEN, REBECCA vs PIPPEN, SIDNEY S. 1889

Filed [blank] day of [blank] 188[blank] asking that certain personal property, which he was going to sell, be attached. [Signed] P. R. Pippen [Signed] Morgan & Smith, Sols.

Separate motion excluded from above list was a cow belonging to W. J. Denson "father of Rebecca Pippin". Stated he had loaned the cow to the couple and had considered giving it to them, but had not done so. W. J. [X] Denson

Rebecca Pippin filed complaint 3 January 1889, stated they married about 13 September 1888; that defendant Sidney Pippin had admitted adultrous conduct with Tennessee Look, who keeps a house of ill fame. Wants maiden name restored. Rebecca [X] Pippin Nathan M. Cox, Atty.

POTEET, BEATRICE vs POTEET, ROBERT 15 July 1896

Defendant is a non-resident of Tennessee, charge is abandonment. Published four consecutive weeks in "The Gainesboro Press". Asks that maiden name Beatrice A. Hunt be restored.

POTEET, J. C. vs POTEET, MANERVA C. 1884

Manerva Poteet summonsed, to appear 1st Tuesday after the 2nd Monday in May, 1884. T. L. Jones summonsed. J. C. Poteet and W. S. Poteet, security for bond of $100.00 to Manerva Poteet. Complaint states they were married 25 July 1871, defendant's former name Manerva C. Rains. J. D. Poteet named Edmond Jones "now of "Texas and T. L. Jones; stated he confronted Manerva, and she is staying in the neighborhood with one Mrs. Rains. Lowe, Sol.

[Signed] J. C. Poteet

PRESSLEY, LARKIN vs PRESSLEY, LONA 1907 and 1908

Filed 29 March 1902, complainant stated Lona's maiden name was Dowell; that they married 29 March 1902. Stated she committed adultery with John Birdwell 19 October 1908. Larkin and Lona had a daughter "now 6 or 7", Sallie Pressley. Lona has an infant he believes belongs to Johny [sic] Birdwell. Larkin [X] Pressley Young & Young, Sols.

Filed 4th District, Chancery Court 6 June 1907. Complainant stated Lona said she did not love him, that she loved Dillin Wilmoth better. Said 2 June 1907 went to the house of "Bell Keith a notorious whore", stayed all day. Asks custody of child Sarah B. Presley. Larkin [X] Presley

PRESLEY, MARTHA vs PRESLEY, DANIEL 1908

Married 6 May 1905, together until 8 October 1905. Stated Daniel would not provide for her, but they lived in the house with his grandmother. He wanted defendant to cook at J. W. Stafford's for board. Own land in 1st District bounded by Jim Godsy, Stafford. Jones, and Pressley, being 29 acres. She asks for land, states there is no personal property worth mentioning. [Signed] Martha Presley

PRICE, A. J. vs PRICE, MAT 1900

Case to be heard first Monday in March, 1900. Married 15 December 1886, together three years. She charges abandonment. Defendant is a resident of Jackson Co., TN. [Signed] Butler, Sol.

[Signed] A. J. Price

PRICE, N. J. vs PRICE, ANDREW 1891

?Jany day of [blank] 1891. Complainant states were "married two years next before this date". Have two boys, Winfield Scott Price [?] year old and Boss Price seven weeks old.

PRYOR, SID vs PRYOR, MANDY

Mandy is a non-resident of Tennessee, now resides in Kentucky. Notice published four consecutive weeks in "The Gainesboro Sentinen". Married Jackson Co., TN 12 May 1894, were together until November or December 1899 when she left with one Henry Schimerhorn. They have two sons, Davy Prior age 5 and Willie Pryor age 3. Complainant requests custody. The youngest son was living with his mother in Kentucky about a year earlier. S. M. Tinsley, Sol.

PRITCHETT, HANNAH MALINDA vs PRITCHETT, FRANCIS MARION 1870

States she and defendant married about September 1866. About 1868 he abandoned her, left for several months, came back, abused her, left again; that he now lives with Elizabeth Smith near the line of Jackson & Overton Co., TN. Asks that personal property be attached, and her maiden name Hannah Malinda Bradley be restored. [Signed] Hannah Malinda Pritchett

PRYON, MARY vs PRYON, CICERO [Surname as indexed on microfilm]

[NOTE: No date. Surname spelled variety of ways in this case].

"We Cicero Pryor as Principal and John H. Pryor as security are bound to Mary Pryor.

[Signed] Cicero Pyrant [Signed] John H. Pyron

PRYOR, WILLIAM vs PRYOR, NANNIE

Married 15 September 1896, were together thirteen years. Lived on the farm of ?Louis Huff in Smith Co. On 20 November 1909, she left with Alex Murphy taking four of their children with her "and about all the household goods"; they lived together in Robertson Co., TN a while. Also alleged adultery with Copland Keith. Stated he was informed and believes defendant repeatedly stated four of the five children were not his but belong to other men. William [X] Pryor

PUTTY, ELIZA vs PUTTY, JOHN H.

[Note: The date on this looks like either 7 July 1837 or 7 July 1857; possibly both are wrong, and it's 1887 considering the 1872 fire. Not on microfilm "Miscellaneous Divorce Cases" list, but is on microfilm reel]. Charge is abandonment. Complainant stated tried to serve defendant three times by the Sheriff, returned "not found in my county".

PETTY, SAMUEL E. vs PETTY, JEMIMA 4 August 1894

Lived Putnam County, Bloomington.

Wade Goolsby age 27 stated has been acquainted with the parties two or three years, live within one-four mile; "she was a quarrelsome woman". [Signed] Wade Goolsby

Clay Goolsby age 19 stated has been acquainted with the parties two years; lived in the house with them; "she was a quarrelsome woman...Mr. Putty was a quiet man". [Signed] Clay Goolsby

PETTY, SAMUEL e. vs PETTY, ADELINE

Married about 22-23 years ago, had born to them Columbus P. Petty age 21 and Arminta ?L age 17. Stated she refused to cohabit with him.

QUARLES, B. L. and W. H., Administrators of QUARLES, T. C.

Inventory of personal property sold and to whom as of 24 July 1900 [5 pages].

Inventory of personal property sold and to whom as of 8 Sept 1900 [3 pages].

Inventory of personal property sold and to whom as of Dec 14, 1900 [1 page].

List of notes and accounts [9 pages].

QUARLES, JAMES T. etal vs McKINLEY, THOMAS, Admr of McKINLEY, MATTHEW C.

[Note: Matthew C. McKinley died 4 July 1873. This is a very lengthy lawsuit involving multiple complainants, bills and cross-bills, spanning a period of about 10 years. The suit by James T. Quarles merely involved attorney fees. The primary suit concerned land McKinley had sold ten acres [5 on each side of creek] on 4 October 1866 to J. R. DeBow and A. G. Donoho who planned to build a grist mill. Recorded Book N, P 163 at Gainesboro, TN 3 May 1867. Built the mill and 10' dam. White Myers owned bottom land above the dam which would have been flooded, and so secured a perpetual injunction to prevent the dam from being 12 feet in height. Some of the pages may be missing, as there are cases with no testimony. McKinley's Last Will dated 1858 was submitted as an Exhibit. In the last years of his life, McKinley was declared deranged, and his son James D. McKinley appointed Guardian. After the death of his father, James D. declined to serve as Executor, and his brother Thomas C. McKinley was appointed Administrator]:

LAST WILL & TESTAMENT OF MATTHEW C. McKINLEY

I, Matthew C. McKinley being of good health and perfect in mind and memory but knowing that all must die and none know when I have therefore thought it prudent to make a disposition of such property as it has pleased God to [smear] with or that I may die siezed and possessed of.

Item first

I wish all my just debts paid and my funeral expenses out of any money I may die seized of or possessed of, or that may first come into the hands of my personal representatives.

Item the second

I have already given as an advancement to my son George W. M'Kinley two slaves Pinkney and Logan which I consider worth two thousand dollars & I charge him with that sum and also I have given my son James D. M'Kinley two slaves Henry and George which I consider worth two thousand dollars and I charge him with that sum. I have also given my daughter Frances the wife of Green B. Thompson two slaves Bill & Catharine which I consider worth nineteen hundred dollars and charge her with that sum.

I have loaned my daughter Martha Jane wife of James M'Claren two negro boys Berry & Ben which I now loan to the said Martha Jane M'Claren during her natural life for her own separate use clear of the use of her husband James M'Claren and at the death of said Martha Jane said negroes to be equally divided between the children of the said Martha J.

I also will and bequeath to my said daughter Martha J. one horse worth one hundred dollars and seventy five dollars in cash which is all I ever intend to give my said daughter Martha Jane McClaren.

Item the third

After my wife and all my children are made equal with my sons George W. and James D. M'Kinley except my daughter Martha Jane who is excluded as herein before stated, I will and devise that the balance be equally divided between my wife and all my children, except my said daughter Martha Jane who is expressly excluded. My wife however is only to have her dower in my real estate and an equal share of every thing else as herein before stated. I hereby nominate and appoint my son James D. M'Kinley sole executor of this my last will and testament hereby revoking and making void all former wills and testaments by me at any time heretofore made. In testimony whereof I have hereunto subscribed my name this 17th of February 1858.

[Signed] M. C. M'Kinley

Signed and published in our presence and declared by the said testator Matthew C. M'Kinley to be his last will and testament in our presence which we have witnessed at his request and in his presence and the presence of each other this 17 February 1858.

[Smear] M'Donald

H. C. M'Donald

?Thomas/James McHenry vs Thomas C. McKinley, Admr

Graham's Heirs vs Matthew C. McKinley Estate, 19 March 1874 [no genealogical information].

McKINLEY, JAMES D. vs RAGLAN, W. H.

Matthew C. McKinley in the last part of his life adjudged a lunatic by county, James D. McKinley appointed guardian. Matthew died 4 July 1873; wealth mostly in land, no cash. W. H. Raglan had sold Matthew merchandise worth $127, James D. denied being personally liable for debt. Bond of R. A. Cox and Thomas W. King of $260 to W. H. Raglin dated 26 April 1877.

Thomas C. McKinley, Administrator:

Respondent Darthula McKinley, William H. Ragland, et ux

Ragland attempted to collect $127 debt; attorney fees to estate totaled $967.74, estate declared insolvent.

Thomas C. McKinley etal vs J. R. and J. D. DeBow vs Thomas C. McKinley:

Notice of Depositions to be taken of J. R. DeBow, John Wood, N. B. Myers, White Myers, J. W. Smallwood, O. P. Burton, J. J. Kelly, D. H. Armistead, William Goolsby on 19 July 1882.

21 July 1883, deposition of James D. McKinley states he was guardian of M. C. McKinley. Stated his father had authorized him to buy mules. Bought one from Ross Wright, paid $120 or $125. 1861 soldiers passed through, took the mule. "I went to the army & seen Col. Stanton & he sent Father a check for $185". Original debt still unsettled. "It was while I was guardian of my Father...it was my Father's debt." [Signed] J. D. McKinley

T. C. McKinley, Admr and others vs J. R. DeBow, A. G. Donoho and J. G. Kelley

Case heard upon appeal [to TN Supreme Court]. Ella ?S/J McKinley, Robert Lee Thompson and John Bell Thompson...exceptions be affirmed and said answers suppressed as to aforesaid minors.

Deed: White Myers & Julian G. Myers his wife to James Debow and A. G. Donaho in Jackson County, TN District 15 on the bank of Martins Creek being five acres more or less on which mill house of Debow & Donaho now stands.

Notice of Depositions to be taken 16 June 1882 of J. R. Debow and John Wood in Trousdale Co.

T. C. McKinley vs Donaho, Debow & Kelly. Complaint states M. C. McKinley is dead, heirs at law to wit: James D. McKinley, G. W. McKinley, T. C. McKinley as heir and administrator, Emma T. Ferell & her husband L. D. Ferell, Alla T. McKinley all of Jackson Co., TN; James McClarin & Fanny McClarin of Smith Co., TN; Jemima Apple and Wert Apple likewise of Smith; James Thompson, William Thompson, John Bell Thompson, Robert Lee Thompson the later four of Putnam Co; H?ugh B. McKinley and David McKinley of Texas; John Bell Thompson, Robert Lee Thompson and Alla L. McKinley minors without guardians are all made Complainants to this case.

To the Sheriff of Davidson Co., TN: One of the Defendants in case, Ida [Alla] McKinley, intermarried with one William Boyd of your county. Boyd to appear 2nd Monday in March 1881 at the Court in Gainesboro.

4 October 1866, Matthew C. McKinley contracted to sell 5 acres [total 10 acres] on each side of the creek next to White Myers land, called the James Roberts Tract, to William Holliman's heirs. Bordered on south by Cannon tract, on all others by Mat C. McKinley Tract. [25 July 1879, one Elizabeth Holliman was added as Plaintiff].

30 September 1879, Bond of T. C. McKinley, L. D. Ferrell, D. H. Armistead and P. M. McCarver as securities for $250 bound to J. D. McKinley pending court decision.

October Term 6 October, Jackson County, Tennessee. Presiding Judge James M. Richmond; Justices present and presiding are R. W. Allen, Alexander Clark, James Eaton, J. R. Stamps, Peter G. Cox, E. C. Stamps, H. H. Draper, E. G. Gaines, Rufus W. Herring, R. P. Scott, W. G. Smith, J. M. Loftis, John A. Matheny, W. M. Cumins, Benjamin F. Chaffin, James P. Pippin, Charles Hopkins, B. G. Keeling, W. H. Dodson, John Cale, Thomas J. Lee, Lewis Hooten, Esqrs.

H. C. McDonald saw Matthew C. McKinley sign his name to his will; Matthew then of sound mind. James D. McKinley renounced as Executor, Thomas McKinley appointed Administrator.

Jackson County, Tennessee, Petition of James McClarin & Jane hi wife filed bill of Complaint 27 October 1866 in Jackson County Tennessee Chancery vs George W. McKinley, Matthew C. McKinley and James D. McKinley [Signed] A. A. Swope, Atty.

William Goolsby, lawful age, stated he ran the mill, helped build the dam. Ground 50-60 bu wheat per day and 100 corn. Cummins Mill about 18 miles away. [Signed] W. F. Goolsby

N. B. Myers stated he has owned an interest in the mill for about four years.

James W. Smallwood, aged 55 years, D. H. Armistead legal age, testify to mill productivity.

20 July 1882, J. R. DeBow age 60, states built dam in 1866 or 1867. Known Ross Wright 40 years. Had paid McKinley for land in his lifetime $500.00 in cash, $30.00 in flour and remained unpaid about $250.00 including interest. Sold mill about 18 months ago.

August 1881 James D. McKinley age 50; case continued to 16 August 1881.

QUARLES, J. T. Administrator of ALLEN, W. B.

Inventory of Final Settlement included invoice from Kittrell & Draper dated 19 June 1909 for merchandise for deceased; B. W. Chitwood for casket 26 April 1909; doctor bill for last illness to December 1907.

QUARLES, J. T. etal vs HAMILTON, JAMES R. etal Circuit, 1871

James R. Hamilton as Administrator of Ferdinand K. Hamilton, who died intestate. Defendants are said James R. Hamilton, William Hamilton, Adam Hamilton, John Sliger and wife Tallie Sliger, Millard Fillmore Hamilton, Arch Hamilton and Bell Hamilton, Franky Hamilton widow of deceased Ferdinand. Children are: James R. Hamilton, William Hamilton, Adam Hamilton, Sallie Sliger wife of John, Millard Fillmore Hamilton, Arch Hamilton and Bell Hamilton; three last are minors. All except Sallie are citizens of Clay Co., TN. Sliger and wife live in Putnam. To be heard 3rd Monday in May 1871 by Special Judge J. W. McHenry. Regular judge is the Plaintiff.

M. G. Butler appointed guardian ad litum for Belle Hamilton. Note executed for legal services by said Ferdinand K. Hamilton before the night of 14 August 1872 for $150.00. Ferdinand owned real estate in Jackson Co., none in Clay Co.

Ferdinand owed Quarles $150.00 for services. He was non-resident of Tennessee. Attachment was levied on land of Adam C. Hamilton in Jackson County on the Cumberland river being lands on which Adam Hamilton lived before his death and Ferdinand K. Hamilton formerly resided; also the Bayse tract bounded by Willet Martin, Hiram Tinsley, James Langford, heirs of Stephen Langford and others being about 2000 acres. 24 October 1870.

QUARLES, JOHN S. vs HUGHES, WIRT 1884

17 Dec 1890 witness M. B. Young of lawful age gives deposition before J. W. Stafford, Clerk & Master. Young was Solicitor in case of Wirt Hughes and others vs Sally Cannon where Cannon land sold by court decree. Wirt Hughes, a son of John Hughes decd served as Executor of father's estate. Land purchased by D. W. Paschall a son in law of John Hughes at the price of debt of $866.15 going to John Hughes' Estate. Decree rendered on 26 March 1883, plus interest.

[Signed] M. B. Young

Complaint of John S. Quarles alleges attorney fees owed to by Wirt Hughes as Administrator of Estate of John Hughes and in his own right, D. W. Paschal and wife Ella on several cases tried in different courts in Jackson Co., "perhaps in Putnam County" and TN Supreme Court amount to $1,000.00 or more; partial list of causes being Jno Hughes vs Ridley Roberts; John Hughes vs Abisha Cannon; Jno Hughes vs Need Apple; Wm Lambert vs Rial Maize etals; and Shepherd vs Cannon "(last three in Court at Gainesboro)". Father of John Quarles, James T. Quarles was counsel of John Hughes up to his death and at August term 1869. D. G. Shepherd vs Sallie Cannon, Jno Hughes & others, Supreme Court affirmed earlier decision.

Sallie Cannon land in formerly 15th Dist now 5th Dist on both sides of Murray's branch and east side of Martin Creek 125 acres more or less, bounded north and east by George McKinley, south by land formerly owned by Holliman & Hogan, west by Martin Creek; known as the Abisha Cannon farm. Land sold 26 March 1883 by decree, Minute Docket J pages 419-20-21 subject to liens for attorney fees of R. A. Cox, M. G. Young, James T. Quarles (deceased in July 1869)and John P. Murray.

Jno Hughes died February 1880. _______ ?Ganaway appointed and qualified as Admr 7 July 1881 and so acted until September 1881. Respondent Wirt Hughes stated James T. Quarles and others represented Jno Hughes in cases of Sampson McClelland vs Brooks & Hoover etals; Jno Hughes vs Brooks & Hoover etals; Jno Hughes vs Eller & Cross; Wesley Harvy vs John Hughes. Brooks & Hughes case determined since death of James Quarles; that at the time of Quarles' death, there was no money owed unless the suit about the Milton Draper land went to the Supreme Court. Draper suit "dragged on for 10 years". Wesley Harvey vs Jno Hughes Estate, suit was to collect a note on which Hughes was surety paid by agreement of parties in Confederate money.

Statement by R. A. Cox, attorney, stated the land of [Abisha] Cannon and wife [Sally], being a trust, could not be sold during Cannon's life for debt, or even for necessaries. "However Abisha having died before Hughes' decree the land descended under the trust to Sally & the children severally". [Signed] R. A. Cox

17 August 1891, witness J. P. Murray stated knew James T. Quarles in his life, was practicing attorney in his court since July 1851. [Signed] J. P. Murray

QUARLES, JOHN S. vs SHEPHERD, BENJAMIN A. etal Chancery 1875

[NOTE: Name Baint/Paint/Buist is not familiar to me. Using 'looks most like' method - mlj]

Jane Denton, Laura Baint [or Paint] and her husband [blank] and William [fold, can't read] and John B. McEwen of the County of Williamson and [blank] Marshall and [blank] Marshall children & heirs of John Marshall deceased of the County of Davidson who are minors by next friend David Campbell vs Benjamin A. Shepherd and Dangerfield ?J Ker?cian surviving partners of Pukins & Co of the City of New Orleans, Louisiana. William Woodfolk on 12 October 1829 conveyed to his son Joseph B. Woodfolk land in the County of Jackson Co., TN subject to estate for life, beginning at a stake...Lieutenant Nathaniel Williams boundary of Salt Lick...on Pole bridge branch.

Joseph Woodfolk died intestate many years ago unmarried without issue; tract descended to brothers and sisters subject to life estate of William Woodfolk only on a 1500 acre tract and not four smaller tracts owned by Joseph B. Woodfolk. William W. Woodfolk is a brother of Joseph B. Upon Joseph B.'s death, William inherited undivided 1/5 interest of 1500 acre tract and the four smaller tracts in 3rd District, Jackson County. 10 March 1869 William W. deeded to David Campbell, John Marshall and John B. McEwen his 1/5 of all above. Deed registered 15 March 1869. "Your orator John S. Quarles", William Woodfolk, Laura Paint [or Baint] and her husband [blank] Baint/Paint. On the [blank] day of [blank] Wade Lyon [or Sisson] and John B. McEwen exhibited original bill in Jackson County, Tennessee. John Marshall afterwards died intestate, leaving minor heirs. [Signed] James T. Quarles, Attorney

[Part of this case appears to have been tried or recorded in Sumner Co., TN 17 November, 1875; no further explanation - mlj].

Benjamin A. Shepherd is a resident of the State of Texas. Dangerfield L. Kervion resident of Louisiana. William Woodfolk, Complainant. [Signed] William Woodfolk [Signed] Thomas H. Malone, Solicitor

Demurrer states improper parties to case...John S. Quarles, William Woodfolk and Samuel

B_ _ _st [possibly Baint or Paint?] and his wife have no interest. J. W. McHenry for Defendants

David J. Shepherd, B. A. Shepherd and others vs Sallie Cannon, John Hughes and others

John Hughes and Garrett Sadler demurrer By Quarles, Solicitor

Know all men by these presents that we, Benj A. Shepherd, Dangerfield L. Kircion and B. J. Farrar, M. G. Young, H. J. Harley and Bob Smith are bound to John S. Quarles, J. R. Buist, Laura Buist, William Woodfolk, David Campbell, John B. McEqin, Eliza Marshal and John Marshal for $1,000.00. Request case be moved to Nashville.

Answer of John Hughes: Complainant David G. Shepherd and his brother James M. Shepherd, partners in trade, Granville, Tennessee. Abisha Cannon conveyed to Henry Sadler & Garret Sadler several negroes, once named Thompson. Abisha Cannon is dead, widow and children correctly set out in said bill. Henry Sadler also dead. February term 1851, Chancery, Gainesboro, Garrett & Henry Sadler, Trustees of Abisha Cannon Sr. and Sally Cannon explained advantages of exchanging negro Thompson for said land. James M. Shepherd received title to Thompson. Thompson died in 1864 before slaves emancipated. David G. Shepherd had in his possession negro Rachel. James M. Shepherd dead, left children who are living; they, not his brother David G. Shepherd are his heirs. Quarles, Solicitor

14 October 1871 [Signed] John Hughes

QUARLES, JOHN S. vs SMALLWOOD, JAMES 1873

William W. Woodfolk of Davidson Co., TN sells to James S. Quarles of Jackson Co., TN for the sum of $5.00 on south side of Cumberland near Gainesboro 2,560 acres granted by the State of NC to James G. Buckhorn on 18 Aug 1789 Grant No. 935 near Brooks ferry; also 75 acres on Roaring river granted to said Wood Woodfolk by State of Tennessee 10 May 1831 Grant #2556; also 135 acres in Jackson Co, TN, Salt Lick, being land conveyed by Poleman Pate to said Woodfolk Nov the 12th 184_, Jackson Co., TN, Book F pps 75 & 75 [sic]; also 46 1/2 acres in Jackson Co., TN on Salt Lick conveyed to said Woodfolk by David K. Witcher & Martha H. Witcher his wife 15 November 1838, recorded Book E pages 321 & 322; also 50 acres conveyed to Woodfolk by James B. Ke?ronley on 15 Nov 1838; also 63 acres on Salt Lick creek to Woodfolk by Edmund ?S Kirby on 3 Jan 1841; also 67 1/2 acres to Woodfolk by Pleasant G. Kirby 18 Nov 1838. "I am indebted to said Wm Woodfolk...balance of judgement obtained by Woodfolk...Circuit Court of Chicot County, Arkansas April 15 1866...$36,576.00 plus interest...if paid by 1 July 1867 this deed to be void". Dated 21 January 1867

[Signed] Wm W. Woodfolk

QUARLES vs SMALLWOOD 1880

Deposition of William Woodfolk of age, 8 September 1880, office of George G_ _ _ _ _ ld, City of Nashville. Contract with John Whittaker prohibiting from cutting timber off of the "Free State". Winter of 1872 and 1873, written obligation of John Wittaker not to cut timer.

W. Sutherland, age 44, Edgefield, Tennessee, occupation lumbering, lumber & sawing and sash & blinds manufacturing. Know Woodfolk bought logs; Quarles & Woodfolk were partners. Sutherland's books burned. [Signed] Wm Sutherland

Thomas Screvener Senior knew Wm Woodfolk Jr. six or seven years.

QUARLES, THADEUS C. vs VANHOOSER, FRANKLIN 1881, Circuit

Plaintiff Quarles sold Defendant Vanhooser five tracts on Jennings creek for $5,000.00. [Plat map of acreage in file; no relationships mentioned - mlj].

QUARLES, WM. H., Administrator of RAY, G. M. 1881, County

Final Settlement of Estate of George M. Ray, deceased. William Ray, Jane McCauley, James McCall & his wife Susannah McCall, Burr Jenkins & his wife Milly, Wm Craighead & wife Lucy, Murphy Craighead & wife Jane, Sallie Allen, Hiram Taylor, Jane Long, George Long, Wm Long, David Long, David Draper & wife Nancy, Puss Long & Sarah Long, Joseph Ray; heirs at law of George M. Ray, deceased. Expenses included burial clothing, material for coffin; invoice 8 November 1880. Quarles resigned as Admr, J. T. Anderson appointed 19 April 1887. Estate Inventory May term 1882 returned by J. T. Anderson.

RAGLAND, L. L. Guardian of MYRES, H. C. heirs [also spelled "Myers"] 1892

H. H. Cason, guardian of H. C. Myers heirs, files report 25 April 1890. Heirs C. B. Myres, L. M. Myres, F. F. Myres & Annie C. Myres.

C. B. Myres age 21 on 23 August 1898, "my father H. C. Myres". [Signed] Charley Myers

L. L. Ragland, guardian of Annie Myers, Final Settlement 22 September 1906.

L. L. Ragland, Guardian of H. C. Myers; heirs C. B. Myres, L. M. Myres, L. F. Myres, A. C. Myres. Dated 17 April 1893.

T. P. Myres vs Vina Ragland Adminx of Henry C. Myers, deceased [smear] Jan 1890.

W. H. Ragland Admr H. C. Myers dcd & Vina Ragland Guardian of Charley Myers, Fred Myers, Martin Myers & Anna Myres. Vina Ragland was the widow of H. C. Myres and intermarried with defendant W. H. Ragland.

RAGLAND, LIZZIE L. vs RAGLAND, W. H. et als [Divorce] 1880

Lizzie Ragland vs W. H. Ragland, John W. Holliman, Lex Cooper, James Hargis, Drury Spurlock, B?ob High, J. H. Anderson, Ben Franklin and J. D. McKinley.

Lizzie and W. H. married Jackson Co., TN 3 September 1879. Her maiden name was Butler. W. H. had three sons by a prior marriage, oldest aged 14-15. W. H. Ragland owned a store. Lizzie's parents lived in Gainesboro, TN. While husband was in Nashville, she took a steamer to her parents. Defendant owns Town Lot #107 in Granville and two tracts in District 5 being 92 1/2 acres bounded by Cumberland River, Elijah Holliman, J. Beasley; and Foster Tract being 150 acres bounded by Cumberland, H. G. Smith, Thomas L. Watts, M. C. Goldburg. Owns judgement against J. D. McKinley 21 May 1877 of $158.02 still on appeal in Supreme Court. James H. Anderson, B. V. High and Ben Franklin dba Anderson High & Co. owe defendant $48.00. Wants alimony and name changed to maiden name Butler. [Signed] Morgan & Butler

Samuel A. Morgan, Sol.

RAGLAND, W. H. etal & HIX, J.P., Administrators of W. E. PUTTY 1903 County

Final Settlement of Estate

RAINEY, CHARITY, Guardian of MEDLIN, ALLEN heirs 1884

Charity Rainey, guardian of Riley C. Medlin, requests George H. and J. M. Morgan to act as Securities. Bond $1700. Deposition of N. M. Cox age 39.

17 May 1884, George H. Morgan vs H. H. Loftis, sued for attorney fee of W. B. Butler & George H. Morgan [co-trustees and securities]

RAINEY, DAISEY vs RAINEY, JOHN [Divorce] 1897 Circuit

Married 13 April 1890 Jackson Co., TN. Owned personal property and 50 acres in 6th District, Jackson Co., Tennessee. Maiden name Whetstone. Two daughters aged 6 and 4, not named.

[Signed] Daisey Rainey

STATE vs JOHN RAINEY, Larceny.

Accused of shooting two mules, one belonging to Hugh [?B.] Whetstone; the other to "Old man Jerry Whetstone", father of Hugh. Hugh B. prosecuted for loss of mules; stated he knew defendant John Rainey..."he married my sister".

Witnesses for Complainant are Josh Hestand, Nancy Scott, Hyram Scott. All tentatively identified John Rainey as 'culprit'. Rainey stated Hestand alienated his wife's affections; stated he was in Martinsburg, Ky on the night mules taken.

Witnesses for State are Jack Staton, Wesley Smith, M. J. Dixon, James Rucks, Nim Reed, R. P. Maddux who arrested John Rainey and Alta Whetstone "wife of the prosecutor...Hughes, my husband". Grand jury returned indictment.

RAINS, JOHN vs RAINS, LOUIZA [Divorce] 1865

John stated they married about 1849. She left twice, came back. Left 14 May 1861. Complainant states impossible to live with her and has abandoned all attempty to do so. "She in the mean time has had five children" [unnamed, father not stated]. Asks right of single man.

[Signed] John Rains

Copy of Loyalty Oath, John Rains to U.S.A. dated July 1865.

John Rains and R. P. Brown execute bond in the amount of $500 dated 6 September 1865 to Louisa Rains. [Signed] John Rains, R. P. Brown

Calvin Hall summonsed 3 August 186?, states he owes said John Rains $20.00 by account.

[Signed] C. A. Hall

RAINS, SUSANNAH vs RAINS, ISAAC E. [Divorce] 1853 Chancery

Susannah Rains stated she married Isaac E. Rains about 19 years ago; they have five children, four sons and one daughter namely Martha Ann, William M., Reuben T., Edward ?J, Samuel A. Rains. Lists few household goods, and that Isaac Rains be enjoined from disposing of them. Requests custody of children. Susannah [X] Rains

RAMSEY, H.A. vs RAMSEY, L.J. etals, has been transcribed verbatim]

Transcribed by Mary Lu Johnson from Jackson Co., TN Loose Court Papers, Reel #107.

Depositions of L.J. Ramsey* and Etter Mainor taken upon Agreement of parties at residence of Crockett Maynor in Dist No 1, Jackson Co Tenn on May 28, 1900 on behalf of defts in above cause in presence of H.A. Ramsey & his Sol W. W. Draper and deft Crockett Maynor & his Solr Jno J Gore. [ Louise J., in household of her mother 1880; see end of document - mlj]

L. J. Ramsey of lawful years for defts taken on verbal interrogatories by agreement sworn states:

I am one of the defts in this case. I am the widow of Henry Ramsey dec'd. He died Mch 27, 1899. I am the owner of the lands in controversy in this case. The same was laid off to me as homestead and Dower.

I never did make a permanent trade with complt H A Ramsey to rent these lands to him for the year 1900.

I can't remember exactly how and all about it. We talked about trading just a few days after his father died. I wanted him to move in the house where I was living and tend the land and let me go home to the home place. He said he would not live any where on the place except where he was living.

Harvey Ramsey said if I caught him a cheating and defrauding me any way that he wanted me to come and tell him so that he would not do it knowingly. He said if I caught him cheating and defrauding me in any way that he would give it up to me at any time.

I say positively that I did not make the trade with H A Ramsey for the land at that time, for he would not take the house that I was living in.

H A Ramsey afterward sent for me to come down to his house, about the last of July 1899. He said he had rented him a house and land provided he could rent the bend field to make out his crop and I told him I reckon I had rented it to Bob Kent. He said Bob Kent could not tend that ground in peace and harmony and I told him that I would see Bob and get him to call back if he called it a permanent trade; that I would as soon he would tend my land as any body as far as he was concerned, and after I had started home he asked me if I aimed for him to tend the land, and I told him, "Yes I reckon. I said to him after I left the house Yes I reckon but I would have to wait till I saw Bro Press

After November court 1899 U A Ramsey* came to my house and called me out & told me he was going to tend that land if he had to have a law suit, and if he had to law for the land he would law for the house too. [*U A and H A Ramsey could be one and the same and I misread it due to the old style of writing; I haven't checked census records to verify - mlj]

At the time I had the conversation with U A Ramsey in which he stated that he wanted the bend land to make out his crop, he said he did not want the house unless I was willing to let him have it, this conversation occurred about the bend land in latter part of July 1899.

H A Ramsey came to me in the fall of 1899 but I don't exactly remember the time but as well as I remember it was Sept 1899 and he named to me to rent the house and I told him I did not want to rent the house, I wanted to go back home. He said then if I was willing he wanted the house and land also, but if not he would not contrary me; the houses were scarce that suited him.

_____ the conversation last stated H. A. Ramsey come up to my house again about November circuit court and had a conversation with me. I named to him had he got him a place and he said he had him a house rented already and he either said that he had rented 10 acres of land or wanted to rented it I don't know which. He said it was some where on Jennings Creek, and I asked him if he could get ready to give me possession by new years day. He said O Yes he could get ready by then. We were talking on things as had heard. He said we would not listen to things ?us/has had heard that he would not contrary me; that he aimed to move as soon as he could.

The reason I was about half way making these promises to H A Ramsey about the land was I was afraid of all of them. As to Henry I always liked him but still I was afraid of him, I had heard threats he had made through his brother.

H A Ramsey cultivated the land last year. His father let him have the land for 1898 & he come to me after his father died & made to rent the land for 1899 but he made no permanent trade for that year, but I let him stay there and cultivate the land for that year.

H A Ramsey did not destroy the place himself that I know of but his family destroyed the fence and the well that I could not use it. I saw his children split up some rails in the yard.

(The above answer objected to by Draper, Sol[icitor])

I saw two of his little children next to the baby, one of them throwed a rag in the well and the other one some sticks and I spoke to their Mamma about it.

At the time of the conversation at my house in November court, Benny Finn and Jno McCully were there.

I had a talk with ?W R Thomas (Darb) in regard to renting this land to H. A. Ramsey. He asked me had I rented this land to Harvy, I told him Yes I had contracted him some, but I would have to see Press Maynor my brother and talk with him, that I was not fit to make trades for myself without counsel. Press was kindly looking after my business for me. I had looked to Press for advice.

The reason I left my home and come up here, I was afraid of Mr. Ramseys people. I was his 2nd wife, and them are children of his first wife.

X Ex [Cross Examine]

U A Ramseys family was present when I had the conversation with him at his house the last of July. H. A. Ramseys brothers come up in the time of the conversation. Frank Mainor was present and this is all I remember of being present. I don't remember of Walker Wilkerson being there that evening, but he was there on Sunday evening afterwards when I was there. We talked about the land trade on the Sunday evening when I was there.

I did not state in Walter Wilkerson presence and in the presence of H A Ramseys family that I was going to let H A Ramsey have the land. I was leaving through the hall and H A Ramsey asked me if I was going to do what we were talking about; I told him Yes, I reckon. At the time I intended to let him have the land provided it was agreeable all around, Of course I was not fit to attend to my business. I had to get some body to do that.

H A Ramsey said he would pay me one third or he would pay me standing rent. I told him one third would suit me better. He said if he rented my land he would make so many rails and he would put them to their place, but that was on the evening that he sent for me that I was telling him about mine and Bob Kents plan.

I did not think I got enough corn for the rent of the land for last year.

H A Ramsey hired his brother to gather the corn, don't know whether my brother helped to gather the corn or not, but he was there when it was measured up. I gathered roasting ears & corn in the field around the house until gathering time. I took two ____ and left four.

H A Ramsey told me afterward that he would give me 18 Bbls [barrels] of corn for my part of that that was in the hill field this was along about corn gathering time. I told him I would take that, I wasn't their when the corn was measured out but Baily Ramsey & Brother Tom told me the number of tubs there was. Of course I did not get that much in my possession. I don't say it was not put in the crib for I was not their. Brother Tom was their looking after it in my place.

I got my part of the corn around the house but I don't know whether I got my part across the branch or not for his family got mad ?at me and sent me word ___ ____ inside of the fence.

I told H A Ramsey that I would see Bob Kent and get him to withdraw. I saw Bob and Bob said it could not be called a permanent trade and of course he could not himself if I did not want him to tend it. I told him I would rather neither one would tend it for it would cause hard feelings.

H A Ramsey never threatened me to my face. Face to face he has always treated me kindly. We talked about things as had heard that one another had said. The reason why I thought the threats were made, Lex Ramsey said he would stay their if he had to kill me over it. I had a peace warrant for Lex Ramsey and Lex told me if I had it served on him that Tom Maynor would have to get out of there inside of three days and he said U A Ramsey said so too and H A Ramsey he said the same - Lex Ramsey claimed that as his home. Agreeable to what they told ___ Lex & his sister and Mary Sircy. Lex was over 21 years old of ?course I don't know his age.

The threat was directed against my brother Tom Maynor".

*I then asked if she had been a single woman ever since her husbands death in March 1899. She remarked that she did not know that this was concerning this law suit. [* No indication this question was by interrogating attorney, but appears it was - mlj].

"Of course I have not remarried since his death. I have become the mother of a child since my husbands death. It was 12 months and some over after the death of my husband until the child was born. My husband Henry Ramsey was not the father of the child.

I don't know whether I am now under indictment in the circuit Court of Jackson County for Lewdness

(Objected to by Gore, Sol. Record is the best evidence)

I am not under bond to appear at July ?term 1900 to answer that charge. I have not been notified about it.

(Objected to for the same reason above. Gore, Sol)

I have been guilty of adultery with Jack Brinley and no others since the death of my husband.

(Above ans objected to by Gore Solr)

Re ex [Re-examined]

I was not permitted to be on hand at the crib when my corn was measured up. H. A. Ramseys wife sent me word that I should not come in side of the bars ?H R would tell me to get out if I did and get out she would ___ me out. The reason I did not go and see about it I did not want to violate the law and I talked to Press Maynor about it and he told me not to violate the law in any thing. Mrs. H A Ramsey sent me the word by Bro Tom's wife.

My Bro Tom was living in the house with me when U A Ramsey and Lex Ramsey sent me word & told me that if I had the peace warrant served on him they would only have 3 days to get ?out with

The reason I had the peace warrant issued against Lex was because he never come in the house unless he abused me and cursed me and the children, then was shooting around the house after he began his cutting up - The house was rocked, but I don't know it was Lex

(Complt objects to any statements or anything about the conduct of Lex Ramsey. Draper sol).

H A Ramseys children took things from my house in my absence.

(Above objected to by Draper Solr)

I have rented the land for this year to Crockett and Wm Maynor

~ Re X Ex ~

I have two children by my husband Henry Ramsey. They were living with me while I lived on the land. They are a boy and a girl.

If the reason Mrs. H A Ramsey did not want to associate with me was on account of my lewd conduct I did not know it. L. J. [her X mark] Ramsey

WITNESS Mrs. Etta Mainor 34 years of age for defts sworn states in verbal interrogation as follows:

I am the wife of Tom Maynor. Know the complt H A Ramsey his wife and family know the land in controversy in this suit.

My husband and me lived in the house of L J Ramsey part of the time last year.

I went down to H A Ramsey one evening. L J Ramsey was talking of going down and clean out her crib next morning, I was going down to H A Ramseys. Mrs. H A Ramsey said that L J Ramsey should not come inside that she would tell her not to come in side and if she did not get out she would put her out. She told me to tell L J Ramsey what she said.

Mrs. H A Ramsey said she had sent her little girl up to Mrs L J Ramseys after some lard and Mrs Ramsey would not let her have the lard and and that was what Mrs H A Ramsey ___ was mad at L J Ramsey about

(All of the above objected to because H A Ramseys wife is not a party to the litigation. Draper sol)

I heard H A Ramsey & L J Ramsey talking at the gate one morning last fall. I think it was about corn gathering time. It was very cool. I heard U A Ramsey say that if he had to law for the land he would hold the house. That was all I reckon I heard either party say.

X Ex

I was about 6 steps or 15 or 20 ft away from H A Ramsey & L J Ramsey when they had the conversation above spoken of. That was all I heard. I had started down to where my husband was working on a ?house/barn.

Of course I could not state what hour it was I just heard H. A. Ramsey say that if he had to law for the land he would hold the house. I have not heard L J Ramsey admit that she rented the land to H A Ramsey I heard her tell it just like she stated it to day.

Etta [her X mark] Mainor

28 May 1900, B.A. Butler, Clerk & Master, acknowledging filing depositions in his office.

H.A. RAMSEY vs L.J. RAMSEY, etal, Pending in the Chancery Court of Jackson Co Tenn

Depositions of T. F. Dixon, Julia Ramsey, J.E. Ramsey, Tennessee Dixon, witnesses for complt in the above case taken upon agreement of parties before B. A. Butler, C & M at the store house of ?Grisham - Dist No 14 of Jackson County in the presence of complt & his Solr ?W N Draper & defts & their Solr J.J. Gore

Deposition of T. F. Dixon, witness for complts sworn states as follows:

I am 46 yrs of age or will be next Nov. I know the parties to this suit. I don't know that I ever had a conversation with L J Ramsey about the rent contract, but I heard her speak about renting the land to H A Ramsey. Heard her speak about it several times. I heard her say she let H A Ramsey have the land for the year 1900. I heard her say this several times since Henry Ramsey died. It occurred about land renting time some time but I don't know exactly when it occurred ?what ?year the time exactly.

I heard a conversation between L J Ramsey and Bob Kent she told Kent she had let H A Ramsey have the land and Kent told her she had rented to him and if she did not mind she would get herself into trouble about it.

X Ex

I could not tell for certain as to what year L J Ramsey said she had rented this land to H A Ramsey, it might have been for this year or it might have been for last year.

I saw H A Ramseys girl take one rail off of the fence - that is all I saw.

(Objected to above ans. Draper Sol)

The well on the place got in a bad shape but I don't know who done it. I don't recollect who was present at their conversations except the time she was talking to Bob Kent. No one but Bob Kent was present that time.

The way I understood it was that H A Ramsey did not have the land rented (Last ans objected to Draper sol)

I heard H A Ramseys family say that H A Ramsey had gone down into Smith Co to rent a place (Last ans objected to by Draper Sol)

~ Re Ex ~

It was after the Commissioners laid off the Homestead and Dower to L J Ramsey that I heard her and Bob Kent talk about it.

~ Re X Ex~

I don't know exactly what kin me and H A Ramsey are. We are Bros in law. I married his sister. T F [his X mark] Dixon

Witness Julia Ramsey of lawful years sworn states as follows (for complts)

I am the wife of complt H A Ramsey, I know L J Ramsey.

I remember a conversation that [two or three words smeared] some time the last of July or first of August last at my house. It was after the July term of the Circuit Court. It was also after the land had been laid off to L J Ramsey.

H A Ramsey sent for L J Ramsey to come down at our house. He wanted to rent the hill land and stubble field from her. L J Ramsey told H A Ramsey that her and Bob Kent was on a trade for the land & that Bob Kent offered to cover her house and fix the fence and give her one third. H A Ramsey told her he would not bind him self to cover the house nor to fix the fence except the fence around the field he had rented, but he would bind himself to make a few rails. She L J Ramsey got up and started home and he H A Ramsey asked her what about the trade, and L J Ramsey remarked You can tend it if I get so mad at you I wont speak to you. The trade was agreed to between the parties. H A Ramsey asked her if she L J Ramsey consider that a trade for me to give you the third and she said Yes Sir, the renting was for the year 1900.

I prohibited L J Ramsey from coming to my house. I did not endorse the way she was living, was the reason I did not allow her to come there.

~ X Ex ~

I don't know for certain when the land was laid off to L J Ramsey. I wont say for certain whether it was laid off in the Spring, Summer or fall. I did not take any notice of it. I don't know whether it was laid off before July 1899 or not. I know it was after the July court. I have no fact or circumstances that makes me know that this land was laid off to her before this conversation occurred (above ans objected to. Record best evidence. Draper sol)

I know myself that the land was laid off to L J Ramsey before this conversation occurred. The land was laid off to her after the July court.

I don't know for certain that this conversation occurred before the land was laid off to L J Ramsey.

Re cross ex

My husband did not in that conversation agree to fix the fence only that adjoins his field that he was renting. My husband fixed that fence. H A Ramsey laid up rails this last fall. He never made any new rails & put up there.

L J Ramsey was standing half way between the house and the bars when she told my husband that it was a trade. The children & Lex Ramsey heard her tell my husband that. Don't recollect whether Walter Wilkerson was there or not. If he was I don't recollect it. No one else but Eliza Ramsey was there.

Witness was asked if it is not a fact that her husband & her family did not greatly damage the place & destroy the well & rails around the place and she said she is not to answer that question and said further that if damaged Mr Maynors little girl did it. She dropped the bucket in it.

My husband went down in McClures bend late last fall to rent land to ?move to. My husband said he went for that purpose. My husband did not tell me when he come back that he had rented land in McClures bend. My husband said he had contracted from Owen Hailey but had not closed out. I don't think it was overly late - the fall when he went. I wont say for certain & whether it was in the summer or fall that he went. My husband went to Jennings Creek to rent a house but he never closed out. I don't know what he lacked in closing out the trade on Jennings Creek. My husband went to McClures bend after July court to rent land but he never went all over the country to rent land. Don't know for certain that it was after or before he had the conversation that he went to Jennings Creek to rent land. This conversation in July was the only conversation I ever heard between my husband & L J Ramsey in regard land. Don't know that my husband rented the house when he rented the land. I never heard anything said about that. I heard my husband say that if Mrs. L J Ramsey would give him up the land that he would give her up the house. I prohibited L J Ramsey from coming inside of my premises to clean out her crib to put her corn - I did not say to her anything about [3-4 words smeared] her corn. After I stopped L J Ramsey from coming their after I found out the way she was living I never neighbored any more with her. I don't know when I prohibited L J Ramsey from coming then. At the time she sent word she was coming there to clean out her crib that was the time I prohibited her from coming there.

It was a week or two after L J Ramsey refused to lend me some lard when I sent my little girl up there until I stopped her from coming there. I heard my husband say to L J Ramsey that when he left the house he would ?leave the place. I never heard my husband say after the July conversation with L J Ramsey that if he did not get to tend that land he would leave the place. I am the wife of complt.

Re Ex

I remember the occasion when the commissioners came there and laid off the land. This land renting trade was after the land was laid off. Julia [her X mark] Ramsey

Witness J E Ramsey for complt sworn states as follows:

My husband's name is Bailey Ramsey. I am a sister in law to complt Know deft L J Ramsey. I had a conversation with L J Ramsey in relation to the rent contract between her and U A Ramsey. She was telling me about it. I have heard L J Ramsey talk about this land renting contract a time or two. I heard her say she had rented U A Ramsey the land for year 1900. She L J Ramsey said that if U A Ramsey rented him another place he was to give her the first refusal for this land back and I heard her say again that she had rented it to H A Ramsey and she turned in again and rented it to Jack Brinley. She said she knew Jack Brinley would stand ?U/H A Ramsey [3-4 words in fold can't read] this land. That is all I know about it. The conversation which L J Ramsey told me, she had rented it to Jack Brinley was after the trees had began to shed their leaves. The other conversations occurred before that time.

X Ex

We were up on the hill above L J Ramseys house at the Spring when we had the conversation about her renting this land to H. A. Ramsey. It was in the fall of the year. It was last year. I don't know for certain what month it was. It was along about corn gathering time I guess for I know the leaves were falling off the trees. There was no one else present. I don't know how come the conversation to come up. She just raised it herself and just commenced talking about it.

I can tell you word for word just what she said, she said she had rented H A Ramsey the land and then she turned in and rented it to Jack Brinley for she knowed Jack Brinley would stand H A Ramsey out and tend it himself. I cant tell you what were her reasons. She gave none as I remember as to why she did not want H A Ramsey to tend it. If she did I don't recollect it. That is all the conversation she had with me at the Spring I reckon. It was in the same conversation that she told me she had rented the land to H A Ramsey that she told me also she had rented it to Jack Brinley. I never heard Baily Ramsey or Charley or H A Ramsey say any thing about who would tend the land in ?case U A Ramsey gained it.

L J Ramsey did not say anything about renting the house, in the conversation at the spring.

Never heard H A Ramsey say any thing about moving from there if I ever heard his wife say any thing about it I don't recollect it. Never had a conversation with U A Ramsey about this land as I now recollect. I guess it was after the land was laid off to H A Ramsey that the conversation at the Spring occurred. I know it was afterward. I never saw H A Ramsey or his family burn a rail in my life nor see them injure the well. Baily Ramsey is a brother to Harvey Ramsey. [Signed] J. E. Ramsey

Witness Tennessee Dixon of lawful years sworn states (for complt)

I am a sister to H A Ramsey, know deft L J Ramsey. I had a conversation with L J Ramsey during last year in relation to the rent contract with U A Ramsey. I heard her say several times that she had rented H. A. Ramsey the land for year 1900. Corn was done made when I heard her talking about it. It is the land in controversy that she said she had rented to H A Ramsey I don't know how often I have heard L J Ramsey speak of the rent contract I heard her several times during last summer and fall that she had rented to H A Ramsey. I heard L J Ramsey say it before the land was laid off to her and afterwards to.

X Ex.

I cant tell you exactly when was the first time I heard L J Ramsey say she had rented the land to H A Ramsey. Don't recollect that. I cant recollect where we was at the first time I heard her say she had rented to H A Ramsey, but I have heard her say so, at my house and at her house. Cant tell what month it was I heard her speak about it first. I cant tell you the second time. I heard her talk about it and I cant tell you what month nor what time I just heard her talk about it. Cant tell the 2nd, 3rd 4th or 5th time I heard her talk about it.

L J Ramsey come to her fence & had the talk to me. This was long about the last of last Summer. Nobody but me and her heard it my little children was with me. Cant tell how come the conversation to come up. She brought it up her self and commenced telling me about letting H A Ramsey have the land, this was after Homestead and Dower laid off to her. Don't remember when the land was laid off to her [words smeared] was last of the summer that it was laid off. She said she had rented H A Ramsey the land and if H A Ramsey took a notion to rent some where else he was to let her have the first refusal back. Cant give the time and place of no other ?particular conversation that we had. I never heard H A Ramsey say a word about his renting ground in McClures bend. Never heard his wife say any thing about it. I may have heard some of the little children talk about it. Never heard H A Ramsey his wife or children say any thing about renting land on Jennings Creek. Don't know that H A Ramsey went to McClures bend to rent land. Some of them said that was what he went down to McClures bend for, to rent land. Some of the children said that was what he went for.

(Last above answer objected to Draper sol)

I never heard H A Ramsey say anything about this rent contract. Never heard anybody but L J Ramsey speak about it. Don't know that ?H A Ramsey & his family destroyed the fence never noticed any thing about it. Never noticed whether the rails disappeared & the fence get ?bars. Never saw them do a thing to the well. Never saw them destroy a thing on the place. I don't recollect much about the house when H A Ramsey went there but [smear] is damaged to what it was when I lived in it. Don't know that it is damaged only worse than it was when Harvy first went there. Don't know whether the well got so bad it could not be used. I never could use it any way and I don't know that it got any worse. Tennessee [her X mark] Dixon

31 May 1900, B A Butler, Clerk & Master, certified filing.

This joint and separate answer of L. J. Ramsey, Crockett Mainer and Wm Mainer, to the bill of complaint of H.A. Ramsey, filed against them in Chancery Court of Jackson County, Tenn. On the 16 day of March 1900.

They admit that at the July term of the Circuit Court at Gainesboro certain lands were assigned to L.J. Ramsey as homestead, and that said ___ ____ described and bounded in Complts bill in this case, they _____.

Deft. L.J. Ramsey positively and emphaticaly denies that she ever rented these or any other lands to Complainant H.A. Ramsey, for the year 1900 or for any other year or time.

Defendants positively deny that in violation and disregard of said rent contracts they fraudulently caused a writ of possession to issue __ dispossess complainants of said lands and to put defendants in possession of the same; but the truth of this matter is that complainant H. A. Ramsey was unlawfully and forcibly withholding said lands from defendant L.J. Ramsey; and in compliance with the Circuit Court decree she did cause to be issued a writ of possession to place her or her agent in possession of the same; that the complainant had no right to the possession of said lands.

The charge in complainant's bill that defendant Crockett Maynaard is insolvent and that if defendants are permitted to dispossess complainant, it will work irreparable injury to complainant is false and untrue and is here positively and emphatically denied.

Defendants deny that Crockett and William Maynard are taking possession of said lands and attempting to cultivate it in violation of complainant's rights and are unlawfully interfering with complainants in an _____ of said lands, and are unlawfully attempting to oust him from his possession of said land under his said contract. They again charge and say that complainant has no right to the possession of said land __ has no contract with defendant L. J. Ramsey, and that he is now a naked trespasser on said land, and is attempting to fraudulently keep possession of same. They charge that defendants Crockett and William Maynard have rented said lands for the year 1900 from their sister and aunt L. J. Ramsey, and under and by virtue of the decree of the Circuit Court ___ ____ is for peaceable and quiet possession of said lands.

Defendant L. J. Ramsey charges that by virtue of said Circuit Court decree a writ of possession issued and went into the hands of the Sheriff of Jackson County, Tennessee; that said Sheriff went on the premises and dispossessed said H. A. Ramsey except one barrel of molasses and some corn; that he locked the doors of the dwelling house and rode off, and that before he got out of sight of the premises complainant's wife and children went on the premises, broke open the doors and again entered into possession of the same before defendants were ever notified that complainant had been partly dispossessed and before defendants had time to take possession themselves. Therefore defendant L. J. Ramsey filed a petition in the Circuit Court of Jackson County at its March term, 1900, and caused an alias writ of possession to issue to place her in the quiet and peaceable possession of said land; that is this alias writ that is now in the hands of the Sheriff.

Defendant L. J. Ramsey is a sister of Crockett Maynard and an aunt of the defendant William Maynard.

Deft L. J. Ramsey states that since complainant has been in possession of said lands he has filled up and totally destroyed a bored well on the place worth $100.00 , has said that if she didn't rent him the land he would take it away, that he would keep her out of possession of said land that he would keep it in law, that it should never do her any good. Complt H A Ramsey is insolvent and nothing can be made off of him by process of law.

Deft L.J. Ramsey again denies that she ever contracted to rent said lands to complt H A Ramsey and that she has rented same to Crockett & Wm Maynard as heretofore stated.

Having fully answered Defts pray to _____ with ____. John J. Gore, Sol. for respondents

Mch 19, 1900, B A Butler, C & M [Signed] L. J. Ramsey, D. C. Mainor, W. D. Mainor

TO THE Hon. ? J. Fisher, Chancellor ___ ____ ___ ____.

The bill of complaint of H. A. Ramsey, a citizen of Jackson County, Tenn. ~ VS ~

L. J. Ramsey, Crockett Maynor and Wm. Maynor of like residence

Complt will show to the court at the July term of the Circuit court at Gainesboro the following with which lands were assigned to the deft L.J. Ramsey as homestead ["and dower" marked out] to wit: ~

Lying in the 14th civil district of said county, on the waters of Fun's branch, containing about 30 acres more or less, being a portion of the lands formerly belonging to Henry Ramsey decd, consisting of the house where complt now lives on said Henry Ramsey farm and the lands are located as follows - North by K.T. and Mary Sircey; east by L.J. Ramsey's homestead, south by said dower and west by James Kent, and including all the stubble and stalk lands inside of said boundry.

Complt charges that after said lands had been assigned to Deft L.J. Ramsey as aforesaid the complainant rented the same from her for the year 1900 for one third of the crop.

Complt charges that in violation and disregard of said contract the said deft has fraudulently caused a writ of possession to issue from said Circuit Court the sheriff of [line unreadable] and put Defts in possession of said land, which writ is now in the hands of the Sheriff of said county who will execute the same and turn complt out of possession of said land unless restrained by injunction.

Defts are insolvent and if they are permitted to dispossess complt it will work irreparable injury to complt.

The defts Crockett and Wm. Maynor are taking control of said land and attempting to cultivate said [line unreadable] with complainant in the possession of said land and are unlawfully attempting to oust him in his possession of said land under his said contract.

Complt prays that this bill be filed; that copy and process issue to bring defts before the court as defts; returnable to April ?rules 1900, that they answer this bill but not on oath; that injunction issue to enjoin defts from the execution of said writ of possession either by themselves or by any other person, or from interfering with complt in the possession and control of said house and lands above described until the termination of his rent contract for the present year, and upon a final hearing that his rights to said house and lands be established __ ___ of this court and he prays for general relief [4-5 words unreadable] application for injunction in this case.

15 Mch 1900 [Signed] H. A. Ramsey [Signed] W. W. Draper, Solicitor

[NOTE: Copy of Writ of Injunction in file to enjoin L. J. Ramsey, Crockett Maynor and Wm Maynor from dispossessing H. A. Ramsey until case is heard September 1899 - mlj].

Security Bond 24 April 1900: We L.J. Ramsey, Crockett Maynor and Wm Maynor principals and J. T. Smith, Securities hereby acknowledge ______ indebted to H. A. Ramsey in the sum of One hundred Dollars

But the conditions of this bond are such that whereas in the case of H. A. Ramsey vs L. J. Ramsey etals now pending in the Chancery court of Jackson County Tenn, an Injunction writ has heretofor been granted by Hon T.J. Fisher Chancellor __ and executed on the parties which writ enjoined the parties defts hereto from executing the writ of possession to place L J Ramsey in possession of the land described in the Decree of the Circuit Court of Jackson County Tenn in the case of L J Ramsey etals vs Walter Sircy etals & whereas said injunction writ is by order of the Chancellor, ordered to stand dissolved upon Deft executing a Refunding bond in the sum of One Hundred Dollars. ?Now if defts shall well ?and truly refund & pay to H. A. Ramsey the full value of the rents of said land for yr 1900, described in said writ of possession & Injunction writ in the event they shall be ?cost in the suit of H. A. Ramsey vs L J Ramsey etals order ___ ____ ___ the Court ?shall decree [cannot read lines at bottom this page or top next page; dark].

April 24, 1900 [Signed] L. J. Ramsey; Crockett and Wm Maynor*; J.T. Smith; L.P. Mainor

[*Looks as thought "Crockett and Wm Maynor" were signed by same person]

Deposition of H. A. Ramsey, Office of the Clerk & Master in Gainesboro, 3 April 1900:

H. A. Ramsey, sworn, states he is Complainant. J. J. Gore, Sol. for Defts.

[H. A. Ramsey asked to tell about the circumstances of renting, replies]:

"Along early in the spring me & L J Ramsey was talking of the trade at the time we had this talk she wanted to move down where I lived, and she asked me if I hadent ["I had" inserted above] just as soon live where I [two lines not readable] wanted to live where I now live and wanted me to move up where she lived then she went off some where and was talking about a trade between her and Dr Ragland and she says to me then Brother Press told me he thought __ if she rented out the land it would be right for me to have it provided I would do her right, then I told her if she did close out the trade with me I would rent it for 2 or 3 or 5 years and if she ever found me defrauding or cheating her any way that I would get out and give her possession this talk all occurred a long in the spring of the last year 1899 and as well as I remember I sent for her to come down to my house along about the last of July we threshed wheat on the 12 July and this was after that after the July term of the circuit court and she come down to my house and I asked her when she came if I could rent the land from her for the year (1900) I told her it was time I was knowing what I was going to do the next year. I asked her if she wanted to rent to me and she says I had just as soon rent to you as any body, then I told her in the beginning of our trade if I say any thing that don't suit you you say no, and if you say any thing that don't suit me I will say no plain talk is easy understood and she wanted me to cover one side of the house that I then lived in and help to make a new fence and I told her I would not do it but after we closed out I agreed to make some rails.

[H.A. Ramsey asked if he in fact rented the house & land]:

"Yes sir but I dident rent the house separate and apart from the lands.

[H.A. Ramsey questioned about terms, replied]:

"I was to give her 1/3 of what growed [can't read line]...year 1900...no one present at beginning of trade but my family...Walter Wilkerson & Lex Ramsey ...come in...heard the closing out of our trade.

[Questioned about later conversations regarding trade, H.A. Ramsey states]:

"I cant state exactly when it was but it was some time after the line was run [setting aside her dower and homestead] but I don't know when the line was run.

She remarked to me that Mr. Butler said that our trade was null and void and I ses [says] well I guess Mr. Butler knows I have never investigated it.

And I rented from her again on the same terms that I first rented from her. ___ the understanding if I left there I would give her the refusal of the land back. [This conversation] occured at her house as well as I remember.

[Asked about later conversations]:

"We had another talk between the 16 and last of Sept. 1899. She asked me if my corn would keep I told her no. I asked her why she said she wanted to sow some wheat and I asked her where she said she wanted to sow on the lower side of the hill, that is she ____ ____ so on a piece that I have now got rented. I asked her if I had ever given it back to her and she said [can't read line] she had understood that I had rented other land and according to contract she had the refusal of it back, and I told her I had not rented the other lands she said she dident want me to hold the land until spring and then give it back I told her I would let her know by Monday or Tuesday night I went up there a Monday night and told her she need not put herself to any more trouble that I was going to tend it that was about the last conversation we had concerning the rents.

~ Cross Examination~

[H.A. Ramsey questioned as to when/where agreement made, who was present]:

"There was no one present at the last trade between me and her except me and her...The best I remember it was at her house...some time after the land was laid off to her as homestead and dower...Aug 1899 as I now remember.

[Asked if he made rails or built fence as agreed under first contract]:

"No I have not made the rails yet but there is plenty time to make them I have been ready to make them a good while. I have just been waiting for them to notify me when they got ready but they have not done it I was ?not to make the fence.

[Asked about L.J. Ramsey stating her Atty B. A. Butler stating contract was illegal]:

"I told her that if Butler told you that, I reckon it was that way, and I said if it is null and void, I want you to say whether you want me to tend the land or not, and if not just say so, and she said I want you to tend the land, and we just renewed the very identical trade as the first one except it was agreed that if I left there I was to give her the refusal of it.

[Q: Now under which contract do you claim the right to this land, the one made before the homestead was laid off, or the one after the homestead was laid off?]:

"I claim the land under all of my contracts if it takes them all to hold it [cannot read line].

[H. A. Ramsey was asked whether L.J. Ramsey told him her brother Press Maynor was handling her affairs, and to go see him]. "No Sir

[When asked if he went to see Press about it, H. A. Ramsey said he went to see Press as to whether L.J. Ramsey had deeded her brother the place "I did not go to see him individually for myself, but I went to see for another man". Ramsey denied offering Press Ramsey $50 a year.

[Q: Didn't you also say to Press on that trip that if you couldn't rent these lands from him, that you didn't care who he rented it to just so he didn't rent it to Bob Kent]?

"No Sir. I may have said that concerning the land I had not rented but the land I had rented I put myself to no trouble about that. I have not proposed to rent that from him. There is about ?15 acres I have not got rented.

[Q: Did you claim to Press on that day that you had any of this land rented]?

"I don't know as I did I asked Press __ __ ___the land sold if L J Ramsey said any thing about my renting ___ the land and Press said she did. I ask Press this question here in Gainesboro.

[Q: Didn't you go off down to Smith County and rent other lands, ____ late in last fall and didn't you say after you came back that you had rented lands in Smith Co.

A: No Sir [Signed] H. A. Ramsey

Walter Wilkerson, witness for Complainant, states he was at the house of H. A. Ramsey when conversation occurred July 1899 between H. A. and L.J. Ramsey concerning renting Henry Ramsey land, knows the parties...when I went in she stepped out and H.A. Ramsey asked her if she was going to let him have it ["the land" marked out and "it" inserted] & she said Yes, and H. A. Ramsey said How are you going to let me have it and she said Just like I always let you have it. [Signed] W. T. Wilkerson

W. R. Thomas of lawful years, Witness for Compt., stated he had a conversation with L. J. "last summer some time". Stated he saw her in the road and she said she had let Harvy Ramsey have some land..."She did not say this year but I just took it for this year it was past renting time for last year". ~ Cross Examine ~

"This conversation occurred after ?we laid off L.J. Ramsey Homestead & Dower. It was before Jno Cale established the line. The line had been established by us and Jno Cale said he just come then to make the line. This conversation occurred before wheat threshing as well as I can recollect but I ?wont positive about whether it was before wheat threshing or not, but I think it was. W. R. [his X mark] Thomas

Witness W. P. Holmes of lawful years for Complt stated he knew L. J. Ramsey; spoke with her "at Mr. Jno McCully some time last summer"...she did not deny contracting him [H. A. Ramsey] some land..." ~ Cross Ex ~

"Mrs. L. J. Ramsey also said to me in that conversation, that H. A. Ramsey had come and give her the land back, and she said that even if he had not, that ?he/his ___ had told her that the contract was no account anyway - that she had no land at that time to contract."

[Signed] W. P. Holmes

Witness Robert A. Kent, of lawful years, sworn, states:

"I know L J Ramsey. I had a conversation with L.J. Ramsey last summer in which she said she had promised H.A. Ramsey the land, but had not closed out. This conversation occurred some time in July 1899. I had spoken to L.J. Ramsey before that time to rent the land for this year. We had come to an agreement about it. She afterwards told me that she had promised H. A. Ramsey the land but she never did say she had rented it to him. She declined to let me have it. Lex Ramsey, Fite Franklin and Tom Maynor's wife was present for a little while. She said that H. A. Ramsey was to give her 1/3 if he taken it, but she ___ ___ ___ have not closed out. This ___ some time in July. I don't know whether Circuit Court had adjourned or it was then in session, it was some time in July.

Cross Ex

"I live on an adjoining farm to the land in litigation. In a conversation with L. J. Ramsey ____ she would not have promised the land to H. A. Ramsey if it had not been for his bluffing talk. This was ?not the first conversation I had with her.

H. A. Ramsey told me that nobody but him or Baily Ramsey could tend this land as long as him or his Bro wanted it, in peace and harmony."

[Q: Did not L J Ramsey move away from there because she was afraid of H.A. Ramsey]

A: I don't know whether she was afraid of H.A. Ramsey or not, but my ____ is she was afraid of the Ramsey lay out. [Objected to the above Quest & Ans. Draper Solr]

A: L.J. Ramsey told me that she was going to get Press Maynor to look after her business and she told me of advice that Press had given her which she thought was good. [Objected to by Draper Solr]

I spoke to Press Maynor about renting L.J. Ramsey land several times. H. A. Ramsey came to my house several times after a saddle hunting him a place [line cut off in copying]

The first time he borrowed the saddle until the last time it was scattered along 2 1/2 ___ worth. He borrowed the saddle as late as October. H. A. Ramsey went down about Dixons Springs to see Owen Haily about a place in McClures bend so he said about it.

H.A. Ramsey told me that L. J. Ramsey was coming home and he did not blame her. She said he told her that if he did not get a house close enough to tend the land that he would subrent it or let her have it back. H. A. Ramsey said L. J. Ramsey was coming home, and that is the house that ?U. A. Ramsey now lives in. She told me in the beginning that if he had to leave that house he was going to leave the whole place. That was along early last summer.

After the sale of the land and before it was ____ we was talking about that land [2 or 3 lines can't read] will be to rent. [2+ lines can't read] claimed it was under a contract from Henry Ramsey.

The fences aroung the place are sorry enough and very sorry. The fences at the present time are not any worse than they were when I first came to the neighborhood. Crockett Maynor has fixed up about the worst places.

The fence was lower round the house when H. A. Ramsey lines this fall than it was the spring. I don't think H. A. Ramsey cultivated his land ?properly last year.

H. A. Ramsey told me that if he had to go to law that he was of a disposition that he would ___ ____ self five years at a time before he would be beat.

~ Re examination ~

H. A. Ramsey claimed that he had closed out with L J Ramsey and their condisions he was speaking of came in all along. H. A. Ramsey did not make any fence last year that I know about. I don't know of his hiring Hite Franklin to make cross rails on the road

When L J Ramsey told me that she would not have rented the land to H A Ramsey if it had not have been for his bluffing talk to her, it was not but a little while after she had told me she had promised H A Ramsey the land It was before September. It was on Monday after U A Ramsey had claimed that he had rented the land on Saturday some time in July, that U A Ramsey told me that no one could tend the land in peace and harmony except Baily Ramsey or H A Ramsey. This was ?at H A Ramseys house. I don't remember of any one being present ?but H A Ramseys family and I don't remember whether they were present or not. If his family were present I don't remember it. It may have been we were setting [3 lines can't read] H A Ramsey wanted my saddle I always let him have it when I was not using it, and when it come around ____ he told me he was going to look for him a place, though I never asked him about it. He borrowed the saddle off and on for 2 1/2 or 3 months. H. A. Ramsey borrowed my saddle when he said he wanted to go and look at a place of Owen Haileys. H. A. Ramsey went a foot on the day he went to see Owen Haileys was very understanding. I would not be positive but it seems to me like it was the last of September or some time in Sept when he went to see H.A. Ramsey. It was a drought year last year. A portion of ?H/U A Ramsey crop was good. I do not know whether it averaged with the neighborhood or not. I never heard L J Ramsey say much about this suit.

Quest[ion]: Have not the Maynor boys Press and the other Maynor boys interfered to prevent H A Ramsey from carrying out his rent contract

A[nswer]: I never heard them say any thing about it. I heard Crockett say if he did not enjoin him or notify him according to law he intended to go ahead with his work. Crockett Maynors boys are plowing there.

Q: Has not Press Maynor been very active in trying to get U A Ramsey off of that place and in looking after this suit for defendant?

Objected to by Defts Gore, Sols

A: Well I have not been present with him in transacting such business.

Q: Is he not here to day looking after the case assisting the Solicitor for the Defts.

A: He is here; he seems to be here presently. He seems to be in business.

Q: Is he or not setting close to the defts lawyer & consulting with [3 lines can't read] complainants generally?

A: I saw him talking to Job/John J_____ _____. He has been ____ ____ close to him. Don't know whether he is assisting him or not. Don't know what he is whispering to him I cant here it.

Q: Don't you know as a fact that there would never have been any trouble between Mrs. Ramsey & ?Her if it had not been for the meddling of these Maynor boys?

A: No sir, I don't know it.

Q: Is or not Crockett Maynor trying & has he or not been trying to get possession of this land & trying to get H.A. Ramsey off of the land.

A: I reckon he has.

Q: Have you not heard one or all of these Maynor boys talk about this suit & about the matters before the suit was brought in a was that was calculated to stir up Mrs. Ramsey & make her mad with Harve Ramsey?

Objected to because leading

A: I don't know that I have

Q: Is or not 1/3 of the crop reasonable rental for the land in controversy?

A: No sir. Not according to custom. Down in our Country we give 1/2 or $3.00 per Acre. Where a man don't have any fencing to do he always gives 1/2 ?and sometimes give $5.00 per Acre.

Q: Where the fences are bad & a portion of the land is stalk land as in this case is not 1/3 of the crop a reasonable rental

A: No sir.

Q: Stalk land rent for as much as stubble

A: We don't find much difference if any. Yes. I give 1/2 last year for stalk land last ?year and would like to have 5 or 6 Acres for land this year at the same price.

Q: Considering the bad state of the fences & the fact that they must be repaired & a portion is stalk land - Do you ____ _____ ____ is worth rental [can't read a line]

A: _____ I offered the widow it is worth right at that ____ the ____ portion. I offered her ____

Q: How much did you offer her

A: I offered her 1/3, and fix the fences all up, to cover one side of the house, and build a porch, and go to ?mill for her, and get her wood, and to do any accommodation for her when it was in my power.

Q: Was you to get the whole place

A: No Sir. I was just to get the part Mr. Ramsey has got, supposed to be 18 or 20 acres.

Q: How often has Press Maynor talked to you about this suit

Objected to Gore Solr

A: I don't know

Q: How often has Crockett Maynor talked to you about it

A: I don't know.

Q: More than once?

A: I don't know, I never kept ____ ___ it.

Q: Are not your sympathies strongly in favor of Defts in this case?

Objected to because not competent, this being a witness introduced by the Compt. Gore, Sol.

A: I am in sympathy with H. A. Ramsey, the man with a family, taking every thing in consideration; knowing he is needy.

Q: Are you not in sympathy with L.J. Ramsey & wish her to win this suit

Objected for same reason. Gore Solr.

A: I couldn't say that I was. I am sympathy that Justice may have its course.

~Re X Examined ~

Q: Is this not extra good land that lays well and easily cultivated?

A: A portion of it is extra good & some tolerably thin - some of it is steep & some of it lies well.

Q: So taking the whole thing into consideration, what do you think would a reasonable rental [can't read a line] Is it worth 1/2?

A: Yes.

Q: Is Press Maynor not a brother to Mrs. L. J. Ramsey and all the Defts?

A: He is a brother to her & Crockett & Uncle to Wm Maynor. [Signed] R. A. Kent

[NOTE: This appears to be the same Complaint & Answer that was retyped by a clerk from the original handwritten filing - mlj]

15 March 1900, Bill of Complaint of H. A. Ramsey vs L. J. Ramsey, et als, Circuit Court, Jackson County, Tennessee} To the Hon. T. J. Fisher chancellor presiding at Gainesboro Tenn. The bill of complaint of H.A. Ramsey, a citizen of Jackson County, Tenn. Vs

L. J. Ramsey, Crocket Maynor and Wm Maynor of like residence.

Complt will show to the court that at the July term of the circuit court at Gainesboro the following with other lands were assigned to L.J. Ramsey as homestead to-sit: Lying in the 14th civil district of said county, on the waters of Fun's Branch, containing about 30 acres more or less, being a portion of the lands formerly belonging to Henry Ramsey deceased consisting of the house where Complt now lives on said Henry Ramsey farm and the lands are located as follows; North by K. T. & Mary Sircy; East by L.J. Ramseys homestead; South by said dower and west by James Kent, and including all the stubble and stalk lands inside of said boundary.

Complt charges that after said lands had been assigned to deft L.J. Ramsey as aforesaid the complainant rented the same from her for the year 1900 for one third of the crop.

Complt charges that in violating and disregard of said contract the said deft has fraudulently caused a writ of possession to issue from said Circuit Court directing the sheriff of said county to dispossess your complainant and put defts in possession of said land, which writ is now in the hands of the sheriff of said county who will execute the same and ___ Complt ?out of possession of said land unless restrained by ?an injunction.

Defts are involvent and if they are permitted to dispossess complt it will work irreparable injury to complt.

The defts Crockett and Wm Maynor are taking possession of said land and attempting to cultivate said land for the year 1900 in violation of Complt's rights and are unlawfully interfering with Complt in the possession of said land and are unlawfully attempting to oust him in his possession of land under his said contract.

Complainant prays that this bill be filed; that copy and process issue to bring defts before the court as defts returnable to april rules 1900 that they answer this bill but not on oath; that Injunction issue to enjoin defts from the execution of said writ of possession either by themselves or by any other person, or from interfering with Complt in the possession and control of said house and lands above described untill the termination of his rent contract for the present year, and upon a final hearing that his rights to said house and lands be established by decree of this court and he prays for general relief.

This is the first application for injunction in this case. [Signed] W.W. Draper Solicitor.

H.A. Ramsey Complt in the foregoing bill makes oath in due form that the statements in the foregoing bill are true, and that owing to his poverty he is unable to bear the expenses of this suit or to give bond for the injunction prayed for and that he is justly entitled to the redress sought by said bill to the best of his knowledge and belief. And subscribed this affidavit in my presence. This Mch 15, 1900 [Signature typed] H. A. Ramsey

Sworn to and subscribed before me This Mch 15th 1900. B.A.Butler C.&.M.

Endorsed Filed Mch 16, 1900 at 3, O,clock P.M. B.A.Butler C.&.M.

The joint and separate answer of L.J.Ramsey, Crockett Maynor and Wm. Maynor, to the bill of complaint of H.A.Ramsey, filed against them in the Chancery court of Jackson county Tenn. On the 16th day of March 1900.

They admit that at the July term of the Circuit Court at Gainesboro certain lands were assigned to L.J. Ramsey as homestead and that said land are properly described and bounded in Complts bill in this case they suppose.

Deft L.J.Ramsey positively and emphatically denies that she ever rented these or any other lands to Complt H.A.Ramsey for the year 1900 ?or for any other year or time.

Defts positively deny that in violation and disregard of said rent ____ they fraudulently caused a writ of possession to issue to dispossess complts of said lands and to put Defts in possession of the ____; but the truth of this matter is that complt H.A.Ramsey was unlawfully and forcibly withholding said lands from deft L.J. Ramsey; and in compliance with the Circuit court decree she did cause to be issued a writ of possession to place her or her agent in possession of the same; that the complt had no right to the possession of said lands.

The charge in Complt's bill that deft Crockett Maynor is insolvent and that if defts are permitted to dispossess Complt it will work irreparable injury to complt is false and untrue and is here positively and emphatically denied.

Defts deny that Crockett and Wm Maynard are taking possession of said lands and attempting to cultivate it in violation of Complts rights and are unlawfylly interfering with Complts in the possession of said lands and are unlawfully attempting to oust him in his possession of said land under his said contract. They again charge and say that Complt has no right to the possession of said land and has no contract with deft L.J. Ramsey, and that he is now a naked tresspasser on said land, and is attempting to fraudulently keep possession of same. They charge that Defts Crockett and Wm Maynard have rented said lands for the year 1900 from their sister and aunt, L.J. Ramsey, and under and by virtue of the decree of the circuit court are entitled to the peaceable and quite possession of said lands.

Deft L.J. Ramsey charges that by virtue of said circuit court decree a writ of possession issued and went into the hands of the sheriff of Jackson County Tenn.; that said sheriff went on the premises and dispossessed said H.A. Ramsey except one barrel of molasses and some corn; that he locked the doors of the dwelling house and rode off, and that before he got out of sight of the premises Complts wife and children went on the premises, broke open the doors and again entered into possession of the same before defts were ever notified that Complt had been partly dispossessed and before defts had time to take possession themselves. Therefore deft L.J. Ramsey filed a petition in the ciruit court of Jackson county at its March term 1900, and caused an ?alienation of possession to issue to place her in the quite and peaceful possession of said land that it is this alias writ that is now in the hands of the sheriff.

Deft L.J. Ramsey is a sister of Crockett Maynard and an aunt of the Deft William Maynard.

Deft L.J. Ramsey states that since Complt has been in possession of said lands he has filled up and totally destroyed a bored well, on the place worth $100.00 and has said that if she dident rent him the land he would take it any way, that he would keep her out of possession of said land that he would keep it in law, that it should never do her any good

Complt H.A.Ramsey is insolvent and nothing can be made off of him by process of law.

Deft L.J. Ramsey again denies that she ever contracted to rent said lands to complt H.A. Ramsey, but that she has rented same to Crockett and Wm Maynard as heretofore stated. Having full answered Defts pray to be dismissed with cost. John J. Gore Solr for Respondents

State of Tennessee ------Jackson County.

Personally appeared before me the undersigned L.J.Ramsey, Crockett Maynor and Wm Maynor who makes oath in due form of law that the statements in the foregoing answer are true and sworn to and subscribed to this affidavit before me This March 19, 1900.

[Names are typed; not in original handwriting] L.J.Ramsey, D.C.Maynor, W.P.Maynor

W.A.Butler, Clerk & Master of the Court, certification [Signed] B.A. Butler Clerk & Master

STATE OF TENNESSEE JACKSON COUNTY...TO THE SHERIFF OF SAID COUNTY GREETING. [Note: This may have been retyped from the original handwritten document- mlj]

Whereas, in the cse of L.J.Ramsey admrx & et als vs Walter Sircy et als lately determined in the Circuit court of Jackson county, Tennessee by final decree in which the lands herein after described were laid off in kind to L.J.Ramsey widow and relict of Henry Ramsey deceased as homestead which lands are described as follows: Beginning at a small poplar in the east bounday line of Kents land; Thence east 165 poles to an elm; Thence south 107 poles to a stake; the south east corner of the original tract of 350 acres granted by the State of Tennessee to J.B. Woodford; Thence west 165 poles to Kents corner; Thence north 107 poles to the beginning, containing 108 acres excluding however about 40 acres of said tract heretofore sold by Henry

Ramsey deceased to Bailey Ramsey and the line of the homestead adjoining said tract so sold off will run with the line of said tract on that side.

Tract No. 2. part of homestead about 21 acres on the lower portion of said tract which divides the remainder of said tract by a division line agreed on by the parties which is marked and all of tract No. 2. that lies on the side of the road where the dwelling house now stands and including the dwelling house, out houses &c, and this is bounded as follows: Beginning on a scrubby beech the north east corner of tract No. 1.---a sugartree and beech pointer; Thence southward with the meanders of the branch to a beech on the east side of the branch; Thence on said direction with the meanders of the branch to a stake in the center of the Woodfork & Granville road near the spring; Thence southward with the meanders of the road to a stake near the corner of a little field; Then eastward to a beech---a fore and aft tree on the bank of a stream; Thence on said direction to a mulberry marked a fore and aft Thence on same direction to an Ironwood marked a fore and aft; Thence on same direction to a stake in the west boundary line of the Woodfork land as a corner to the Bailey Ramjsey tract.

And Whereas, at the July term 1899 of said Circuit Court said lands above described were ordered, assigned and laid off to L.J. Ramsey widow &c, of Henry Ramsey deceased as homestead and a writ of possession was ordered to issue to put L.J.Ramsey in quite and peaceful possession of all of said lands.

Now therefore you are hereby commanded to forth with put in immediate, quite and peaceable possession of all the above described lands the said L.J. Ramsey and you will eject, if necessary all and every person in the boundaries of said land that is attempting to hold any part of said boundary against the wishes of the said L.J. Ramsey and if necessary you will use the force of the county to execute this writ and you will make due return of this writ showing how you have executed the same.

Witness Clay Reeves cl'k of our said Circuit Court at office in Gainesboro Tennessee the 1st Monday in March 1900 and 124th year of American Indipendance. [Signed] Clay Reeves Clerk.

[The below may have been retyped from original handwritten-mlj]

L.J. RAMSEY VS WALTER SIRCY et als

To the Hon. W. T. Smith Judge &c Presiding in Gainesboro Tenn. The petition of L.J.Ramsey who is a citizen of Jackson county Tenn.

Against

Harvey Ramsey and his wife Julia Ramsey citizens of like residence

Petitioner would respectfully represent and show to your Hon. that at the [blank] term 1899 of the Circuit court of Jackson county Tenn. Your petitioner as widow and relict of Henry Ramsey deceased was assigned homestead out of the lands of the said Henry Ramsey deceased, in kind which lands are fully described in decree Minute Docket "K" page [blank] of your Hon's court and is refered to for contents. A writ of possession was awarded by your Hon. to put petitioner in the quiet and peaceable possession of said lands and every portion thereof, which lands included and there is sistuated on said lands a dwelling house then occupied by Deft Harvey Ramsey said lands are also fully described in the writ of possession issued in persuance of said decree and returned to this court which writ is also refered to for contents and is made a part and parcel of this petition.

Your petitioner will show your Hon. that the writ of possession awarded by said decree was regularly issued by the clerk of this court on Jan. 4tth 1900 and came to the hands of the sheriff W.H.Sadler it is supposed on the same day issued but as to this the return does not show.

Petitioner shows that on Jan. 31st 1900 the sheriff went on the lands and attempted to and did as she is informed and believes put Deft Ramseys family out of the house ______ __ ___ land and locked or nailed up the doors and informed the parties ejected that he would place petitioner in possession of said house but before the sheriff court get back __ the house of petitioner a short distance and ?inform her of ?what he had done and place her in possession as it was his duty to do Deft Julia Ramsey as petitioner is [5-6 words can't read] of said house by breaking down or [8-10 words can't read] possession of said house in [line can't read].

Your petitioner charges that at the time of the attempted execution of the writ petitioner was confined to her room and was unable to take possession of the house her self but thought that she had an arraignment [?arrangement] and understanding with the sheriff that when he executed the writ he would notify her brother Press Mainor of the time so that he could be present and take possession for her as her agent. She is informed and believes that the sheriff failed to notify her brother of the time he would execute the writ and that her brother Press Mainor had no knowledge as to when the same would be executed.

Your petitioner charges that the sheriff upon leaving the place or soon thereafter as petitioner is informed and believes, remarked to diferent persons that he was satisfied that the Defts family whom he had just put off the place, had all ready gone back and regained possession; the sheriff however remarked that he had done his duty in the matter and that he had no power under the writ to do any thing else and refused and is still refusing to execute the writ by again putting defts family out of possession and placeing petitioner in quite and peaceable possession of said land.

Your petitioner charges that said writ was never executed in legal contemplation on account of the sheriffs failure to put petitioner in the quite and peaceable possession of said land. It was his duty to have remained on the place untill petitioner or her agent had been placed in said house and defts had been entirely removed off the premises and not have shown any determination to have regained possession of same which did not exist in this case as petitioner is informed and believes but she charges that the act and conduct of Deft Julia was sufficient to show the sheriff that they intended to set at all naught all his acts in the matter as soon as the sheriff got out of signt. To say that this was an execution of the writ is an absurdity. Petitioner states that even if she had ___ified of the first time that Sheriff had put Defts out of the house [6-8 words can't read].

Deft Harvy Ramsey as Petitioner is informed and believes after he was informed about the officer throwing his family out of the house (he Harvy Ramsey being absent when done) but returning that evening, has remarked that he did not intend to give up the possession at all, and said that when they put him out he would go back or ___ and that whenever he was put out again he would go back on.

Contempt against the process of the Honorable court and defts should be held on said charge and Petitioner asks that an attachment writ issue to attach the bodies of said defts and that they be dealt with as the court may think right and proper.

Petitioner also asks that an alias writ of possession be awarded in order that she may be placed in the immediate possession of said house and lands. Petititioner prays that such orders be made in this case as the court may see proper without process as the case of L.J. Ramsey admr vs Walter Sircy is still pending in this court. She prays for general relief.

[Typed names] D.B.Johnson & B.A. Butler Sols for Petitioner.

State of Tenn---Jackson County.

Personally appeared before me the undersigned Press Mainor agt of L.J. Ramsey makes oath in due form of law that the statements in the foregoing Petition are true to the best of his knowledge information and belief and sworn to and subscribed to this afft before me on this Mch 6th 1900. [Signed] L. P. Mainor

Sworn before me... [Signed] Clay Reeves, Clk

[New document, can't read 2-3 words in crease. Typewritten]

___ ___ joint and several of Walter Sircy, Bluford Francis Sircy, _____ May Ramsey and LC. Ramsey minors under the age of 21 years ___ ___ Guardian adlitem and Solicor John Cale to the bill of [Can't read next two lines]

Reserving unto themselves and himself the benefit of the usual exceptions to said bill answering says: Admit that Henry Ramsey died intestate in Jackson County Tennessee at the time stated in the bill and that he died seized and possessed of the lands described therein.

Admit that the heirs of Henry Ramsey are properly set out in said bill. Admit that L.J. Ramsey is the widow and relict of Henry Ramsey deceased and that she is entitled to Homestead in sand lands. Admit that deceased was indebted to some extent at the time of his death but to what parties and in what amount he does not know and requires proof. Suppose it true the lands that is proposed to be laid off to the widow for Homestead will be a just and equitable division ___ ____ ___ to her for homestead in said lands, but as to this the court is asked to look after and protect the interest of his wards. Admit that the personal estate left by deceased is but small but as to whether or not it is sufficient to pay the debts of decease they neither admit or deny but requires proof. Respondent for wards ask the court to fully protect the interest of his wards; and now having fully answered prays to be hence dismissed with costs &c

[Typewritten] John Cale Guardian adlitem & Solicitor

State of Tennessee, Jackson County

Personally appeared before me the undersigned John Cale Guardian Adlitem for Walter Sircy, Bluford Francis Ramsey, Annie May Ramsey and L/C/Ramsey minors who makes oath in due form of law that the above and foregoing answer is true to the best of his knowledge information and belief and sworn to and subscribed to before me this July 6th 1899 [Signed] John Cale

Sworn & Subscribed to before...Clay Reeves

L.J. RAMSEY, Admx &c Etals

VS Report of Clerk on Reference

WALTER SIRCY Etals

I Clay Reeves clerk of the Circuit court of Jackson county Tenn in obedience to an Instanter order of reference made at the present term of this court made herein took proof at the time and place mentioned in the Order of reference from which ___ ___ ords in this case report as follows:

Upon the first question I report that Henry Ramsey died the owner of and seized in fee of the lands described in Exhibits A and B to L.J. Ramsey deposition which Exhibits are refered to and made part of this report as to boundaries &c.

Upon the Second Question refered I report that the lands that is proposed to be laid off in the bill in this case to the widow Mrs L.J. Ramsey as Homested is a reasonable and proper allowance to her and the same is not worth over $1000-in point of fact is not worth that there being only about 85 acres of said land so allotted to her which is not worth over $7 or $8 per acre (see the depositions of J.H.Howell page [blank] this record and also Dep of WH. Brooks Page [blank] this record.

Upon the 3rd question I report that there has been nothing nor will be an thing collected of personal assets out of which to pay the just, valid and subsisting debts of said estate of said deceased and the admx had before the filing of the bill in this case duly and legally suggested to the county court of Jackson county Tenn the insolvency of said estate (See the Dep of L.J. Ramsey Rec P [blank]. There will never be any personalty available for the payment of debts (See L.J.Ramsey Dep P [blank]

Upon the 4th question I report that it will be necessary to sell the lands or a portion there of described in the bill to ____ decedent or all the balance of the lands after laying of Homestead to the widow including the reversionary interest ___ said Homestead. The lands to be sold lie on the upper end of Tract No [Can't read] upon the parties. See Dep of L.J. Ramsey [Can't read two lines] to be sold upon the terms described in the decree.

Upon the 6th question I report that the estate of Henry Ramsey ?deceased was indebted at the time of his death to the following _____ __ the amounts annexed to their names towit:

To Dr. J. Shepherd in the sum of about $48.00

To Dr Boyd in the sum of about $15.00

To A.R. Dean in the sum of $ 8.50

To Douglas Carver and John Clinton in the sum of $50.00

To H.A. Ramsey in the sum of $53.00

To B.D. ramsey in the sum of $24.00

To W.H. Brooks in the sum of for costs of administration

And expense thereof in the sum of about [blank]

The above indebtedness was all due, just and valid debts of the said Henry Ramsey deceased. See Dep of L.J. Ramsey P [blank] and Exhibits in record See also Dep W.H.Brooks P [blank]

I respectfully make this report to the July 1899 Circuit court. [Typed] Clay Reeves Clerk

[A typed copy of the original transcript and the original follow each other on microfilm; I compared both documents to get the most accurate transcript possible - mlj]

To the Hon. W.T. Smith Judge of the 5th Judicial Circuit of Tennessee presiding in Gainesboro Jackson County Tennessee.

The bill of complaint of L.J. Ramsey Admrx of Henry Ramsey Deacd and also as widow and relict of the said Henry Ramsey dec'sd, H.A. Ramsey, B. D. Ramsey, C. W. Ramsey, Vaddie Sircy and husband G.R. Sircy, Cora Hughes and Husband Thomas Hughs, Tennessee Dixon and husband T.F. Dixon, Beverly Sircy, Ethy Sircy all citizens of Jackson County Tennessee except Beverly Sircy who is a citizen of Smith CO Tenn.

Against,

Walter Sircy, Bluford Francis Ramsy, Annie May Ramsey, L.C. Ramsey, Dr. _____ Boyd, Douglass Carver & John Climer, D. J. Shepherd, A.R. Dean all Citizens of Jackson County Tenn.

Your Complainanats will respectfully represent and show to your Hon. that Henry Ramsey departed this life intestate in Jackson Co. Tenn. on the 27th day of March 1899 leaving Complts & Defts as his heirs at law except defts. Shepherd, Boyd, Dean, Carver and Climer. The defts Walter Sircy, Lex C. Ramsey, Bluford F. Ramsey & Annie May Ramsey are Minors under the age of 21 years without general gardian being children and grand children of the said Henry Ramsey dec'd.

Complts will respectfully show to the Court that the said Henry Ramsey died seized and possessed and the owner in fee simple of the following described lands to-wit:

1st Tract bounded on the South by Woodward W. by James Kemp on the North by K.T. Sircy & Mary Sircy on the E. by tract no. 2 or lands that Henry Ramsey purchased from Mary L. Stevens and on the West by lands of James Kemp containing 64 1/4 acres.

2nd Tract Bounded on the North by W. H. Sircy East by Woodfork lands ?now owned by [blank] Young South by Woodard. West by tract no 1. containing 61 acres more or less being same lands Henry Ramsey purchased from Mary L. Stevens. Each of said tracts of land lie in Jackson Co Tenn in the 14th civil district thereof the deeds to same will be filed on or before the hearing of this cause if necessary.

Your Complts charge that