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Moses Estate Papers

From Green county Court Hose: File #387l

I, J.H. Caulfield, printer and publisher, of the Kentucky Register, a public authorized newspaper, published in Elizabeth town, Ky., do certify, that the annexed order of publication in chancery, wherein Jeremiah Lewis and Aaron Lewis are complainants against the heirs of Moses Skaggs, deceased---defendants has been published in said paper for two calendar months, by successive weekly insertions, commenting on the 2nd day of April last and ending on the 2nd day of June l836. Given under my hand the 2nd day of June l836.

Signed J.H. Caulfield
Proprietor, Printer, & Publisher of "Ky. Register"
2 l/2 squares---Printer fee $5.00
Copy of Newspaper article as follows:

Advertisements---Green Circuit Court, Feb. term l836, Jeremiah Lewis and Aaron Lewis complainants against the heirs of Moses Skaggs, dec'd defts---In chancery.

This day came the complainants and filed their bill, and it appearing to the satisfaction of the court, that the defendants James Meredith, John Meredith, Daniel Meredith, Matthew Meredith, Wm. Meredith, Susanna Quary, and Wm. Quary her husband, Thomas York and wife, Laban Ellis and wife, Rebecca Skaggs, Susanna Criswell, Edw. Whit, Adam Harman, Henry Harman, Mathias Harman, Robert Beavers & wife, Moses Beavers and wife, Thomas Christian & wife, Josiah Whit and wife, Archibald Maloney and wife, John Mitchell & wife, Joseph Howell & wife, Parthena Hankins, Lucy Hankins, Lydia Hankins, Joseph Hankins, and Moses Hankins are not inhabitants of this commonwealth, and they not having answered the complainants bill agreeably to law and the rules of this court, it is ordered that unless the aforesaid non-resident do answer the same on or before the first day of the next term of this court, the same will be taken as confessed against them. A copy test. John Barret, Clk.

April,----: The deposition of William Ratliff taken at the home of William Skaggs, on Aleck Fork of Pitman's Creek pursuant to notice on the 27th of April, l836, to be read as evidence on the trial of a suit in chancery now pending in the Green Circuit court, in which Aaron and Jeremiah Lewis was complainants and William Calvin, Charles Blevins and others are defendants. The deponent being of lawful age and first duly sown deposition and saith:

I was acquainted with Moses Skaggs of Green County Kentucky. He had four sisters to wit: Susanah who married one Richard Whit, Betsy or Elizabeth, who md. John Hankins. Lydia who married Mathias Harman and Nancy who md. William Meridy. I was acquainted with all of them in the state of Virginia and quite intimate with them.

Question of complainants: Has (or have) Moses Skaggs or not one brother by the name of John Skaggs.
Answer: Yes he had.

Question by same: Were or were not the sisters above named the only sisters, which Moses Skaggs had?
Answer: Yes, they were all that I know of.

Question of same: State if you can when Moses Skaggs died and where he lived at the time of his death.
Answer: I can not say certainly when he died, but think it has been about forty years. He died at his house in Green County.

Question by same: Did or did not Moses Skaggs leave at his death any children?
Answer: He never had any children that I knew of. He had none I know when he died.

Question by same: Did or did not Richard Whit, and wife, Matthias Harman & wife and John Hankins and wife live---in the state---of Virginia.
Answer: They did.

Question by defendants: Are you acquainted with the children of John Hankins, Hezekiah Whit and Mathias Harman.
Answer: None but the children of Hankins and one of Whit.

Question by same: State how long it has been since you was acquainted with the above.
Answer: Yes, I was.

Question by same: Was you acquainted with the brothers of Moses Skaggs, if so name them.
Answer: I was acquainted with Henry, James, Charles, John, Richard, & Jacob these were all the brothers of said Moses Skaggs.

Question by same: Did you know them in Kentucky and did they not all raise large families.
Answer: Yes, I believe they did.

Question by same: Was you acquainted with the children of the above named persons.
Answer: I was acquainted with some of them. Rachel Blevins, Archibald Skaggs, Thomas Skaggs & Moses Skaggs, these are Charles Skaggs children.

Question by same: Was you acquainted with Henry Skaggs; children, & how many of them.
Answer: I was acquainted with Lucy Stacy, Mary Combs & James Skaggs & Silvey Roark.

Question by same: Was you acquainted with the children of James Skaggs?
Answer: I was acquainted with William Skaggs & Rachel Etherton, children of James Skaggs.

Question by same: Was you acquainted with Richard Skaggs; children.
Answer: I knew Henry Skaggs.

Question: Did all the children of the above named persons live in the state of Kentucky and the county of Green.
Answer: Believe they did.

Question by complainants: Were you or not acquainted with the children of Jacob Skaggs.
Answer: He had one son by the name of William Skaggs who is now living in Green County, and further this deponent said not.

His mark
William X Ratliff

Also the deposition of Francis Samples taken at the same time and place for the same purpose. The despondent being of lawful age and first duly sworn says:

Questions by complaints: Were you or not acquainted with Moses Skaggs who died in Green County about forty years since.
Answer: I was.

Question by same: How many sisters had he and whom did they marry?
Answer: He had four sisters only to wit: Susanah married a Richd Whit, Lydia, married Matthias Harman, Elizabeth married John Hankins and Nancy who married William Meridy.

Question by same: Did they or not live in the State of Virginia when you knew them.
Answer: I think it was.

Question by same: Have or not Moses Skaggs ever have any children.
Answer: No, he never had any that I ever knew and I was intimately acquainted with him.

Question: Was or not the wife of sd. Moses Skaggs named Elizabeth, and did she or not survive him.
Answer: Yes, that was her name and she did survive him many years. She has been dead not a long while.

Question by same: Have or not you and Jacob Skaggs brother of Moses lawfully married---.
Answer: We were and lived together many years as man & wife.

Question by same: How many children had you and what are their names?
Answer: We had but one, and he is named William and is now living in this county.

Question by defendants: Do you consider yourself the widow of Jacob Skaggs deceased.
Answer: I do.

Question by same: Do or do you not consider yourself interested in the estate of Moses Skaggs dec'd.
Answer: I do not know that I do.

Question by same: Do you or do you not consider yourself interested in sd. estate for your son, William.
Answer: I do not, and further this deponent sayeth not.

Her mark
Frances X Samples

Also the deposition of John Spratt taken at the same time and place for the same purpose. the deponent being of lawful age and first duly sworn says:

Question by complainants: Are you or not acquainted with the trace of land on which old Moses Skaggs lived and died in Green Co.,.?
Answer: I am acquainted with the land on which I have been informed sd. Moses lived and died.

Question by same: State if William Jones, dec'd, who was admr. of the estate of sd. Moses did or not live on and rent out sd. tract of land for many years, previous to his death.
Answer: He lived on ad cultivated it for two or three years. I do not know whether he--rented it out.

Question by same: State what that plantation was worth rent, per year at the time Jones occupied it.
Answer: I should think the plantation at the time he had it was worth at least one hundred dollars per year on an average.

Question by same: do you or do you not know that sd. Jones had the following slaves, to wit: Rachel, Lydia & Matilda which belonged to the estate of sd. Moses in his possession as admr., for some years before his death, and that he appropriated their labor to his land?
Answer: He had for two or three years.

Question by same: State what each of those negro women were worth hire per year during the time he had them.
Answer: I think they were worth twenty five a piece, I would have been willing to have given that.

Question by same: do you or not know that since the death of sd. William Jones, William Cavan and Charles Blevins, have had access to sd. slaves in possession as admr. of sd. Moses Skaggs and they have been enjoying the benefit of their labor?
Answer: They have.

Question by same: do you or not know, that since the death of sd. Jones, sd. Caven and Blevins have been renting out the land above spoken of and was or not the land during the time they have been renting it worth at least one hundred and thirty dollars per year?
Answer: Yes.

Question by same: Are you or not acquainted with Rachel, Lydia, Matilda, Gabriel, Ann, Marion, Mary, Lewis & Frank, Henry and -----if so state what each of them are worth.
Answer: I have known them for many years. Rachel, I should think is worth three hundred dollars. Lydia is worth six hundred, Matilda five hundred, Garbiel, is worth four hundred, Ann is worth two hundred & fifty, Mary is worth three hundred dollars, Lewis is worth three hundred---and Frank Henry is worth one hundred and fifty dollars.

Question by defendants: Were you acquainted with the farm and the value of renting per year, at the time Jones took the same in possession?
Answer: I think it was worth fifty or sixty dollars per year.

Question by same: Was not a part of the farm rented out, at the time Jones came into possession of same.
Answer: It was.

Question by same: How much more was the rent of the farm worth at Jones death than it was at the time Jones took the same in possession?
Answer: I think it was double as much.

Question by same: What was the improvement of the farm worth, by the labors Jones put on the same?
Answer: I think sd. Jones improved the farm to the amount of three (four crossed out) hundred dollars.

Question by the same: Was not the widow of Moses Skaggs dec'd supported from the proceeds of the farm & Negroes before and after Jones came into the possession of the same?
Answer: I believe the widow (or woman) was supported from the proceeds previous to Jones coming into the possession and I believe Jones supported her after he got into the possession of sd. farm.

Question by same: did not the property above mentioned---remain in the possession of the widow after Jones death, so long as he lived.
Answer: I believe the Negroes did.

Question by same: did you ever know the widow to desert the farm during her life?
Answer: She lived and died there.

Questions by complainants: Do you or do you not know that although the widow lived in the farm until her death, that the larger portion of it was rented out by the administrators?
Answer: I do.

Question by sane: Do or do you not know that during the time Jones had the plantation in possession that much of the valuable timers on it was destroyed, and the land was worn and deteriorated by the cultivation of it.
Answer: I think some of the valuable timer was destroyed and the land has been injured-----of it has always cultivated in corn and oats.

Question of same: Do you or do you not know that, before the death of the widow, Caven and Blevins leased the farm and some of the Negroes to one Ratliff and that they received one hundred and twenty five barrels of corn from him as the rent of sd. farm.
Answer; They did rent the farm and one of the slaves to Ratliff. I understood that Ratliff------------------------------------. I can not say on what terms.

Question: Have or not the lease of which you have spoken as being on the land when Jones took the possession nearly expired.
Answer: I do not know, and further he says not.

Signed: John Spratt

Also the deposition of Peter Despain taken at the same time and place and for the same purpose the deponent being of lawful age and sworn deposeth & says.

Question by complainant: Were you or not acquainted with Moses Skaggs dec'd formerly of Green County?
Answer: I was. I lived in the State of Virginia and came with him to this county.

Question by same: Did he or not die in this county and did he or not have or ever have any children?
Answer: He did die in this county many years ago. He never had any children. His father and mother died many years ago before Moses. He had however four sisters to wit: Susannah, Lydia, Elizabeth & Nancy. Susanah married Richard Whit, Lydia married Matthias Harman, Elizabeth married John Hankins and Nancy married William Meridy. He also had the following brothers to wit James, Henry, Richard, John, Jacob and Charles--Elizabeth, Susanah and Lydia and their husbands lived in Virginia where I suppose their children are now living.

Question by same: Did or not Moses Skaggs die before any of his sisters and before John Skaggs.
Answer: I do not know when the sister in Virginia died. Moses however, died many years ago and before his sister Nancy Meridy and before John Skaggs.

Question by Defendant: Do you consider yourself interested in the estate of Moses Skaggs dec'd.
Answer: I do.

Question by complainants: Have you or not any interest in establishing the claims of any of the persons from or through whom Aaron & Jeremiah Lewis set up their claim in the suit.
Answer: No.

Question by same: Have you or not any interest----------.
Answer: I do not know that I have.

Question by same: Do you or not know the heirs of Jacob Skaggs.
Answer: Jacob Skaggs had but one child. A son by the name of William Skaggs, who is now living in this county. And further this despondent says not.

His mark
Peter X Despain

The within depositions of William Ratliff, Frances Samples, John Spratt, adn Peter Dspain was this day taken subscribed and sworn to before said William Ratliff, Frances Samples, John Spratt and Peter DSpain before the undersigned at Justice of the peace for said county at the time and place and for the purpose stated in the action. This is given under my hand this 27th day of April l836.

Virginia, Tazewell Co. to wit: In pursuance of a commission from the Circuit Court of Green Co., Ky. and anotice reputedly---we William cox & William Gillespie two acting Justices of the peace for the said county of Tazewell & State of Virginia have on this 27th day of July l836 at the said court house of Tazewell County caused Moses Hankins, Joseph White, Mathias Harman, Bird Lockhart, Joseph Hankins, Abel Hankins, William White, James White & John White to come before us to give evidence in a certain matter of controversy pending in chancery in the circuit court of Green County,Kentucky whence Jeremiah & Aaron Lewis are complainants & one Charles Blevins and others defendants.

Moses Hankins being duly sworn on the Holy evangelist of almight God and of lawful age deposeth and sayeth: That he had seen & knew Moses Scaggs when deponent was a small boy. Scaggs then lived in what was then Washington County but is now---in the county west end of Tazewell County, that Moses Scaggs, as exponent---understands moved to Green County Kentucky about the year l790 or l792, and that he understnads Scaggs died there about thirty years ago, and according to the exponents information Scaggs had brothers & sisters living at his death whose names are as follows: John, Henry, Richard, Jacob, Charles, Susanah, Lydia, Elizabeth & Nanc.

Question by plaintfiff: Do you know who these several sisters married?
Answer: Susanah married, agreeably to the best information, Richard Whitt and that it was the common report of the county that they were man & wife as deponent understands. Lydia married mathias Harmon and Elizabeth married John Hankins according to information the deponent being too young at the time the above marriages took place to be fully acquainted with the circumstances is the reason why he does not state more positively as to the circumstances surrounding them, but, he verily believes that the above named sister of Moses Sikaggs were lawfully named as deponant, knows they lived with the several persons named as their husbands. this deponent knows that Richard Whitt and Susannah his wife formerly Susanah Scaggs, John Hankins and Elizabeth his wife, formerly Elizabeth Scaggs, matthias Harmon & Lydia his wife formerly Lydia Scaggs are all now dead and the despondent understands & believes that John Scaggs is also dead. The children of John Scaggs as this deponent understands & believes are Susan the wife of William Querry. There were one or two other children whose names deponent has forgotten. The children of John Hankins are Mary the wife of Joseph White, Rachel, wife of Archibald Maloney, Lucy hankins, Rebecca the wife John Howell, Sally the wife of John Mitchell, Lydia his wife are Henry Harmon, Aaron Harmon, Mathias harmon, Katy the wife of Robert Beavers, Phebe the wife of Moses Beavers. The children of richard Whitt and Susannah his wife are Hezekiah Whitt, edmund Whitt, Richard Whitt, Susanah Creswell the wirfe of Henry Creswell. William Meridy and Nancy his wife had five children when they left this country but deponent does not know whether they are living or not. The foregoing are all the heirs now living of by the----------. Moses Scaggs never had any children as far as deponent knows and further this deponent sayth not.

his mark
Moses X Hankins

Mathias harmon being duly sworn & lawful age deposeth as followeth: That the children of mathias Harman, Lydia his wife, John Hankins, Elizabeth his wife, richard Whitt & susannah as stated (or sworn) by Moses Hankins are stated truly in number & names according to the best of deponents knowledge & belief and deponent also has reason to believe that the ----of Moses Hankins is true and further he sayeth not.

Signed: Mathias Harman

Bird Lockhart being sworn & of lawful age sayeth that the deponent has been acquainted with mathias Harman & Lydia his wife and John Hankins & Elizabeth his wife for about twenty years and previous to their deths & with their childrn and believes the statements made by Moses Hankins in his deposition----to them are correct & then----and that the children above named were always acknowledged & lawful by Lydia harman & elizabeth hankins as their true & lawful children and further this deponent sayeths not.

Signed: Bird Lockhart

Joseph Hankins being sworn & lawful age sayeth that the statements contained in the deposition of moses Hankins are correct & true in every particle---to the best of his knowledge, and further this deponent sayeth not.

his mark
Joseph X Hankins

Joseph White being sworn & of lawful age sayeth that this deponent knows about the same state in the depositions of Mathias Harman and further this deponent sayeth not.

Signed: Joseph White

John White being sworn & of lawful age sayeth that the deposition of Bird Lockhart is correct & true & further this deponent sayeth not.

Signed: John White

State of Virginia, Tazewell County: We William Gillespie and William Cox two acting justives of the peace for the said county and state and authorized by the court thereof to take depositions do hereby certify that the foregoing depositions were rightly taken & sworn to & subscribed before us at Tazewell court house on the 29th day of July l836. (Each of the deponents claims one days attendance amounting to $3.7l in all).

Signed: William Gillespie
/william Cox, J.P.

State of virginia, Tazewell County, to wit: I hohn Crockett clerk of the County Court of Tazewell County do hereby certify, that William Gillespie and William Cox whose names are above subscribed are acting justices of the Peace for the county aforesaid and that full worth ----&----due to their official acts and that the signatures above purporting to be their are genuine. Given under my hand and private seal (there being no seal of office) this 29th day of July l836.

Signed (John Crockett, CCTC)

I Henry Bowen, presiding Justice of the County court of Tazewell do hereby certify that John Crockett above named is clerk of said court and that full faith and credit are due to his official acts. Given under my Hand & seal this 29th day of July l836.

Signed: H. Bowen P.J.

The depositon of Elias Barbe taken at the house of William Sympson in the county of Green and State of Ky. on the 6th day of Feb. l837 agreeably to the noice hereto annexed to be judged as evidence on the part of the defendants in a suit in chancery now a depending in the Circuit Court for the County of Green where in Jeremiah Lew8is and Aron Lewis is complainants and William Cox and Charles Blevins defendants the desponant being of lawful age and first duly sworn deposeth and saith:

Question by defendants: Are you or you not axquainted with the lands of Moses Skaggs dec'd where one william Jones dec;d formerly lived.
Answer: I am.

Question by same: Is the land increased in value by the imporvements made by said Jones?
Answer: I would presume that its value had been increased but what extent I am not able to say.

Question by same: Do you or do you not know whether the other brothers of Moses Skaggs dec'd left lawfull issue or not.
Answer: I had never learned but what they were lawfully married to the women by which they had issue, and further this deponants sayeth not.

Signed: Elias Barbee

Also the depostion of Thornton Buckner taken at the same place & he same time for the purpose mentioned in the foregoing caption.

Question by defendants: Are you or are you not acquainted with the lands of Moses Skaggs dec;d whereon William Jones dec'd formerly lived & if so state the increased value of said land by the improvements made by said Jones.
Answer: I am acquainted with it. It is increased in value but to what amount I cnanot say, & further this deponants saith not.

Signed: Thornton Buckner

Also the deposition of Daniel Turner taken at the same time & place & for the same purpose in the foregoing caption namemd.

Question by defendants: Do you or do you not know the negro woman Matilda and her children, formerly in the possession of William Caven & how long William Caven had them in possession?
Answer: I knew her & her three children the time said Caven had her & her children in possession was about twelve months.

Question by same: Do you or do you not know that the children was sick with the flux some five or six weeks?
Answer: I believe they were sick, but I do not know how long. I suppose that length of time.

Question by same: Do you or do you not believe that from the sickness of said negros that they were of considerable expense to Caven over & above the labour performed by them?
Answer: I think the labour performed by them would compensate said Caven for keeping them.

Question by same: Was you or was you not acquainted with the brothers & sisters of sd. Moses Skaggs & if so how many of them.
Answer: I was not acquainted with his sisters if he had any. Those of his brothers who claimed to be such was Henry Skaggs, Charles Skaggs, John Skaggs, Richard Skaggs & Jacob Skaggs.

Question by same: Do you or do you not recollect how long since the death of Moses Skaggs?
Answer: I dno not recollect but---about forty years.

Question by same: Do you know if any of his brothers are living.
Answer: I do not.

Question by same: Do you or do you not know whether any of said brothers left issue.
Answer: I believe a majority did.

Question by complainants: Do you or do you not know whether Jacob Skaggs left any lawfull issue.
Answer: I have always understood he did not, and farther the deponants saieth not.

Signed: Daniel Turner

Also the deposition of Eli McCollum taken at the same time & place & for the same purpose mentioned in the foregoing caption.

Question by defandants: Do you or do you not believe that the boarding & clothing of the negro woman Lydia & her three children was ot worth as much while in the employnent of Chalres Blevins as the labor performed by them.
Answer: I would suppose the labor not worth more & farther the deponant saith not.

Signed: Eli McCollum

The foregoing depositions of Elias Barbee, Thornton Buckner, Daniel Turner & Eli McCollum beofre the undersigned a Justice of the Peace for the said county of Green at the time & place & for the purpose stated in the foregoing caption given under my hand this 6th day of Feb. l837. William Sympson JPCC

Justices fee $l.00
Witnesses in attendance fee: l50 each
Constable's fee $l.25

Blevins & Caven's Depositions: J. & A. Lewis filed by W. Caven Feby l837. The depositions of ---Lockhart & others taken at the clerk's office of Tazewell county in the State of Virginia in or on the lst day of nov. l837 in pursuance of a notice & a commission issued by teh Clerk of Green Circuit court; the said depositions being intended for evidence in a suit now pending in the chancery court of Green Circuit in the State of Kentucky wherein Aaron & jeremiah Lewis are complainants & Moses Skaggs administrators & heirs are defendants:

Moses Hankins of lawful age having been first duly sworn upon the Holy Evangelists of Almightly God, deposeth & saith that he was acquainted with Moses Skaggs who lived in what is now Tazewell county, Virginia, that said Moses Skaggs removed from Virginia about the year---and went to the State of Kentucky as this deponent always understood & he believed that John Skaggs, Liddy Skaggs, Susannah Skaggs & Elizabeth Skaggs were the brother & sisters of said Moses Skaggs that the John Skaggs is dead & that William Query is an heir to Mathias harman, that said mathias Harman & his wife, Liddy are dead & that their heirs now living are Adam Harman, mathias Harman, Henry Harman. Robert Beavers, Moses Beavers & Thomas Christian the said Robert & Moses beavers and Thomas Christian having married daughters of said Mathias & Liddy Harman now dead & that Hezekiah Whitt, susannah Careswell & Edmund whitt are the heirs to siad richard Whitt & his wife, Susannah, that the said Elizabeth Skaggs married John Hankins, that she & her husband are now dead & that Moses hankins, Joseph Hankins, Lucy Hankins, Lydia hankins, Parthena Hankins, Archibald maloney, John Mitchell, John Howell, & Joseph White are the heirs of said John Hankins & Elizabeth, his wife, the said maloney, Mitchell, Howell, & White having married daughters of the said John & Elizabeth hankins. This deponent further states the persons before mentioned to wit: William Querry, Adam Harman, Mathias Harman, Henry Harman, Robert Beacvers, Moses Beavers, Thomas Christian, Hezekiah Whitt, susannah Greswell, Edmund Whitt, Moses Hankins, Joseph Hankins, Lucy Hankis, Lydia hankins, Parthena Hankins, Archibald maloney, John Mitchell, John Howell & Joseph White have sold & transferred to Aaron & Jeremiah Lewis of Ky. their right & claim to the estate of Moses Skaggs deceased & this desponant knows of their acknowledging except Edmund Whitt whom the deponant did not see & also a writing transferring their said right & claim to said Aaron & Jeremiah Lewis, which writing is similar to one now here produced & said to be a copy tested by the clerk of Green Circuit Court in Ky. The reason & upon which this deponant funded his statements, that the persons above named are the heirs of John & Elizabeth Hankins, mathias & Liddy Harman, Richard & Susannah Whitt, & John Skaggs & that the said John , Elizabeth, Liddy & Susannah Skaggs were brother & sisters of Moses Skaggs, are the facts that the said deponant has been acquainted & lived for 54 years amony the parties, he has alwys heard & known them to be recognized as the relatives to the persons as he has stated, general report and universal opinion has considered them to be the persons he has said, & this deponant is as certain of their idenitty & relationship as he can be of any such fact, & further this deponants saith not.

His mark
Moses X Hankins

Joseph Hankins another witness of lawful age having been first duly deposeth & saith that he was acquainted with Moses Skaggs about the year at which time said Skaggs resided in Washington County, now Tazewell, Virginia, that said Skaggs removed from Virginia to Ky. about the year---since when deponant has known but little of him. the said Moses Skaggs had several brothers & sisters, as these were persons whom siad Moses Skaggs & everybody else recognized as his brothers & sisters, to wit, John Skaggs, who is now dead & a daughter of said john Skaggs married one William Query; also Elizabeth Skaggs, who married John Hankins. The said Elizabeth & her husband are both dead & their children now reside in Tazewell County, Virginia to wit: Moses, Joseph, Lucy, Lydia, & Parthena Hankins, also the wives of Archibald maloney, John jMitchell, John Howell, & Joseph White are children of said John & elizabeth Hankins. Susannah was also a sister of Moses Skaggs & she married Richard Whitt, both now dead & Hezekiah Whitt, susannah Creswell & Edmund Whitt are children & heirs of said Richard & Susannah Whitt & residence Virginia. Liddy also another sister of moses Skaggs, married mathias Harman. The said Liddy & her husband are dead but the; have children & heirs residing in Tazewell County to wit: Henry, mathias, & Adam Harman & their wives of thomas Christian, Moses Beavers, & Robert Beavers. This deponent was well acquainted with the Skaggs family & has not hesitation in asserting that the persons above named are such members of said family as he has stated. The said Moses Skaggs was never married.

His mark
Joseph X Hankins

Ebenezer Brewster, another witness of lawful age having been first duly sworn deposeth & saith that he has resided in Tazewell Co. for 62 years & that he was acquainted with a number of the Skaggs family. This deponent has always understood & believed & has heard many person say that Elizabeth, the wife of John Hankins, Liddy the wife of Mathias Harman senior, & Susannah the wife of Richard Whitt, were sisters of Moses Skaggs who moved to Ky. about the year l782 & that John Skaggs was a brother of said Moses Skaggs. This deponent knows that Moses, Joseph, Lucy, Lydia & Parthena Hankins & also the wives of Archibald Maloney, John Mitchell, John Howell & Joseph White were always called & reputed children of Elizabeth & John Hankins & that said children were always recognized by by said Elizabeth as her children. This deponent also knows that Mathias, Adam & Henry Harman & also the wives of Robert Beavers, Moses Beaver & Thomas Christian were called & reputed by all persons, children fo the said Liddy, wife of Mathias Harman & that ssid Liddy recognized them as her children. Hezekial & Edmund Whitt & Susanah Creswell were also known as the children of the said Susannah, wife of Richard Whitt, & the said Susanah Whitt & every other person always recognized said Hezerkiah & Edmund whitt & Susanah Creswell as her children. The said John Skaggs had a daughter, who married William Querry as this deponant has always heard & believed. The said Elizabeth hankins & Liddy Harman died in Tazewell Co., Va. Susannah Whitt & John Skaggs are also dead as this deponent has heard & believes & further this deponant saith not.

His mark
Signed: Ebenezer X Brewster

Thomas Witten, another witness of lawful age having been first duly sworn, deposeth & saith that he has resided in Tazewell Co. for about 66 years & that he was acquainted with a nuber of Skaggs' family & lived neighbors to them. Every person whom this deponant ever heard speak of the subject, said that Moses Skaggs & John Skaggs & Elizabeth Hankins & Susanah Whitt, & Liddy Harman were brothers & sisters. This despondent was acquainted with Moses Skaggs & the others above named. The said Moses skaggs removed to Ky. as was said about the year l782-l783-l784. Henry, Adam & Mathias Harman & the wives of Thomas Christian, Moses Beaver, & Robert Beavers were always said & supposed to be children of Liddy Harman sister of said Moses Skaggs & recognized by said Liddy as her children. Joseph, Moses, Lucy, Lydia, Parthena Hankins & the wives of Archibald Maloney, John Mitchell, Joseph White & John Howell were also always recogniexed by Elizabeth Hankins, sister of Moses Skaggs, as her children. ---depondent hath also always understood that Hezekiah Whitt & Edmund Whitt & Susan Greswell were children of Sister of said Moses Skaggs, & they have always been reputed as such & further this despondent saith not.

His mark
Thomas X Witten

Bird Lockhart of lawful age being duly sworn deposeth & saith that the papers now exhibited & signed by the heirs of Moses Skaaggs deceased was acknowledged signed by the parties in despondent presents except by Susan Creswell & Edmund Whitt, who despondent did not see executed the papter. Said paper now exhibited is a copy of the original contract by the Clerk of Green Circuit court, Ky. & further this dponent saith not.

Signed: Bird Lockhart.

Virginia, Tazewell Co., to wit: We Harvey George, & William Cox Justices of the peace for the county & sate aforesaid do hereby certify that the foregoing depositions of Moses Hankins, Joseph hankins, Ebenezer Brewster, thomas Witten & bird Lockhart were duly taken, sworn to & subscribed before us at the clerk's office of the county court of our said county of Tazewell on the lst day of Nov. l837 in presence of the commission & notice herewith returned. Given under our hand & seals Nov. lst. l837.

Signed: Harvey George
William Cox

Virginia Tazewell co. to wit: I, John Crocket, clerk of the County Court of Tazewell County do hereby certify that Harvey George and William Cox whose names are here---before subscribed are and were at the time of subscribing the same acting justices of the Peace in and for said county, and that the foregoing----ppurporting to be the ----are genuine.

In testimony whereof i have here unto subscribed my name and affixed the Seal of my office at Jeffersonville, this lst day of nov. l837.

Signed: by John Crockett Clk
-------Brown

I henry Bowen presiding justice of the county court of Tazewell do hereby certify that John Crockett is clerk of said court, and that full faith and credit are due to his official acts. Given under my hand and seal this 2nd day of Nov. l837. Signed: H. Bowen, P.J.
Filed 27th Nov. l837.

To the honorable Judge of the Green Circuit court in chancey sitting were Archibald maloney & Rachel his wife, John Mitchell & Sally his wife, John Howell & Rebecca his wife, Parthena Hankins, Luch Hankins, Lydia Hankins, Joseph Hankins, Moses Hankins, Joseph white, Mary his wife, susan, husband Hez Whitt, Adam Harman, Matthis Harmon, Henry Harmon, robert beavers & Katy his wife, Moses Beavers & Pheve his wife, thomas christian---to a bill inhibited in said county by Jeremiah Lewis & Aaron Lewis against themselves & others your respondents after the usual excetion to said bill for revision them to---there of as they are advised that it is material for them to answer do now answer & say that it is ----that Moses Skaggs alluded---departed this life many years since in Green Co., Ky. & possesxed at his death---. Your repsondents have been informed of a quantity of real & personal property---true more over as estate in said bill that the said Moses Skaggs died intestate & without children leaving his brothers, Henry, richard, Charles, Jacob & John & his siters susannah was then wife of one richard Whitt, Lydia wife of mathias Harman, Elizabeth wife of John Hankins & Nancy, wife of William Meredy, his only representatives & heirs at law. All of these brothers & sisters have departed this life, the four first, wit Henry, richard, charles & Jacob died without any issue & intestate & remainder died intestate leaving the following children who are the surviving heirs at large & representatives of the aforesaid moses Skaggs to wit.---four daughters of John Skaggs to wit.: Susan, now the wife of William Quary,----now the wife of Laban Elliz & Rebecca who yet remains unmarried, the children of richard Whitt & Susan his-----. Respondents Hez Whitt & Susan who intermarried with Henry Criswell, said Henry Criswell being now dead; the children of Mathias Harman & Lydia his wife who are your respondents. Adam Harm, Mathis harmon, Henry harmon, Katy Beavers& wife of Robert beavers, Phebe Beavers wife of Moses Beavers & Lovace now deceased who married your respondent Thomas Christian, the children of John Hankins & Elizabeth his wife who are your respondents. Rachel wife of Archibald Malony, Sally wife of John Mitchell, Rebecca wife of Hohn Howell, Mary, wife of Joseph White, & Parthenia Hankins, Lucy Hankins, Lydia Hankins, Joseph Hankins & Moses Hankins; the children of William Meredy & nancy his wife, who are Joohn Meredy, James Meridy, Daniel Meridy, Mathias Meridy, William Meridy the only children of said William & Nancy Meridy now living the rest having died unmarried the above named persons constitute all & each of the heirs & representatives of the aforesaid Moses Skaggs of the conduct----. charles Blevins & Cavin of the ----& things which transpired in Ky.: your respondents of their knowledged----they have always understood & believed that the said Mosess Skaggs removed from Washington Co. to Ky. about the year l79l & died as above stated or about in the year l805. Your respondent & wit. that they did here to fore to wit. in the year l835 sell & convey by the inventory the bill mentioned marked one, two, three, & four the compts Jeremiah & Aaron Lewis is all their right, title, inters & I-----in & to the estate of the aforesaid Moses Skaggs & your respondents now have & asser no. right on claims whatsoever in & to said estate, but your respondents---over that by their contract with the said Aaron & Jeremiah & Aaron Lewis took the same at their own rish & Your respondents were not answerable for the failure of said Jeremiah & Aaron Lewis to succeed in any suit they might bring for recovery of the said estate of Moses Skaggs. Your respondents being therefore in no wise being interested in this suit & having fully answereed pry to be dismissed with their costs.

State of Virginia, Tqzewell Co., Sct. On this day John Howell & Joseph White, Parthenia hankins, Luch Hankins, Lydia Hankins, Joseph Hankins, Moses Hankins, Hezekiah Whitt, Henry Harman, Mathias Harman, Robert Beavers, his wife, Moses Beavers & Phebe his wife personally appeared before the subscribed acting Justice of the Peace for the county & state aforesaid & Made oath that the statements as made in the foregoing answer of their own knowledge are true & as made from the information of others they believe them to be true. Goven under my hand this 30th day of July l830.

Bird Lockhart.

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