Interrogatory of Julia A. Allen, former wife of Robert Haynes, Deceased
Julia A. Allen, Guardian et al Suit pending in
No. 476 vs the District Court
Celia A. Haynes of Jackson County Texas
Answers and depositions of Julia A. Allen of Jefferson, Marion County, Texas to the accompanying Interrogatories presented to her in the above entitled cause taken before S. W. Moseley, County Judge of Marion County, Texas in accordance with the accompanying Court mission.
Answers of witness Julia A. Allen.
1. To the first Inty the answers;
I am a party to this suit.
2. To the 2nd Inty the answers:
I am now married to P. M. Allen and was formerly married to Robert Haynes, deceased.
3. To the 3rd Inty the answers:
I was formerly the wife of Robert Haynes who died in Texana, Jackson County, Texas on the 4th day of
November AD 1878.
4. To the 4th Inty the answers:
Robert Haynes died leaving one child a girl named Mary Celia Haynes. She is now alive and is aged 13
thirteen years.
5. To the 5th Inty the answers:
Mary Celia Haynes is the daughter of Robert Haynes and myself. I am her natural and legal guardian. I have
letters of guardianship issued by order of the County Court of Marion County Texas. I am the guardian of her
person and Estate.
6. To the 6th Inty the answers:
Robert Haynes at the time of his death had 640 acres of land in Jackson County.
7. To the 7th Inty the answers:
Robert Haynes owned 640 acres of Ramon Musquez grant in Jackson County Texas the same was given to
him by deed from his mother.
8. To the 8th Inty the answers:
The deed was executed by Robert Haynes’ mother to him.
9. To the 9th Inty the answers:
Robert Haynes’ business required his absence from home often during his life and on one occasion before
leaving home Mr. Haynes took the deed of gift made him by his mother, Mrs. Celia A. Haynes and other
valuable papers and carried them to his Mother’s Home and delivered them to his said Mother for safe
keeping. During Mr. Haynes’ absence from Home I spent most of the time at the residence of my
mother-in-law Mrs. Celia A. Haynes.
10. To the 10th Inty the answers:
I never saw the signature to said deed.
11. To the 11th Inty the answers:
I know the hand writing and signature of the Defendant Mrs. Celia A. Haynes.
12. To the 12th Inty the answers:
I had such a deed in my possession. Robert Haynes gave it to me and told me what it was.
We spoke of it frequently.
13. To the 13th Inty the answers:
The deed was by me given to my former Husband Robert Haynes and by him deposited with
Mrs. Celia A. Haynes for safe-keeping since which time I have never seen said Deed.
14. To the 14th Inty answers:
I gave the Deed to my former Husband Robert Haynes and He placed it in Hands of Mrs. Celia A Haynes
for safe keeping as before stated.
15. To the 15th Inty the answers:
I have already previously answered in this Deposition this question.
16. To the 16th Inty the answers:
Robert Haynes owned a House and Home on said 640 acres of land in Jackson County Texas.
Mr. Haynes built the House after he got the Deed to the Land from his mother.
17. To the 17th Inty the answers:
My former Husband Robert Haynes and myself lived on said 640 acres of land from July 1875 until his death
on November 4, 1878. I resided on the Place all the time from July 1875 until September 1880.
18. To the 18th Inty the answers:
I have already stated the length of time Robert Haynes lived on said land. The part of the Dan Haynes Place
that Robert Haynes owned and lived on was to the best of my recollection the south half of 1280 acres
and lay along the banks of the Lavaca River.
19. To the 19th Inty the answers:
Robert Haynes owned said land during his lifetime and managed used and controlled the same from the time
his mother gave him the Deed to it up to his death.
20. To the 20th Inty the answers:
I have already answered the first part of this Inty. I did not hear Mrs. Celia Haynes make any remark
about the Deed when my Husband gave it to her.
21. To the 21st Inty the answers:
In my answers to previous Intys herein I have fully explained and stated all about the matter inquired after
in this Inty.
22. To the 22nd Inty the answers:
About (18) eighteen months after the death of my husband, Robert Haynes, Mr. George Gayle offered to
purchase the said land from me. I then went to Mrs. Celia A. Haynes’ House and told her that Gayle
had offered to purchase the land and I then asked her to give me the Deed to the Land that Robert Haynes
had left with her in safe keeping. She refused to give it up stating that she did not want any strangers on the
land because it was inside of the pasture and further stated that she wanted to keep it for my little girl
Mary Celia Haynes and that she could not give up the Deed unless she was forced to do so.
23. To the 23rd Inty the answers:
I have herein previously stated all that I know in regard to the matter inquired after in this Inty.
24. To the 24th Inty the answers:
I do not know what became of said Deed after my husband gave said Deed to Mrs. Celia Haynes.
25. To the 25th Inty the answers:
It never had.
26. To the 26th Inty the answers:
I have already stated all that I can now recollect of any importance in this matter.
Cross Interrogation
1X. To the 1st XInty the answers:
My first Husband Robert Haynes died on November 4th 1878 in Texana Texas.
2X. To the 2nd XInty the answers:
I never received any such Deed executed by my Husband but did have possession of the Deed executed by
Mrs. Celia A. Haynes to Robert Haynes. Robert Haynes I think gave me the deed to put away in the year 1875
after we had moved on the land that is now in controversy.
3X. To the 3rd XInty the answers:
Robert Haynes was living on the Land conveyed in said Deed at the time he was accidentally shot and killed
in the Town of Texana. He was in possession of said land at the time of his death.
4X. To the 4th XInty the answers:
I do not know whether or not said Deed was ever acknowledged or whether it was ever recorded or not.
Julia A. Allen
Guardian
Sworn to and subscribed before me this 17 day of November AD 1891.
S. W. Moseley County Judge
Marion County, Texas
The State of Texas I S. W. Moseley County Judge
County of Marion of Marion County Texas do
hereby certify that the foregoing Answers of Mrs. Julia A. Allen the witness before named were made before me and were sworn to and subscribed before me on the 17th day of November A.D. 1891 by the said Witness Julia A. Allen.
Given under my hand and official seal
This 17th day of November A.D. 1891.
S. W. Moseley
Julia A. Allen, Guardian et al Suit pending in
No. 476 vs the District Court
Celia A. Haynes of Jackson County Texas
Answers and depositions of Julia A. Allen of Jefferson, Marion County, Texas to the accompanying Interrogatories presented to her in the above entitled cause taken before S. W. Moseley, County Judge of Marion County, Texas in accordance with the accompanying Court mission.
Answers of witness Julia A. Allen.
1. To the first Inty the answers;
I am a party to this suit.
2. To the 2nd Inty the answers:
I am now married to P. M. Allen and was formerly married to Robert Haynes, deceased.
3. To the 3rd Inty the answers:
I was formerly the wife of Robert Haynes who died in Texana, Jackson County, Texas on the 4th day of
November AD 1878.
4. To the 4th Inty the answers:
Robert Haynes died leaving one child a girl named Mary Celia Haynes. She is now alive and is aged 13
thirteen years.
5. To the 5th Inty the answers:
Mary Celia Haynes is the daughter of Robert Haynes and myself. I am her natural and legal guardian. I have
letters of guardianship issued by order of the County Court of Marion County Texas. I am the guardian of her
person and Estate.
6. To the 6th Inty the answers:
Robert Haynes at the time of his death had 640 acres of land in Jackson County.
7. To the 7th Inty the answers:
Robert Haynes owned 640 acres of Ramon Musquez grant in Jackson County Texas the same was given to
him by deed from his mother.
8. To the 8th Inty the answers:
The deed was executed by Robert Haynes’ mother to him.
9. To the 9th Inty the answers:
Robert Haynes’ business required his absence from home often during his life and on one occasion before
leaving home Mr. Haynes took the deed of gift made him by his mother, Mrs. Celia A. Haynes and other
valuable papers and carried them to his Mother’s Home and delivered them to his said Mother for safe
keeping. During Mr. Haynes’ absence from Home I spent most of the time at the residence of my
mother-in-law Mrs. Celia A. Haynes.
10. To the 10th Inty the answers:
I never saw the signature to said deed.
11. To the 11th Inty the answers:
I know the hand writing and signature of the Defendant Mrs. Celia A. Haynes.
12. To the 12th Inty the answers:
I had such a deed in my possession. Robert Haynes gave it to me and told me what it was.
We spoke of it frequently.
13. To the 13th Inty the answers:
The deed was by me given to my former Husband Robert Haynes and by him deposited with
Mrs. Celia A. Haynes for safe-keeping since which time I have never seen said Deed.
14. To the 14th Inty answers:
I gave the Deed to my former Husband Robert Haynes and He placed it in Hands of Mrs. Celia A Haynes
for safe keeping as before stated.
15. To the 15th Inty the answers:
I have already previously answered in this Deposition this question.
16. To the 16th Inty the answers:
Robert Haynes owned a House and Home on said 640 acres of land in Jackson County Texas.
Mr. Haynes built the House after he got the Deed to the Land from his mother.
17. To the 17th Inty the answers:
My former Husband Robert Haynes and myself lived on said 640 acres of land from July 1875 until his death
on November 4, 1878. I resided on the Place all the time from July 1875 until September 1880.
18. To the 18th Inty the answers:
I have already stated the length of time Robert Haynes lived on said land. The part of the Dan Haynes Place
that Robert Haynes owned and lived on was to the best of my recollection the south half of 1280 acres
and lay along the banks of the Lavaca River.
19. To the 19th Inty the answers:
Robert Haynes owned said land during his lifetime and managed used and controlled the same from the time
his mother gave him the Deed to it up to his death.
20. To the 20th Inty the answers:
I have already answered the first part of this Inty. I did not hear Mrs. Celia Haynes make any remark
about the Deed when my Husband gave it to her.
21. To the 21st Inty the answers:
In my answers to previous Intys herein I have fully explained and stated all about the matter inquired after
in this Inty.
22. To the 22nd Inty the answers:
About (18) eighteen months after the death of my husband, Robert Haynes, Mr. George Gayle offered to
purchase the said land from me. I then went to Mrs. Celia A. Haynes’ House and told her that Gayle
had offered to purchase the land and I then asked her to give me the Deed to the Land that Robert Haynes
had left with her in safe keeping. She refused to give it up stating that she did not want any strangers on the
land because it was inside of the pasture and further stated that she wanted to keep it for my little girl
Mary Celia Haynes and that she could not give up the Deed unless she was forced to do so.
23. To the 23rd Inty the answers:
I have herein previously stated all that I know in regard to the matter inquired after in this Inty.
24. To the 24th Inty the answers:
I do not know what became of said Deed after my husband gave said Deed to Mrs. Celia Haynes.
25. To the 25th Inty the answers:
It never had.
26. To the 26th Inty the answers:
I have already stated all that I can now recollect of any importance in this matter.
Cross Interrogation
1X. To the 1st XInty the answers:
My first Husband Robert Haynes died on November 4th 1878 in Texana Texas.
2X. To the 2nd XInty the answers:
I never received any such Deed executed by my Husband but did have possession of the Deed executed by
Mrs. Celia A. Haynes to Robert Haynes. Robert Haynes I think gave me the deed to put away in the year 1875
after we had moved on the land that is now in controversy.
3X. To the 3rd XInty the answers:
Robert Haynes was living on the Land conveyed in said Deed at the time he was accidentally shot and killed
in the Town of Texana. He was in possession of said land at the time of his death.
4X. To the 4th XInty the answers:
I do not know whether or not said Deed was ever acknowledged or whether it was ever recorded or not.
Julia A. Allen
Guardian
Sworn to and subscribed before me this 17 day of November AD 1891.
S. W. Moseley County Judge
Marion County, Texas
The State of Texas I S. W. Moseley County Judge
County of Marion of Marion County Texas do
hereby certify that the foregoing Answers of Mrs. Julia A. Allen the witness before named were made before me and were sworn to and subscribed before me on the 17th day of November A.D. 1891 by the said Witness Julia A. Allen.
Given under my hand and official seal
This 17th day of November A.D. 1891.
S. W. Moseley