EXCERPTS FROM INTERROGATORY OF CELIA A. HAYNES
CASE 476, DISTRICT COURT, JACKSON COUNTY, TEXAS, 1891
JULIA A. ALLEN ET AL VS CELIA A. HAYNES
Answer to Interrogatory 5th
This Interrogatory is answered in Interrogatory 4th. And I never received any paper from Mrs. Julia A. Haynes purporting to be a deed from myself to Robert Haynes, my son.
Answer to Interrogatory 6th
Mrs. Julia A. Haynes may be able to answer this question. But as I never gave Robert Haynes a deed neither before nor after his death. nor was a deed from myself to him ever returned to me, I am unable to answer the question.
Answer to Interrogatory 7th
There was no land conveyed or attempted to be conveyed by myself to my son Robert Haynes.
Answer to Interrogatory 8th
I know nothing about any deed as referred to in this interrogatory.
Answer to Interrogatory 9th
This Interrogatory is answered in my answer to 8th Interrogatory.
Answer to Interrogatory 10th
I owned before the war a large fine residence. And after the boys came back home I had them to tear down the residence and build for me and each of them a small residence out of the material from the large residence and among the others Robert built him a house below me on the bluff from the river, some six or eight hundred yards from my house, on the 1,280 acre tract that was deeded to me by Daniel Haynes.
Answer to Interrogatory 11th
Mrs. Julia A. Haynes never returned into my possession a deed that I had given my son Robert Haynes as I had never given him one. The land was mine, and the house a part of my residence as stated in answer to Interrogatory 10th but when my son died and before she (Mrs. Julia A. Haynes) left the county I affirmed if she and Bob’s child would stay that I could support them.
Answer to Interrogatory 12th
The land 1,280 acres was purchased by me from Daniel Haynes my step son with slaves my separate property inherited from my father’s estate.
Answer to Interrogatory 13th
I don’t recollect when the C H brand was recorded, but it was recorded in my name and I always claimed them. Yet they were claimed as community property in the litigation to settle the debts of my dead husband Thomas Haynes in 1874 or 1875. The cattle were originally bought with my separate property.
Answer to Interrogatory 14th
My deceased husband left surviving him five children.
Answer to Interrogatory 15th
As I have repeatedly answered there never was a deed delivered either by me to my son Robert or from his wife Julia to me for safe keeping, therefore there could not have been any conversations in regard to a deed.
Answer to Interrogatory 16th
I know nothing of the deed referred to, in this Interrogatory.
Answer to Interrogatory 17th
Answered in the answer to the 16th Interrogatory.
Answer to Interrogatory 18th
My grand daughter Mary Celia Haynes, the daughter of Robert Haynes, deceased, is about 12 or 13 years of age.
Celia A. Haynes
Sworn and subscribed to before me this the 30th day of October 1891.
Hugh L. White
Co Judge
The State of Texas
County of Jackson
I Hugh L. White County Judge in and for Jackson County State of Texas do hereby certify that the foregoing 18 answers to Interrogatories were by me … to writing the witness Mrs. Celia A. Haynes then signed and swore to the same, before me at Mrs. Jennie Haynes place some six miles below Edna where she the witness was on a visit.
Given under my hand and seal of Office this the 31st day of October AD 1891.
Hugh L. White
County Judge JC
Fee for going down to Mrs. Haynes & taking deposition
$5.00
CASE 476, DISTRICT COURT, JACKSON COUNTY, TEXAS, 1891
JULIA A. ALLEN ET AL VS CELIA A. HAYNES
Answer to Interrogatory 5th
This Interrogatory is answered in Interrogatory 4th. And I never received any paper from Mrs. Julia A. Haynes purporting to be a deed from myself to Robert Haynes, my son.
Answer to Interrogatory 6th
Mrs. Julia A. Haynes may be able to answer this question. But as I never gave Robert Haynes a deed neither before nor after his death. nor was a deed from myself to him ever returned to me, I am unable to answer the question.
Answer to Interrogatory 7th
There was no land conveyed or attempted to be conveyed by myself to my son Robert Haynes.
Answer to Interrogatory 8th
I know nothing about any deed as referred to in this interrogatory.
Answer to Interrogatory 9th
This Interrogatory is answered in my answer to 8th Interrogatory.
Answer to Interrogatory 10th
I owned before the war a large fine residence. And after the boys came back home I had them to tear down the residence and build for me and each of them a small residence out of the material from the large residence and among the others Robert built him a house below me on the bluff from the river, some six or eight hundred yards from my house, on the 1,280 acre tract that was deeded to me by Daniel Haynes.
Answer to Interrogatory 11th
Mrs. Julia A. Haynes never returned into my possession a deed that I had given my son Robert Haynes as I had never given him one. The land was mine, and the house a part of my residence as stated in answer to Interrogatory 10th but when my son died and before she (Mrs. Julia A. Haynes) left the county I affirmed if she and Bob’s child would stay that I could support them.
Answer to Interrogatory 12th
The land 1,280 acres was purchased by me from Daniel Haynes my step son with slaves my separate property inherited from my father’s estate.
Answer to Interrogatory 13th
I don’t recollect when the C H brand was recorded, but it was recorded in my name and I always claimed them. Yet they were claimed as community property in the litigation to settle the debts of my dead husband Thomas Haynes in 1874 or 1875. The cattle were originally bought with my separate property.
Answer to Interrogatory 14th
My deceased husband left surviving him five children.
Answer to Interrogatory 15th
As I have repeatedly answered there never was a deed delivered either by me to my son Robert or from his wife Julia to me for safe keeping, therefore there could not have been any conversations in regard to a deed.
Answer to Interrogatory 16th
I know nothing of the deed referred to, in this Interrogatory.
Answer to Interrogatory 17th
Answered in the answer to the 16th Interrogatory.
Answer to Interrogatory 18th
My grand daughter Mary Celia Haynes, the daughter of Robert Haynes, deceased, is about 12 or 13 years of age.
Celia A. Haynes
Sworn and subscribed to before me this the 30th day of October 1891.
Hugh L. White
Co Judge
The State of Texas
County of Jackson
I Hugh L. White County Judge in and for Jackson County State of Texas do hereby certify that the foregoing 18 answers to Interrogatories were by me … to writing the witness Mrs. Celia A. Haynes then signed and swore to the same, before me at Mrs. Jennie Haynes place some six miles below Edna where she the witness was on a visit.
Given under my hand and seal of Office this the 31st day of October AD 1891.
Hugh L. White
County Judge JC
Fee for going down to Mrs. Haynes & taking deposition
$5.00