Page 51 -55
June 9, 1874
Lucinda Bolton Davis

Q. From what race or nationality of people was your and Jemima Simmerman's father descended? What was the nationality and race of your mother?
A. My father was a Spaniard and his mother a blue eyed German. My mother was an American, was born in America. I don't know what nation she descended from. She was rather fair complected and had blue eyes and light hair. She was also Mrs. Simmerman's mother.
Q. State whether or not your father was a citizen and voted in the elections of the county before his death and before the war?
A. He was a citizen and voted in the elections held in this and Marion Counties before the war.. lived sometimes in one and sometimes in the other county. He died some six years since as I understand. He went to Illinois  I understand.
Cross
Q. Where did your parents reside at the time of your first recollection--give the county and state.
A. They resided in Pendleton Dist in the state of South Carolina.
Q. Where did they move to from that place?
A. To Blount County, Tennessee
Q. How many years ago?
A. About 40 years ago
Q. How long did you reside in that county
A. Seven or eight years.
Q. Where did you move to from that County?
A. We moved to the Hiwassee District about 6 miles above the mouth of the Hiwassee River.
Q. How long did you live there and where did you move to from that place
A. I can’t say how long we lived there, perhaps five years. We then moved below Kelly's ferry in Marion County Tennessee. I married there. Then I and husband moved to Alabama and stayed there two years and then moved to Blount County. My father still resided in Marion County about Col Oats.
Q. About what date did your father remove to Hamilton County Tennessee?
A. It must have been about twenty years ago or more.
Q. From the time your father removed from South Carolina how long was it until you next saw your grandmother and grandfather on your mother's side of the house?
A. I never saw my grandmother on my mother's side. I never saw my grandfather on my mother's side since I left South Carolina. I was very small last time I saw him.
Q. Where did you last see your grandmother and grandfather on your father's side... I mean how long ago?
A. I never saw them. My grandmother died before I was born and I never saw my grandfather.
Q. What was the color of your mother's hair and complexion of her skin?
A. She had light hair and fair skin
Q. Where was she born?
A . In South Carolina as I have heard her say.
Q. What was the color of the hair, skin and eyes of your father?
A. He had dark hair, dark eyes and skin, tolerable dark, but not to hurt-about the color of mine
Q. In what election do you know of your father voting in Marion or Hamilton County?
A. I don't recollect of any particular election, but he voted in all. I never heard of any objection, and he always mustered until he got too old.
Q. What was the maiden name of your mother?
A. Rachel Davis.

June 25th, 1874
Page 87-95
Deposition of Arch Brown
Q. State your age, present residence and how long you have resided in the Counties of Hamilton or Marion in the state of Tennessee?
A. I am now 63 years old, live in Marion County. Have lived in said County about 40 years.
Q. State whether or not you ever knew Solomon Bolton the grandfather of Martha Simmerman and if so when did you first know him and where did you know him?
A. I knew him in Marion County, Tenn., some 25 or 30 years ago, and until he left this Country.
Q. About what time died he leave this country? And you will state whether or not while said Solomon Bolton resided in Marion or Hamilton Counties he exercised the privilege of voting in elections and whether his testimony was admitted in Courts of Justice against white persons?
A. Mr. Bolton left here some four or five years ago... I don't remember exactly. He voted in Marion County. I do not know about his voting in this County as I was not here. His testimony was received in the Courts of the County against white person before the war by Complt in Cross Bill. ......
Q. State whether or not you know of any of Bolton's family-- his father or other in the state of North Carolina or other place
A. I was in So Carolina once and saw his father. I knew most of his family. I was on business in So Carolina. His father, or a man claiming to be his father came to me to inquire after his son Solomon Bolton whom he said was living in this County
Q. State whether or not the father of Solomon Bolton was regarded and treated as a citizen of South Carolina, or as a colored man? You will also state his church relations-to what church he belonged and how he was received by society, so far as you were able to determine.
A. They told me there that he was a very respectable citizen there. I asked if he was not a colored man and they told me he was not, but was a Portagese. The told me that he was a member of Baptist Church there in good standing and was received in good society. I saw nothing to the contrary.

Cross
Q. How did you come to be in South Carolina when you saw the father of Solomon Bolton? Where did you then live? And how did it happen that the neighbors said anything about said Bolton?
A. I was there looking after an estate that was coming to me. I then lived in Marion County, Tenn. Old man Bolton came to see me and inquired about his son, said his neighbors had told him I lived near his son.
Q. Give the year as nearly as you can remember, also the name of said Old Man Bolton?
A. I have been there twice. The time at which the conversation occurred was about 28 or 29 years ago. I did not ask the name of the old man Bolton, and do not know his given name.
Q. Were you at his house and was his wife then living?
A. I was not at his house. I understood his wife was then living
Q. Did you not then and since and yet know of negro preaching?
A. Oh yes
Q. What District or County in South Carolina was it that you saw old man Bolton at the time mentioned?
A. It was in Spartanburg District
Q. At that time where did Solomon Bolton live and how long had he lived at such place?
A. He lived on Oates place, about 9 miles below me in Marion County Tenn. He had lived there some two years, I think.
Q. When did he move a way from there and where to? Give the year and place?
A. I do not know exactly. He kept living about up and down the river in that County. I can't give the dates
Q. When and where did Solomon Bolton claim to be a Portagese and how did he come to so claim?
A. The first time I heard him at it was at Court, at Jasper, some 24 or 25 year ago, as I recollect it was not long after I came from So Ca. I was summoned to prove that he was a negro.
Q. Was that the time you say he, Bolton, prosecuted Bromley?
A. Yes sir.
Q. What was his color or complection
A. He was a dark skinned man.
Q. Do you not know that negroes did visit the house of Solomon Bolton and associate with him and his family while he lived in Marion County
A. I do not know
Q. Do you not know that one or more negroes married into the family of Solomon Bolton?
A. I do not know that any one did
Q. In what election did you ever know of Solomon Bolton voting and who were judges and who clerks; tell the name of some one of them?
A. He voted in the Van Buren election. I think John McBridge was one of the clerks, but it has been so long that I do not remember. I think Matthew Girdley was one of the Judges.
Q Are they or either of them living, and at what voting ground? Name the place Girdley lives
A. Near Jasper on the Read place I think, in Marion County. I saw him the other day at Court. McBride moved to Texas. The voting ground-where I knew of Bolton voting was at the McBride place in the 6th Civil District of Marion County
Q. Who held the Court as Judge when Bromley was tried?
A. I think it was Judge Scott, but I am not certain
Q. Whose child was it that Bromley was charged with killing?
A. It was his wifes
Q. Give the year as near as you can remember it, that Solomon Bolton moved to Marion County and from what place and stated did he move from?
A. It has been some 28 or 29 years since. He said he came from South Carolina, Don't know what place.
Q. How many of the family of the father of Solomon Bolton did you know in South Carolina or elsewhere - aside from Solomon Bolton and his family?
A. I did not know any of them except Solomon's family. I saw his father as above stated and said at one time a man who claimed to be a brother of said Solomon.

William J. Standifer
Page 95
Q. What is your age? How long have you resided in Hamilton County Tennessee:
A. I am seventy two years old. I have resided in Hamilton County since March 1837
Q. Were you or not acquainted with Solomon Bolton? When did you first become acquainted with him, and how long did you continue to know him?
A. I first became acquainted with him in Marion County Tennessee, some thirty five or forty years ago. I knew him until he left Hamilton County since the close of the late Civil War.
Q. If you know whether or not Solomon Bolton, the grandfather of Martha Simmerman ever served as a soldier in the armies of the United States, please state all you know on that subject? In what war was he a soldier? Please state the facts by which you now that he was a soldier?
A. All that I know on the subject was derived from the fact that I made application to the Pension Office of the United States for Bounty land for services rendered by him in the army of the United States in the War of 1812 with Great Britain. He went into said service in South Carolina as alleged in his application for Bounty land. He obtained a late warrant on said application.
Q. Please state whether or not the application was predicated upon services rendered by said Solomon Bolton as a soldier? Was he a private soldier or non-commissioned officer?
A. The application for bounty land was made on account of services alleged by him to have been rendered in said was as a private soldier.

Page 100-109
August 29th 1874
John Boydston
Q. Give your age and residence and occupation?
A. My age is 80 years. My residence in Lookout Valley, 4th Civil District of Hamilton County Tennessee and occupation a farmer.
Q. State the length of time you have resided in Hamilton County Tennessee and were acquainted with Solomon Bolton and Jemima Bolton in their lifetime? If so how long did you know them?
A. I have resided in Hamilton County ever since the spring of 1825. I was acquainted with them both. I think it has been about thirty years since I became acquainted with Solomon Bolton and I was acquainted with Jemima from the time she was a very small child.
Q. State how far you lived from them.
A. I lived some four or five miles from them.
Q. State how they were treated and recognized by their neighbors and acquaintances as to their pedigree, and how they held themselves out, as white people, or otherwise? State how that was?
A. Solomon Bolton never claimed to be a white person. He claimed to be a Portugese himself, but his neighbors considered him to be a part negro. Jemima was always considered as his child.
Q. State whether Solomon Bolton testified in court, voted and was held to perform military services as white people were required to do?
A. He never testified in Court or voted or was required to perform military service to my knowledge.
Q. Were you acquainted with him from the time you first became acquainted with him until his death?
A. I was generally
Q. Give the general appearance of Solomon Bolton as to color, stature, shape of his head, and color and kind of hair on his head?
A. He was about five feet eight or ten inches high, rather on the spare order. His head was rather of a flat shape. He was of a very dark complexion. His hair was black and kinky, and he always kept it cut very short.

CROSS
Q. Did you know of your own knowledge the race of people, from which Solomon Bolton was descended?
A. I do not
Q.. Did you know any of the ancestors or family of Solomon Bolton
A. I knew none of his ancestors and none of his family except his wife and children.
Q. Do you know or swear that Solomon Bolton was a negro, or was descended from the negro race?
A. I do not know anything about it, except that he claimed to be Portugese.
Q. Was his wife a white woman or a negro
A. She was a white woman.
Q. Do you know of your own knowledge that Solomon Bolton was not a Portugese
A. I do not
Q. Did you know Solomon Bolton when he lived in Marion County?
A. I do not
Q. Did you not know of a man named Bromley being prosecuted in Marion County by Bolton for killing some of Bottons's family and being sent to the Penitentiary for that offence?
A. I heard that circumstance spoken of. I knew that Brumley was in the penitentiary upon that charge from what he told me.
Q. Was not Solomon Bolton too old for Militia services when you knew him?
A. He was up in years. He had grown children when I first knew him.
Q. Do you know a family of people living in this vicinity named Breedlove? And what is that relationship?
A. I know the Breedloves. They were connected to Solomon Bolton. I do not know the relationship.
Q. Of what race of people are the Breedloves?
A. I do not know
Q. Are the members of the Breedlove family as dark or darker in complexion than Solomon Bolton was?
A. The complexion and appearance of the Breedloves are very similar to that of Solomon Bolton.
Q. What was the color of Jemima Simmerman and what sort of hair did she have?
A. She was dark complected and had straight black hair.
Q. Did Jemima Simmerman to your knowledge have any African or negro blood in her?
A. She did not
..............................
RE EXAMINED
Q. Your are asked in your cross examination did Jemima Simmerman to your knowledge have any African or negro blood in her and you answer she did not. Do you mean to say that she did not have negro blood in her or do you mean that you did not know whether she did or not?
A. I meant that I did not know whether she did or not.

Jno E. Godsey Page 128-132
April 10th 1875
Q. Were you acquainted with Solomon Bolton ? If so, when, and how long did you know him?
A. I knew him well from 1841 to 1865
Q. Give a general description of Solomon Bolton. Describe his features, hair, nose?
A. He had a brown complexion-black and somewhat curly hair-a roman nose-rather sharp a full cheek-rather round face.
Q. State whether or not you are acquainted with the negro race? Are you acquainted with the distinguishing characteristics between negroes or mulattoes, and white people?
A. I am, and have worked among the negroes all my life. I know the difference between negroes or mulattoes and white people.
Q. Judging from your acquaintance with Solomon Bolton and your knowledge of the negro race, state whether or not Solomon Bolton was a negro or mulatto.
A. I know that he was not a negro and am confident that he was not a mulatto. He had none of the negro brogue-had well formed features, a good countenance. His foot had as much hollow as any white man
Q. Of what race of people did Solomon Bolton claim to be? How was he treated and recognized in the community where he lived?
A. Spanish. He was treated as any other white man, when he was sober. He was always admitted to the table with white families of people whenever he was as far as I know, and recognized as a white man.
Q. What do you know of Solomon Bolton having been a soldier in the United States army, and having received land warrants for his service?
A. He was a soldier in the War of 1812. He received two land warrants for his services in the US Army in that war. I have seen the warrants-for 80 acres each.
Q. Was Solomon Bolton's hair kinky as the hair of a mulatto? Illustrated by an example what you mean by his hair being curly? Was it or not more curly than that of many white men?
A. It was not so curly as many white mens whom I have known. It was not kinky. It was only a little more curly than Mr. Samuel Williams.
Q. Were you acquainted with Sol. Bolton's wife, if so, state whether or not she was a white woman?
A. I knew her well. She was a white woman.
Q. Were you acquainted with the daughters of Sol Bolton? With what race of men did they intermarry? Give the names of some of the sons in law of Sol. Bolton?
A. I knew his daughters. they married white men. Two of them married twice each, and each time they married white men. Robt. Taylor, Ramy McCulloch, Jno Skelton, J.C. Simmerman, Hiram Davis and Mr Brumley were all his sons in law of Sol Bolton.
Q. Were any of these men ever indicted for marrying these women or was there ever any talk of indicting them about it?
A. they were never indicted and I never heard of any talk of that effect. They were married during slavery times and I think certainly I would have heard of it if there had been any talk of that kind.
Q. State whether or not Jemima Simmerman was a negro, mulatto, or person of mixed negro blood?
A. If she was I could not tell it. She was of fair skin, white complexion, blue eyes, auburn hair, and no one could discover any negro blood in her.
.............
CROSS EXAMINATION
Q. Have you any doubt but that Solomon Bolton had no negro blood in him; or have you any doubt about Jerome C. Simmerman being as sane and sound in mind at the time he married Jemima Bolton?
A. I don't think he had negro blood in him. He had something in his blood besides white blood. I have no doubt about Jerome C. Simmerman being sane and sound in mind at the time he married Jemima Bolton.

Jno L. Divine
Page 133-137
Q. What is your age? Where do you reside and how long have you lived in Chattanooga?
A. My age is about fifty six. I live in Chattanooga. I have resided or lived in Chattanooga since the year 1838
Q. Were you acquainted with one Solomon Bolton? If so , how long did you know him?
A. I was acquainted with Solomon Bolton from the year 1844 to 1860
Q. Of what race of people was Solomon Bolton? What did he and his family claim as to be his nationality? How was he treated and recognized in the community where he lived?
A. I don't know of my own knowledge what race of people he belonged to. I often heard Bolton say that he was Portugese. I have often heard his wife say the same thing. He was treated and recognized in the community in which he lived as such.
Q. Describe the appearance, features, color, hair, nose, &c of Solomon Bolton?
A. He was a man of rather medium size-about size of Saml Williams-had dark complexion, with dark or dark gray hair perfectly straight. I have heard persons say that it was impossible for him to have negro blood, having such straight hair. My recollection is that he had a large Roman nose-something like Lew Shepherd at any rate his nose was not flat. His foot was rather small-and he was rather a trim made, well formed man physically.
Q. Please state whether or not you were well acquainted with Solomon Bolton and whether or not he lived on your farm, and how long did he live on your farm?
A. I was well acquainted with Solomon Bolton. He never lived on my farm. He lived on Saml Williams farm for several years. I saw him often, sold him goods, and traded with him in various ways and times.
Q. Were you or not acquainted with a man named Breedlove? If so how was he related to Solomon Bolton? Did Breedlove's wife or not have straight hair?
A. I was acquainted with a man named Breedlove. He lived on my farm seven years. He married Solomon Bolton's sister, so I understand, and heard, Breedlove and Bolton often speak of and talk on the subject.
Q. Please state whether or not you are well acquainted with the negro race, and the characteristics by which negroes or person of mixed blood are distinguished from white people.
A. I am acquainted with the negro race and the characteristic by which negroes or persons of mixed negro blood are distinguished from white people.
Q. State whether or not Solomon Bolton was a negro or person of mixed negro blood, judging from your acquaintance with Solomon Bolton and knowledge of the negro race.
A. I did not consider him a negro or person of mixed negro blood. He was not mixed, judging from my acquaintance with mixed negro blood.
Q. Were you acquainted with Jemima the daughter of Solomon Bolton who became the wife of Jerome C. Simmerman, if so was she or not a negro, mulatto, or person of mixed negro blood to the third generation?
A. I was acquainted with Jemima the daughter of Solomon Bolton who became the wife of Jerome Simmerman. I did not consider her negro, mulatto or mixed negro blood.
.......

I. G. Thomas
Pge 139
Q. What do you know about the blood of Solomon Bolton, as to whether he had African blood in him or not-give your best opinion.

  Excepted to because the question seeks to elicit the opinion of a witness.
A. I can't say that he had negro blood in him but he was pretty dark.
Q. Did he have kinky hair, resembling the hair of mulattoes, or not?
A. I think his hair was a little kinky. I have seen 'kinkier' hair.
Q. Did you or not ever know him to vote or 'sit' on a Jury?
A. I never did.
Q. How long were you acquainted with Solomon Bolton
A. Ever since 1840 till he died.
Q. How long have you been in Hamilton County?
A. All the time since 1837.
Q. Have you been generally acquainted in this County with men who have voted and those who served on Juries since 1837 or not?
A. Yes
Q. With whom did Solomon Bolton mostly associate what race of people?
A. I did not live near enough to him to know

Elijah Hale
Page 144
The said Elijah Hale aged 73 years being duly sworn deposed as follows;
Q. Were you acquainted with Solomon Bolton who once lived in Hamilton County Tennessee and his family? If so how long since your first became acquainted with them, and how long were you acquainted with them?
A. I was acquainted with Solomon Bolton very well, but not so well acquainted with his family. I first became acquainted with them about 50 years ago and have known them most of the time since, having known him in this, Marion, and Blount Counties in this state.
Q. How was he always treated, recognized and considered by his neighbors and acquaintances, and how did he hold himself out to his neighbors and acquaintances. Was it as a white person or negro? State fully how he was treated and recognized in that respect.
A. He was always treated as a free negro and held himself out as such to his neighbors.
Q. Were you acquainted with Jemima Bolton who was said to have been married to J. C. Simmerman if so, was she one of the daughters of Solomon Bolton referred to by you.
A. I was not acquainted with Jemima Bolton. I have seen her frequently. She was said to have been his daughter.
Q. Please give a general description of Solomon Bolton, his complexion, shape, size, and character of hair &c?
A. His complexion was about the color of a half breed, a mixture of white and negro. He was a stoutly built, well made man when he was young. His hair was kinky. His general appearance was that of a mulatto.

CROSS EXAMINED
Q. Was Jemima Simmerman a negro, mulatto, or person of mixed negro blood within the third generation inclusive?
A. I do not know. I never saw her that I know of
Q. Did you know Jemima's mother? If so was she a negro?
A. I knew her, she was not a negro. She was a great deal whiter than Solomon Bolton.
Q. Did not the daughters of Solomon Bolton intermarry with white men?
A I do not know... that was the report.

William Rogers
Page 155
Q. Were you acquainted with Solomon Bolton and family, if so, how long were you acquainted with them?
A. I was well acquainted with Solomon Bolton and family from boyhood up to the year 1851 which was many years ago.
Q. Was he a white man or negro or of mixed blood? If so, of what race? Give your best judgement and give a description of the man, complexion, size, shape, color and character of hair, lips, nose &c, give a full description?
A. I regarded him of mixed blood, and I considered him a negro. My impression is that his hair was curly. He was a chunky, heavy set man, weighed about 150 lbs. Don't remember about his nose and everything of that kind. He was looked upon and regarded as a negro by the neighborhood.
Q. How was he treated and recognized by his neighbors, as a white man or as a negro?
A. At gatherings and corn shuckings and gathering of all kinds, when I was with him he was considered a negro and never to my knowledge ate with the white people.
Q. Do you know of his being examined as a witness on voting or offering to vote? If you do, state all you may know about it?
A. I never knew of his giving testimony as a witness, or of his voting or attempting to do so.
Q. At gatherings and public places where he would be, would he associate and eat with the white people or with the negroes ?
A. He was among white folks in shucking corn &c like other negroes, but when the eating time came he did not eat with the white folks.
Q. Was Jemima Bolton the person said to be the wife of Jerome Simmerman one of Solomon Bolton's daughters?
A. Yes sir. She was said to be the daughter of Solomon Bolton
CROSS EXAMINED
Q. At whose corn shucking were you with at Sol Bolton?
A. Daniel Scively and divers of others.
Q. What sort of man did Sol Bolton say about the sort of man he was?
A. He said he was Portugese
Q. Was Jemima Simmerman a negro, mulatto, or person of mixed negro blood to the third generation inclusive?
A. I cannot tell.
Q. Do you know anything about Sol Bolton having been a soldier in the United States Army in the War of 1812?
A. I do not
Q. Did you ever hear him call the roll of his company?
A. I never did.
Q. Do you know about his getting a bounty land clam for services in that war?
A. I do not.
Q. When you were at Sam Williams corn shucking with Bolton did he eat there with the negroes?
A. My impression is he did, if he ate at all.
Sworn and subscribed before me
10th April 1875 W. Rogers.

A. B. Beeson
Page 174
Q. were you well acquainted with Solomon Bolton, the grandfather of Martha, complainant in the Cross Bill, and, if so, state what race of people he was or appeared to be. Also give a description of his person and complexion and appearance.
A. I was. He was called a Malungeon. He was a small spare made man, with low, flat head, had a dark complexion, rather a flat nose, turned up at the end. He wore his hair short, and it was always inclined to curl or kink.
Q. In the neighborhood in which he lived did he associate with white men or free negroes as his equals?
A. His general association was with the Malungeons-his own people. I never saw him associate with whites except when he had business.
Q. How many different families in this County or adjoining Counties did you know of the same race or character of people -name them?
A. I don't now how many- several - but the Perkins- the Goins, Mornings, Shumakes, Menleys &others.
Q. What was the complexion, color or appearance of the wife of Solomon Bolton the grandfather?
A. She appeared to be a whiter woman than he was a man. I have seen her very often. She went rather slouchy and if she had mixed blood in her, it was less distinct than in the old man.
Q. Now state whether said Solomon Bolton ever exercised the privilege of serving on Juries, testifying in the Courts of the County or voting in popular elections, and how long did you know him?
A. I was an officer for sixteen years and during that time I always held the election. I never suffered any man to hold the election over my head. The old 5th District extended to the state line. I sometimes held the election in the 3rd and 4th Districts. Mr. Solomon Bolton never offered to vote when I held the election. At one time I went to see J. C. Rowdens. He told me that he had a n***** suit, and had some doubts as to whether he could try it. I asked him if the parties were all negroes. He said yes. I told him he had as much right to try it as if they were all white. He then asked me if I wouldn’t sit on the case with him. That my judgement should be his judgement and his mine. I agreed to do it. We entered into the trial. I asked if the parties were all there. The suit was the result of a drunken spree. Solomon Bolton spoke up and said he was plaintiff and was ready. The Perkins were defendants. One of them said they were ready. I then qualified Solomon Bolton and his witness. I think three of his daughters were witnesses. I examined them and then qualified the other side-- the Perkins-- and examined the witnesses for defense. We then fixed up the judgement and I got on my horse and left. That was the only time I ever knew of Solomon Bolton testifying in the Courts of the Country at any other time. I never knew him to sit on a Jury. Never knew of his being summoned. I never saw him about the Court House during my reign of office.

CROSS EXAMINED

Q. Do you know that Solomon Bolton had any negro blood in him?
A. Not of my own knowledge - only just from outward appearances.
Q. Do you know anything about the ancestors of Solomon Bolton or the race of people from which he sprung?
A. I do not
Q. Can you swear that Jemima Simmerman had any negro blood in her?
A. I don't know anything about that.
Q. In what Civil District did Solomon Bolton live in Hamilton County, and in what Civil District was it that you never would allow any one to hold an election over you?
A. He lived most of the time in the 4th on this side Tenn river, opposite Samuel Williams. It was the old 5th civil District that I always held the election.
Q. Do you know of Solomon Bolton ever offering to vote, and being refused.?
A. Never
Q. Do you know of Solomon Bolton being called as a witness and being rejected on account of being a negro?
A. Don't know it of my own knowledge. Heard that he was rejected at Marion Co., Cir Court.
Q. Did you not understand that he was admitted to testify in Marion County, and was not some man sent to the penitentiary on his testimony?
A. I never so understood.
Q. Were any of the other sons and daughters of Solomon Bolton married and to whom were they married?
A. There were two others married. One married a Perkins. The other married a brother to Mac Davis' wife. Another married a Davis (Old Hiram Davis.)
Q. Were this brother to Mac Davis' wife and Davis white men or negroes?
A. McDavis' wife's brother was a white man. Hiram Davis is I think a clear blooded white man.
Q. Was not Solomon Bolton of the same race of people as the Breedloves who live near Chattanooga? And was he not related to the Breedlove family?
A. I don't now. He seemed to be darker. They may have been related.
Q. Is Breedlove a negro or Portugese?
A. I don't know. Never said a Portugese that I know of
Q. Are you not taking a good deal of interest in this case in favor of Mrs. Jack, and against Martha Simmerman?
A. I am not that I know of. If so I do not know it. I married into the connection. I am security for Mrs. Jack, but she is amply able to pay costs.
Q. Have you not since this suit was commenced, been talking and interesting yourself about the case? Have you not had frequent conferences with Mrs. Jack's counsel, advising of witnesses by whom the claim of Martha Simmerman could be defeated?
A. I may have talked about it, but I have no interest in it. I may have told Judge Trehitt of some witnesses who would make good witnesses for Mrs. Jack, because I know all the old citizens.
Q. Do you not desire that Mrs. Jack should recover in this case?
A. Of course a man would prefer to see a woman recover. I consider that Sam Williams is the main party, and I prefer to see any decent woman successful in any contest.
Q. What office did you hold when you were dispensing Justice to Solomon Bolton and the others at Esq Rowdens?
A. I was Deputy Sheriff.
Q. What do you understand by Malungeon?
A. I think it is a term applied to mixed blooded people.

A. B. Beeson 2nd April 1875

W. W. Warren
Page 183
The said W.W. Warren aged 65 years being duly sworn deposed as follows;
Q. Were you acquainted with Solomon Bolton who used to live in Hamilton County Tennessee and his family?
A. Yes sir.
Q. How long since you first became acquainted with them and how were you acquainted with them?
A. I think I made their acquaintance about 1844 or 1845, and I knew them until the left the County of Hamilton Tenn.
Q. How was Solomon Bolton treated and considered by his neighbors, as a white person or a negro, and how did he hold himself out to his neighbors?
A. His neighbors treated him as a negro. He told me that we was not a negro, but his looks was different. He looked like he had African blood in him.
......
Q. Do you know that Jemima or Solomon Bolton had any negro blood in their veins?
A. I do not know.
Q. Did not Solomon Bolton always claim to be a Spaniard or a Portugese?
A. He claimed to be a Spaniard
Q. Are you acquainted with that race of people? If so was Solomon Bolton darker in complexion than person of that race generally are?
A. I do not know any thing about that race of people.
Q. Did you now any thing about Solomon Bolton's ancestry?
A. I did not
Q. Did not the daughter of Solomon Bolton intermarry with white men?
A. They did.
Q. What do you know about Solomon Bolton's having been a soldier in the War of 1812?
A. I frequently heard him say he was in that war, and he would tell a great deal about what occurred in that war.
Q. What is the complexion of Martha Simmerman? Does she indicate that there is any negro blood in her?
A. She is slightly dark complected having black hair and eyes. Do not know that she indicates any negro blood.
RE EXAMINED
Q. Did Mr. Solomon Bolton have 'kinky' hair resembling that of a mulatto or not?
A. I think he did
Sworn to and subscribed before me
2nd April 1875
Emmerson Roberts
Page 201
Q. Were you acquainted with Solomon Bolton the father of the woman that it is alleged Jerome C. Simmerman married, if so, for how many years?
A. I never was particularly acquainted with him. I have seen him often and knew him when I saw him.
Q. Do you know of what race of people he was, if not, so state, then give a description of the man, stating the color of his skin, the shape of his head, his face, and nose, and the color of his hair, whether it was straight or otherwise, and whether he wore it long or uniformly cut short.
A. I do not know of what race of people Solomon Bolton was. He was a dark skinned man. I do not recollect the shape of his head. I do not know the shape of his face or nose, but they resembled the negro race. His hair was black and my recollection is that he wore it cut short and it was kinky.
Q. Are you acquainted with a son of Betsie Bolton, a sister of said Jemima, and, if so, state his complexion, or color and which is the blackest said Solomon, the son of Betsie, or his grandfather Solomon Bolton?
A. I am not acquainted with a son of Bessie Bolton
Q. Are you acquainted with a colored man by the name of Jake Stringer. If so which was the darkest, Solomon Bolton or Jake Stringer?
A. I know Jake Stringer. My recollection that if there was any difference Solomon Bolton was the darkest.
CROSS EXAMINED
.............
Q. did you know Jemima Bolton?
A. I do not know that I ever knew her.
Q. Of what race of people was Jemima's mother?
A. I do not know
Q. Do you know and can you swear that Jemima had any negro blood in her veins?
A. I do not know and cannot swear as to that.
Q. Did you know anything about the ancestors of the Boltons?
A. I did not.
Q. What do you know about Sol Bolton having been a soldier in the War of 1812?
A. I do not know anything about it
Q. To what race of people did Bolton claim to belong?
A. I do not know.
Q. Were you well or intimately acquainted with Bolton?
A.. I was not intimately acquainted with him.
Q. How far apart did you and Solomon Bolton live?
A. Some ten or twelve miles.
Sworn and subscribed before me
Aug. 9th 1875

J. T. Stringer
Page 211
Q. Did you know Solomon Bolton, if so, when? What race of people was he of? Describe his appearance, complexion and hair, shape of head and face &c- With whom did he associate? What character and race of people?
A. I knew Solomon Bolton for several years. I always regarded him as a being of the negro race. His complexion was very dark. His head looked to be flat on top and shaped like a Negroes's, and his hair was black and kinky. The Bolton family associated mostly with Negroes.
CROSS EXAMINED
Q. In the event Martha Simmerman is defeated in this suit your children will get an interest in Jerome's estate will they not?
A. My children Dick and Mollie are interested in the suit. They would be an heir.
Sworn and subscribed before me
9th day of Aug. 1875

Daniel Scively
Page 217
Q. Did you know Solomon Bolton?
A. Yes.
Q. Describe his color, hair and general appearance?
A. He was very dark skinned and black hair. I hardly know how to describe the shape of his face and nose. I think he wore his hair short and not very straight.
Q. Did the family of Solomon Bolton associate with and marry into white or black people or families, and if the women had children were they by white or colored men or Negroes?
A. I don't know that I know of any of the women marrying. I know of one having at least one child by a negro or colored man as reputed. His name is Ike Perkins. I remember now that one married a man by the name of John Skelt and they moved to Arkansas, and one married a man by the name of Davis, I think. the Bolton family was not out much with white folks. They mostly associated with Negroes. They and the Perkins colored people [ free] generally associated together.
Q. Do you know anything about the County Court of Hamilton County ever appointing patrols to keep slaves and Negroes away from Bolton's house, if so, about what year and what do you know about it?
A. There were patrols appointed in 1860. I think I was one of the last. There was talk of it before. I don't remember of any certain house to be patrolled.
CROSS EXAMINED
Q. What race of people did Solomon Bolton claim to belong to? Was his wife a white woman?
A. I do not know that I ever heard him say - I do not know about whether his wife was a white woman or not.
Q. Were not Hiram Davis who married a Bolton, John Skeet, and a Mr. Taylor, who also married in the Bolton family white men? Did not Bob Bolton marry a white woman?
A. I do not remember Taylor. Davis and Skeet were white men. Bob Bolton, Solomon's son, married a white woman.
Q. Were any of these parties prosecuted or threatened with prosecution for marrying in the Bolton family?
A. Not that I ever hear of.
Q. Was Solomon Bolton's hair kinky, or was it what we call curly?
A. It was curly instead of kinky.
Q. Describe Jemima Simmerman as nearly as you can? Give her color, color of her hair &cA. She was rather a dark skinned woman, but lighter than any of the Bolton, Her hair was black and straight.
Q .State whether or not Jemima had as much as one eighth negro blood in her? Give your best opinion?
A. She was not a clear blooded white person-she was mixed with something, but I cannot say it was negro. I do not know the proportion of mixed blood in her, if any.
Sworn to and subscribed before me
Aug. 9. 1875

Augustus Evans
Page 236
Q. What was the character of the family of Solomon Bolton as to virtue and chastity?
A. Some of them bore bad names and were said to conduct themselves badly.
Q. Did not colored people both slaves and free persons of color congregate and have their frolics at Bolton's home?
A. I do not know that I ever heard of anything of this kind unusual. I have known of Negroes having corn shuckings on the place, but in the same way they would have had them at any other white person's house in the country.
Sworn and subscribed before me
16th August 1875

Hugh L. W. Allison
Page 243
Q. What is your age and where did you live from 1850 to 1860 and in what business were you engaged?
A. I am 53 years of age. I have lived in Dade County Georgia. I have been engaged in several things within the ten years.
Q. Were you then or ever acquainted with Jerome C. Simmerman or Jemima Bolton?
A. I knew the Bolton in Tennessee. Do not know Simmerman.
Q. If you know anything about what race of people Solomon Bolton was, and the character of his associations, whether with white or colored people, tell what you know about that?
A. The Bolton that I knew was part negro and I suppose associated with people of their color.
Q. What was the old mans name, and where did they live when you knew them, and was one of the old man's daughter married to a man by the name of Bromley and what became of him?
A. Solomon, they lived in Marion County Tenn. Bromley married one of Bolton's daughters or they lived together. Bromley killed a child and was sent to the Penitentiary from Marion County, Tenn for 10 years, but Bromley now lives in Dade  Georgia.
CROSS EXAMINED
Q. Is not Bromley a white man and married to a white woman of respectable family?
A. Bromley is a white man and is married to a white woman. I do not know the family whether they are respectable or not.
Q. Give the date of this (Bromley) trial as near as you can.
A. The Bromley trial was between 1836 and 1844. Do not recollect the year.
Q. Was not Solomon Bolton the prosecutor and a witness against Bromley on this trial against Bromley?
A. I do not recollect, he may have been the pros. and a witness.
Q. How long since you have seen Solomon Bolton?
A. It has been 30 or 35 years since I saw him.
Q. For how long were you acquainted with Solomon Bolton
A. Some 6 or 7 years.
Sworn to and subscribed before me
August 11th 1875

Mrs. Malinda White
Page 257
Mrs. Malinda White witness for Martha Simmerman, aged about 64 years being duly sworn deposed as follows;
Q. Were you acquainted with Solomon Bolton and his father? If so, where did you know them and how long?
A. I was acquainted with them. They lived nears neighbors to me when I was first married. I knew them in Sourens District in the State of South Carolina. I lived by them until I moved to this state. I do not remember the exact length of time, but I had five children before I left South Carolina.
Q. How were Solomon Bolton and his father treated, and recognized by the people and his neighbors in South Carolina, whether as Negroes, or as citizens?
A. They were never called or treated as Negroes. They mustered with white people, visited and associated with white people. I have been on the muster ground and have seen the old many mustering with white people. They voted in elections just as other citizens. They were not white men but were never regarded and treated as free Negroes. the old many belonged to the Church with white people. I have seen him take sacrament in the church with white people.
Q. State whether or not you were acquainted with Solomon Bolton's mother? If so what sort of woman was she, and how was she regarded and treated by the neighbors and person in the community where she resided?
A. I was not acquainted with Solomon's mother, she was dead. and the old man was living with a second wife when I knew them, who was as white a woman as I ever saw.
Q. To what race of people did old man Bolton and Solomon Bolton claim to belong? Describe them, giving their color and kind of hair, and their general features.
A. I think they claimed to be Portugese. Sometimes children would throw up to old man Bolton's children about being Negroes and it made them very mad to be accused of being Negroes. They were rather low in stature, of dark color, Their hair was black, coarse and perfectly straight. Their hair was not like the hair or wool of a negro. It was not kinky. Solomon Bolton's nose was somewhat on the Roman order. Their lips were somewhat thick, but no thicker than that of many white people whom I have seen.
Q. State whether or not the children of old man Bolton attended schools in South Carolina with white people? State whether or not his children intermarried with white people? If you knew Solomon Bolton's wife the mother of Jemima Simmerman state whether or not she was a white woman?
A. They - that is his grandchildren  - went to school wit hwhite children in South Carolina. Several of his grandchildren married amongst white people, and none of them ever associated or mixed with negroes.  I did not know Solomon's wife, the mother of Jemima.
Q. State whether or not you know a preacher named Dyke?  If so, where did he live, how was he related to Solomon Bolton, and what race of people did he belong to?  How was he treated and recognized in this and Hamilton County?
A. I knew the preacher Dyke, have heard him preach.  He lived some where about Kelly's Ferry Marion County.  I do not know the relation he sustained to Solomon Bolton.  I have heard he was a cousin, but don't know of my own knowledge how that is.  He claimed to be of the same race of people that Solomon Bolton claimded to be - Portuguese and Spaniard perhpas, I do not remember positively.
Q. Do you know whether Arch Brown was ever in South Carolina?  If so state upon what business he went?
A. He came to see me in South Carolina when my first baby was about three months old. He is my brother. He also went back there once after that. He and my husband went to Cherokee Georgia to look after some estate of my father. This was abut twelve months after the first trip.
CROSS EXAMINED
Q. What is your age?
A. Sixty four years of age
Q. How many children did the father of Solomon Bolton have by his first wife and how many by his second wife?
A. None by the last. I know of four by the first wife.
Q. Give their names.
A. Creasia and Pollie were the daughters, and one Pet, they called him but I think his name was Solomon, the other Elisha I was thinking of was I think a grandson.
Q. When did Solomon leave that country?
A. He was backwards and forwards from this country to that from the time I knew anything about him until I left that country.
Q. Was he grown when you knew him?
A. Yes sir
Q. What election did you ever now Solomon Bolton to vote in?
A. I don't recollect
Q. Were you at any election when Solomon Bolton voted?
A. No sir
Q. Were you at any election when Solomon's father voted?
A. No sir
Q. were you ever at any muster when Solomon or his father mustered?
A. Yes sir, I was at a Battalion Muster when he went and his grandsons went with him.
Q. Do you allude to the father of Solomon Bolton?
A. Yes sir
Q. Give the names of the grandsons?
A. Elisha Breedlove, Jacob Breedlove and John Bolton.
Q. Did you see Solomon Bolton muster?
A. Yes sir. I saw Solomon Bolton in line.
Q. Did Solomon Bolton live in South Carolina after you got acquainted with him?
A. Yes he would come and stay a year or nearly so and then back here - this was a-long when I first got acquainted with him-Finally he came to this country and stayed all the time..
Q. Why were the grandchildren of Solomon Bolton more particular abut associating with Negroes than white folks?
A. I don't know that there was any difference.
Q. How often did you ever see old man Bolton the father of Solomon Bolton take the sacrament?
A. I can't say how often. They were mighty strict Methodist to go to their meetings.
Q. Did you then have any negro churches there, or were all members of the church in the same church?
A. They were all in the same church, but the negroes had separate seats from the white members, and were waited upon afterwards in taking the sacrament.
Q. What is the name of any white child or person that Solomon Bolton's father sent his children or grandchildren to school with?
A. Billy Ramply,  Isaac Rhodes, and Isaac Strands and many others.
Q. Give the names of the Schoolmaster?
A. Billy Watson kept one school they went to.
Q. Were there negro preachers in South Carolina when you knew the Bolton there?
A. Yes sir
Q. How many years since you moved away from South Carolina?
A. twenty five or six years I expect.
Q. Whom did Pollie and Cressie Bolton marry?
A. Cressied married Reuben Breedlove. I don't know whom Polly married.
Q. Who was the mother of John Bolton?
A. Cressie Breedlove.
Q. Was he born before her marriage?
A. Yes sir.
Q. Have you now given the names of all the Bolton family that you knew?
A. I have given the names of all I was acquainted with.
Q. What was the name of the father of Solomon Bolton?
A. His name was Solomon.
Q. Did you see them both muster?
A. No sir-I saw the old man Solomon muster and his grandchildren.
Q Did you know young Solomon--Old Solomon's son, after you came to this country and left South Carolina?
A. No sir.
Q. Was Solomon-Old Solomon's son- a low, chunky man"
Sworn to and subscribed before me
August 28th 1875

A. Kelly
Page 266
Q. Were you acquainted with Solomon Bolton? If so, when and how long did you know him and where did he live?
A. I was acquainted with Solomon Bolton. I got acquainted with him about thirty years ago. and knew him until he left here several years ago. He lived in several places in Marion and Hamilton Counties.
Q. State whether or not you knew of Solomon Bolton's voting in any elections in Marion County? If so, in what elections did he vote?
A. He always voted. I never heard of his vote being challenged or questioned until I think about the year 1840 his vote was challenged.  My father and I got the law and showed it to the Judges of the election. They decided he was a competent voter, and I never heard his vote questioned after that time.
Q. State whether or not the Records of the Circuit Court of Marion County, made before the war have been destroyed? If so when and how were they destroyed?
A. The records are not at the Court house now. It is said that they were destroyed during the war. I was in Jasper during the war and saw Court papers scattered about.
Q. State whether or not a man named Bromley was sent to the Penitentiary from this County before the war? Who was the prosecutor? Was or not Solomon Bolton examined as a witness.
A. William Bromley was sent to the Penitentiary before the war from this County. I do not remember who was the prosecutor. Solomon Bolton was examined as a witness in that case.
CROSS EXAMINED
Q. When Solomon Bolton voted was it the Harrison election? Was it not in a strong Whig District? And did not the excitement run high, and were you a Whig and Bolton vote the Whig ticket?
A. Yes and I have heard him brag a heap of times that his father was in the old Revolutionary War, was a Whig, and that he stood in his shoes.
Q. Did you ever see or know of him offering his vote afterwards?
A. I don't recollect of it.
Q. Was not Bromley a son in law of Solomon Bolton, and indicted for killing a child of his wife, and was not that a reason for Bolton prosecution and being a witness?
A. I know he was a son in law and killed the child, but don't know that was the reason Bolton was prosecutor and allowed to be a witness because he was a son in law.
Q. Describe the size, build, complexion and general appearance of Solomon Bolton?
A. He was a common sized man-rather chunky. He was dark complexioned, some said he was part negro, and some said one thing and some another, but he said he was a Portugese.
Q. Describe his hair and how he wore it?
A. His hair was dark, and he generally wore it cut off tolerably short.
Q. Was Bromley a man of good character and in good standing, or was he only living with the woman, having taken up with her, and kept low and bad company? How was that?
A. Before that Bromley was under good character, but when he married Bolton's daughter people was astonished at it and he acted badly and it was not long afterwards until he was put in the Penitentiary.
Q. Did not Negroes frequently visit the house of Bolton when he lived in neighborhood, when you knew him?
A. Yes - but those time Negroes would go to most houses. People were not so particular then as now, but how or in what manner the Negroes visited Bolton's house I don't know.
Sworn to and subscribed before me
Aug 28 1875


DAVID MC NABB
Page 270
Q. What is your age? Where do you reside? How long have you lived there?
A. I am about 64 or 65 years old. I live two miles above Kelley's Ferry in Marion County Tennessee. I have lived in this vicinity many years. Perhaps forty or fifty years. I have lived where I now live some twenty five years.
Q. Were you acquainted with Solomon Bolton? If so, when did you become acquainted with him and how long did you know him?
A. I was acquainted with Solomon Bolton. I became acquainted with him some twenty five or thirty years. I knew him some twenty five years.
Q. State where Solomon Bolton lived while you knew him?
A. He lived at different places near Kelly's Ferry in Marion county and sometimes in Hamilton.
Q. State whether or not Solomon Bolton before the late was exercised the privileges of citizenship in Marion County such as voting &c? State in what election you now of his voting?
A. My uncle was a Justice of the Peace who held the election once. Somebody objected to Solomon Bolton's voting. It was decided that he was entitled to vote and he did vote. I do not remember particularly of any other elections in which he voted, but never heard his right to vote questioned after that time.
Q. Do you remember of a man named Bromely being sent to the Penitentiary from this County before the war? If so for what offence was he sent? Who was prosecutor? Was or not Solomon Bolton sworn and examined as a witness?
A. I remember of Bromley's having been sent to the Penitentiary. His wife who was a daughter of Sol. Bolton had a child before Bromley married her and Bromley killed that child. I do not know for certain, but always heard that Bolton was. I was not at the trial, but understood that he was a witness.
Q Was Bromley a white man?
A. He was. He was raised close to me and I knew him from a child.
Q. State whether or not Solomon Bolton and his family associated with white people or Negroes? State whether or not Solomon Bolton's daughter's intermarried with white men?
A. Up in our settlement there was no Negroes. Two or three of his daughters married white men. One of them married a man named Perkins who was a dark colored man, like the Bolton family. The neighborhood talk was that he was part negro.
Q. Did you know Rev Bryan Dyke? What relation was he of Sol Bolton? What denomination of Christians did he belong to? How was he recognized and treated in the community where he lived and preached?
A. I knew Mr. Dyke. I think he called Solomon Bolton uncle, but it might have been a cousin. I am not certain about it. He was well respected amongst the people, preached for and associated with white people.
Q. Which was the darker Solomon Bolton or Mr. Dyke? Were they not or did they not claim to be of the same race of people?
A. Mr. Bolton, I think, was rather the darker. They claimed to be of the same race of people.
Q. Was Perkins and the Bolton woman married, or had they just taken up together?
A. I can't tell the fact abut that. They did not live close to me.
CROSS EXAMINED
Q. Is not the time you speak of Solomon Bolton voting, the same time mentioned by Mr. Kelly today in his deposition in the Harrison election in 1840?
A. I expect it was.
Q. Did you ever see him vote or offer to vote after that time?
A. I cannot say.
Q. Did not the Judges of the election let him vote because it could not be proven that he was a negro to certain degree?
A. That was my understanding from my uncle who was a Justice of the Peace.
Q. You are satisfied that his -Bolton- vote was challenged?
A. That is the best of my recollection.
Q. Describe the complexion and general appearance of Bolton, the color of his hair, eyes and skin, and then state what race of people he belonged to, to the best of your opinion?
A. Bolton had dark hair-He was common sized man. He had dark skin. I cannot say I have an opinion as to his race. It was talked in the neighborhood that he was part negro, but he claimed he was Portugese, when anything was said about it. He always wore his hair close I think.
Sworn to and subscribed before me
Aug 28 1875

Elisha Breedlove
Page 297
Q. State your age and residence, and how long you have resided in the state of Tennessee?
A. I am 50 years old live in Walker Co., Georgia I have lived off and on in the state of Tennessee since 1849. have been in Georgia the past four years.
Q. Where did you reside at your earliest recollection?
A. In Spartanburg District So Ca.
Q. About what year did you leave that District
A. About October 1849
Q. State if you ever knew Solomon Bolton, father of Jemima Simmerman, mother of Martha Simmerman, complainant in the Cross Bill, and what relation, if any are you to him.
A. I knew Solomon Bolton referred to above. He was my mother's brother.
Q. Where did you first know him?
A. In South Carolina-Spartanburg District.
Q. Tell as near as you can when you first knew him?
A. When I was about seventeen years old (say about 1842) he came to see us, on a visit, at our house in Spartanburg Dist.
Q. Mention the names and residences of the brothers and sisters of your uncle Solomon Bolton.
A. Kiddy Bolton whom I never saw is dead. Archibald Bolton lived and died in Spartanburg So Ca. Spencer Bolton lived in Spartanburg and removed from there many years ago. I never knew when he went. Priscilla Bolton is my mother-moved here with me in 1849 and died in this County. These are all the brothers and sisters that I know of.
Q. State how you were received and treated in South Carolina in regard to schools, and were you received into public schools in South Carolina? State whether or not you and your cousins went to public schools in South Carolina and whether or not you were treated as of African blood, or otherwise?
A. We were received into any and all schools in South Carolina. My cousins and myself went to public schools as well as other. We ere treated just as other scholars and not as having African blood.
Q. State whether or not since you came to Tennessee you have exercised the right of voting in elections and testifying in Courts of Justice?
A. I have-both in Tennessee and in Georgia-
Q. To what race of people did your ancestors belong, as you understand it?]
A. I was taught to believe and have always understood that my grandfather Bolton was a Spaniard and my grandmother Bolton was an American by birth.
Q. If you remember of having seen your grandmother Bolton and if so, was she or not a white woman, and where did you marry?
A. I remember having seen my grandmother Bolton when I was small. as I remember she was a white woman. I married first in South Carolina and a second wife in Georgia.
Q. State the color or both of your wives?
A. They were both white women. One of them is still living and can be seen any day.
CROSS EXAMINED
Q. Who did you go to school to in South Carolina?
A. Wm. Watson, James Simons, Harvey Wofford, Alex McCurley.
Q. How long did you go to each? and did you ever go to school there to any other persons?
A. I went to Watson 12 months-to Simons 6 months- or about that time and to the others about three months each. I never went to any others.
Sworn to and subscribed before me
1st Sept. 1875

G. W. Rider
Q. State whether or not you knew Solomon Bolton? If so, how long did you know him ? Of what nation of people was he, and what was his color and into what sort of society was he received, and with whom did he associate?
A. I knew Solomon Bolton-Knew him in 1840 and from that until his death, I don't know of what nation of people he was. I always considered him a free negro. We always called him a free negro, and he was a mulatto or looked like he was about one fourth negro. He worked with Crutchfield when I did in the brickyard. He always went to the kitchen with the Negroes to take his meals. Never knew him to take meals or sleep in the house when white people were. He was always with Crutchfields Negroes when he worked there. So far as I know he was always treated as a free negro.
CROSS EXAMINED
Q. When and where did Solomon Bolton die?
A. I only knew from report that he is dead and I do not know where he died if he is dead, nor when he died.
Q. When did you first know Solomon Bolton?
A. I think it was in 1840. 1841 or 1842. I do not recollect the year. It was while we were making the brick for this house in Crutchfields brick yard.
Q. When did he then work or live after he left Crutchfields?
A. Across the river. I do not know the place. He lived across the river at the time he worked for Crutchfield. I do not know the place where he lived.
Q. Where did you next see him after he left Crutchfield's Brick yard?
A. I saw him here often-saw him at Harrison Tennessee and as I saw other men through the County. I do not know when and where I was him first after he left Crutchfields.
Q. Do you know to what race of people he belonged?
A. No sir.
Q. Has any one talked to you about your testimony in this cause, and if so, who did so?
A. Mr. A. Beeson asked me what I recollected about Bolton. Other parties, the lawyers on the other side asked me since what I knew about Bolton.
Q. Where did Bolton come from?
A. I don't know.
Q. Do you know Elisha Breedlove and how long have you known him?
A. I have known him a good many years. I cannot state the number of years.
Q. What sort of woman was Solomon Boltons wife?
A. She looked like a white woman. I am not sure that I could tell his wife from two or three other women who would come together. One was his wife and they were all white.
Q. Have you not often seen Spaniards, Mexicans, and Portugese as dark as Bolton?
A. I have.
Q. What do you know about Solomon Bolton having been a soldier in the War of 1812, and having received land warrants for his services in that war?
A. I heard him say he had a land warrant for his services in that war, and he wanted to sell it to me. I cannot remember whether he showed me the warrant or not.
RE EXAMINED
Q. What lawyer asked you in regard to Bolton and what passed between you and said lawyer?
A. Mr Shepherd asked me what they would prove by me. I told him what I answered in my answer to 1st question in chief, or the substance of same.
Q. What is the color of Elisha Breedlove?
A. He is about the color of a Mexican or Spaniard or a fourth breed negro.
Q. Do you know yellow Bill Crutchfield as he is called?
A. Yes
Q. What is his color and of what race is he, and how is his color as compared with Bolton?
A. He is a fair skinned man with blue eyes. He was a slave-considered a Negro-calls himself a Negro yet-was bought by Tom Crutchfield out of a drove of Negroes. Bolton was a much darker man than said Bill Crutchfield.
Q. Did you know the wife of said Bolton personally?
A. I did not know her personally. Did not know her from other women that I saw with her.
Q. Did you know any thing of said Bolton told you, or about his claim to land warrants, except what he told you?
A. No.
Sworn to and subscribed before me 2nd Sept 1875

W. L. Dugger
Page 307
Q. What is your age and where have you resided for the last thirty years?
A. I am 49 years old and have resided in Hamilton County for the last 30 years.
Q. Did you know Solomon Bolton, if so, how long did you know him?
A. I knew old Solomon Bolton a long time and up to the late war.
Q. Of what race of people was he? What was his complexion and with what race of people did he eat, drink and sleep?
A. He was a mixture. I can't tell what race he was of. He was called part Negro. he never denied it to me. I don't know who he eat with except on steam boat. He then eat with the Negroes and deck hands, some white and black and all eat together. The blacks would sometimes eat to themselves and the white to themselves and sometimes all together.
Sworn to and subscribed before me
4th Sept 1875

Jefferson Simmerman
Page 311
Q. Did you know Solomon Bolton and family?
A. Yes sir.
Q. Did you know what race of people he and his family associated with, eat and slept with if so, what?
A. We were slaves and he was counted a free Negro and we all associated together pretty much. Bolton and family eat with Negroes or colored people.
Q. Did you ever know of Bolton and his family having dances or frolics at this house, if so, who went to them?
A. Yes. Four or five of us negroes and Samuel Williams' negroes generally attended them.
Q. Did Bolton family take part in the dance with the negroes?
A. Yes sir.
Q. Were the dances finally broken up and stopped, if so, what did it?
A. The people put out patrols, and stopped us colored folks going there and that stopped the frolics at Boltons.
Q. To whom did you belong?
A. to James Simmerman who was a brother of Jerome C. Simmerman.
Q. How far did you live from Bolton?
A. About three and one half miles.
Q. What was the character of Bolton's family and especially of the woman that is said to have married Jerome C. Simmerman? Was it that of a virtuous or lewd woman before her alleged marriage?
A. She was a lewd woman.
Q. How long after the time it was said that her and Simmerman was married before the defendant Martha was born.
A. I think it was only about three or four months as well as I can recollect.
Q. State what you know about an attempt on the part of Jerome C. Simmerman and Jemima Bolton to marry in Hamilton County Tennessee, the reason why it was not consummated and by whom it was prevented and for what reason?
A. His, Simmermans, brother said she was a Negro, and that she was at the time as he believed in a family way by another man who was trying to bring about the marriage to keep it from being known as to who she was pregnant by. And his brother James Simmerman set a lot of us boys that belonged to him to prevent their marrying, which we did at one time-when they left and went off some where and came back and said they were married.
Q. Was Jerome crazy at this time?
A. Yes sir
Q. On whose land do you live?
A. On A. B. Beesons
Q. How long have you lived there?
A. Well, I have been there about twenty five years and have lived on Beesons land since freedom took place, since the war.
Sworn to and subscribed before me
6th Sept 1875

Rev. D. D. Scruggs
Page 315
Q. If you ever resided in Spartanburg District, South Carolina, state when and how long you resided there?
A. I was born there in the year 1806 and lived there until the year 1866, just sixty years.
Q. State whether or not you were acquainted with a man names Spencer Bolton in Spartanburg District So. Ca.?
A. I knew him.
Q. State to what race of people Bolton belonged, and state fully all the facts in connection with your acquaintance with him and his family?
A. He belonged to the Spanish race of people I think. I am positive that it was either Spanish or Portugese. I was Tax Collector in the District at one time and amongst other things I was required to levy a per capita tax on all Negroes and I recollect distinctly that it was not levied by me upon him. He, Bolton was a dark skinned man with very straight hair and long nosed, thin visaged man-At the time referred to when I was tax collector, some parties reported to me that Bolton was of mixed blood. Thereupon I proceeded to investigate the matter by calling in three citizens living in his neighborhood, among whom were a Mr. Young, Mr. Miles, and other to assist me in deciding the question; the decision was in favor of Bolton, to the effect he had no Negro blood in him. About the same time my attention was also called in an official capacity to a Mr. Dempsy who claimed to be a Portugese, and the decision in his case was that he was of mixed blood, but I gave him the right of appeal but he left the country. Bolton and Dempsey were not in any way connected.
Q. Were you acquainted with a Mr. Breedlove who was a son in law of old man Bolton? What race of people did he belong to?
A. I knew him, but not so well as Bolton, I don't recollect to what race of people he belonged, but do not think he was taxed.
Q. State what sort of woman old man Bolton's wife was?
A. I do not recollect particularly, but my recollection is that she was a fair complected and light haired woman.
Q. What was the character which Bolton sustained in the community in which he lived as to honesty and integrity? State whether or not his associations and church relations were with the white people or Negroes? State whether or not he voted at elections, participated in musters and sent his children and grandchildren to school with white children?
A. I know nothing against his honest character. I do not know as to his church relations but if he had any at all, they were with the white people, as all the Negroes were associated with the whites in this capacity at that time. I think he voted with the white people but as to the musters and school matter I know nothing.
Q. State whether or not yourself and the gentlemen whom you called in to settle the question as to Bolton's liability for the free Negro tax were slave owners and well acquainted with the Negro race?
A. We were all slave owners and well acquainted with the Negro race. I suppose the aggregate number of slaves belonging to the gentlemen referred to and myself was one hundred.
Q. State whether or not old man Bolton was respected as a good citizen by his neighbors? How far apart did he and the gentlemen before mentioned live at the time referred to by you.
A. I never heard anything than good reports as to his citizenship and he was respected by his neighbors so far as I know. He and the gentlemen referred to lived in the same neighborhood not more than six miles apart.
Q. What do you know or did you know about his having been a Revolutionary Soldier?
A. I heard it spoken of that either he or his father was a Revolutionary Soldier.
Sworn to and subscribed before me
6th Sept 1875

Samuel Williams
Page 319
Q. Were you or not well acquainted with the reputation of and character of Jemima Bolton before and at the time of her marriage with Jerome C. Simmerman? If so, what was her character for virtue and chastity.
A. I was acquainted with her character. I never heard of any thing wrong with her except it was with Jerome C. Simmerman. She and Jerome were to have been married on Christmas day and the friends of Simmerman prevented him from going to Bolton. They were married on the 14th of June after this and she was at the time in the family way by Jerome C. Simmerman as he afterwards informed me. Jemima never had any other suitor or sweetheart except Jerome that I know of.
Q. Where did Jemima live at this time and what were your means of knowing the character she sustained?
A. She lived with her father and mother on my farm, and they had lived there for a number of years.
Q. Was there ever any improper intimacy or criminal connection between you and Jemima at any time?
A. No sir-she is clear of that charge.
Q. State whether or not while Solomon Bolton lived on your farm there were ever any Negro frolics which Negroes attended at his house? If such thing had occurred would you have known it?
A. There never was that I know of. I think I would certainly have known it if any such thing had occurred.
Q. Did Bolton live any where else in this neighborhood except on your farm?
A. He did not.
Q. State whether or not you ever knew of a family of free Negroes that kept a family record of birth, marriages and deaths?
A. I never new of any such thing being kept by free Negroes.
CROSS EXAMINED
Q. How far from your house did Solomon Bolton live?
A. I suppose a little over ½ mile across the river from me.
Q. How often did you visit his family, and did you know what was occurring at his house ever night?
A. I visited his family sometimes two or three times a week and sometimes would not be there for two or three weeks. Was not there of nights except passing after night occasionally. I did not know what was going on after night-- only supposed I would hear of such thing if it had been going on. Negro frolics seemed pretty big.
Q. How wide is the river opposite your house and how far did Bolton live from the river?
A. The river is some three hundred and fifty yards wide. Bolton lived about 150 yds from the river and it is about 300 yards from my house to the river.
Q. Did you never hear of Jemima Bolton being in a family way before she was said to have married Jerome Simmerman?
A. Never heard anything about it until just a day or two before they were said to be married-but was not much surprised at it as he was there over half his time, I think.
Q. Were you present and see them married?
A. No sir -was not.
Sworn to and subscribed before me
21st September 1875

Elizabeth Bolton
Page 323
Q. What is your name and where have you resided from your earliest recollection?
A. My name is Elizabeth Bolton. If I live to see the first day of next March I will be forty five years old. I lived at Mr. Oates in Marin County where I first could recollect. Then at Adam Lambs, then at old man Rogers on Sale Creek. Next on Mr. Williams place across the river opposite his house from there I went to Illinois.
Q. With whom did you live all this time?
A. I lived with my father till he died in Illinois since that time have lived by myself.
Q. What became of the infant daughter of Jerome and Jemima Simmerman after Jemima's death and where is she now?
A. I took her when she was nine days old and have kept her with me all the while. She is now at Mr. Williams' house. She lives with me on Mr. Williams farm.
Q. State whether or not the complainant in the Cross Bill is the daughter of Jerome and Jemima Simmerman?
A. She is the same girl.
Q. To what race of people did your father belong? Was there any Negro blood in him? State from what you may have heard your father and his brothers and sisters say on this subject.
A. My father's father was a Spaniard. There was no Negro blood in them. I have heard my father talk about it and he said there was no Negro blood about them.
Q. To what race of people did your grandmother Bolton belong?
A. I never saw her and never paid any attention to what my father said about her.
Q. State with what class of people your father's family associated?
A. They associated with the white people-generally poor people.
Q. State whether or not there were any Negro frolics ever had at your father's house, or frolics where Negroes came and danced with your father's daughters?
A. No sir, there never was any Negro frolics at our house. Nor were there any frolics where Negroes came, except corn shuckings. I never danced a step in my life. Jemima never danced. My sister Sallie as I heard danced some after she was married.
Q. What was the character of Jemima before marriage?
A. It was just as good as any other poor girl.
Q. What was your grandfather Bolton named and where did he live?
A. His name was Spencer Bolton and lived in Spartanburg District South Carolina.
Q. How long has your father been dead?
A. It has been about six or seven years; do not remember exactly, but the date of his death is in our family bible.
Q. How did the color of his skin, and the color and straightness of his hair compare with yours?
A. There was very little difference in the color of our skins, if any thing, I am a little darker than he was. Our hair was just alike.
Q. Will you attach to this decoction a lock of your hair?
A. I herewith attach a lock of my hair.
CROSS EXAMINED
Q. Are you a daughter of Solomon Bolton?
A. Yes sir.
Q. Was not Jemima Bolton in a family way when she is said to have been married to Jerome Simmerman, and how long after she was married before she gave birth to a child?
A. She was in a family way, before she was married, but I disremember how long after she was married before she gave birth to a child.
Q. State as near as you can how long it was after they were said to marry before said child was born?
A. It was about five months after they was married as near as I can recollect.
RE EXAMINATION
Q. Who was the father of the child born five months after Jerome's marriage? Under what circumstances did Jerome Simmerman have intercourse with Jemima? What did he say about it?
A. To the best of my judgement Jerome Simmerman was his father. He said that he would not have got her if he had not got around and over persuaded her. He said my father was unwilling to the match because Jerome was rich and Jemima was poor. He went to him the second time and told my father that Jemima was in the family way by him and then the old man consented for him to marry her.
RECROSS EXAMINED
Q. Is not Jerome Simmerman insane or crazy and was he not insane before he is said to have married Jemima.
A. He is crazy now, or if he is not he acts like it. I can't say whether he was before or not. When he was coming to see her and was at our house with so much sense as any man I ever saw.
Sworn to and subscribed to me
21st September 1875

Kittie Williams
Page 329
Q. Were you or not acquainted with Solomon Bolton the father of Jemima Simmerman? If so, when and how long did you know him?
A. I was acquainted with him. I first saw him in the spring of 1846. I knew him from that time till about the time of the late war. I think he stayed here until after the surrender. He lived on our place, just opposite our house across the river from the time he came here till he left.
Q. How was he treated and recognized by you and his neighborhood, whether a negro or not?
A. He was treated and recognized by our family at the time he lived here as a Spaniard.
Q. State whether or not he ever visited your house? If so was he or not received as a negro? State whether or not he ate with the white family or negroes while at your home?
A. He was here often. He was not treated as a negro. He would not be treated as a negro. He always when he ate here ate at our table with the white family.
Q. State whether or not your husband was the owner of a considerable number of negro slaves? State whether or not your would have permitted a negro or person of mixed negro blood to have eaten at your table?
A. He was the owner of a considerable number of negro slaves. We never did permit such persons to eat at our table.
Q. If you ever had occasion to observe closely as to whether or not Solomon Bolton's hair was kinky, state the circumstances and the result of your observations.
A. Our negroes complained that we were letting Bolton eat at the table. They said he was a negro and his hair was kinky. On one occasion while he was eating at my table I concluded that I would examine his hair closely. It was about two inches long and perfectly straight. The negroes always said that his hair was kinky at the back of his neck. I knew it was straight in front, and at this time I just walked behind him and examined the hair at the back of his neck. It was straight and extended to and a little over his coat collar. He raised a family of children, all of whom I knew, and they all had straight, black hair. I also knew Bolton's sister and brother and their hair was straight and black.
Q. State whether or not there were any negro frolics, or frolics at which negroes attended, held at Bolton's house while he lived on your farm? If such an occasion had taken place would you or not have known or heard of it from your negroes and others.
A. I never heard of any negro frolics or frolics at which negroes attended there, unless you would call corn shuckings, frolics. He had corn shuckings and had Negroes at them like other families. He frequently had preaching at this house. I think if such frolics had been held it is more that likely I would have heard of it.
Q. What was the character for virtue and chastity sustained by Jemima Bolton?
A. Very good so far as I heard. I never heard anything disrespectful of her. I knew her from a little girl and never heard or knew of anyone going to see her except Jerome Simmerman.
Q. State whether or not there was any negro blood in Jemima Bolton judging from her color, her hair, her nose and other features?
A. I do not believe there was.
Q. What did Solomon Bolton and his people claim as to the race of people to which they belonged?
A. They claimed to be Spaniard and Portugese.
Q. Was his wife a white woman? State whether the daughters of Bolton intermarried with white men? Give the names of the white men who married into the Bolton family?
A. His wife was a white woman with fair skin and blue eyes. All that I knew married white men except one, Polly married or lived with Mr. Perkins. Hiram Davis a white man married one of Bolton's girls. Bob Taylor a white man married another. Jerome Simmerman married another. Bob Bolton, a son of Solomon married a white woman-Miss Taylor.
Q. How far did Jerome and Jemima live from you while they lived together as husband and wife?
A. It was not over a half mile.
Q. How did they get along together? State how Jerome treated her, and how she treated him?
A. So far as I knew they got along well together.
CROSS EXAMINED
Q. Are you the wife of Samuel Williams, the next friend of Martha Simmerman in the above suit?
A. Yes sir
Q. How often did you visit Solomon Bolton's family?
A. I don't think I ever made special visit to his family. May have stopped there sometime in passing, or looking at the corn.
Q. What was the color of Solomon Bolton? Was it not that of a mulatto or half breed negro?
A. He was dark skinned.
Q. Was he not darker than a dark skinned white man, and was not the color different to that of a dark skinned white man and did he not look like a mulatto?
A. He was darker than a dark skinned white man, but I never thought his color looked like a mulatto or negro, but thought it looked like Spaniard. I have saw one or two Spaniards in my life time.
Q. Did you know what was occurring or going on at the house of Solomon Bolton's house of a night?
A. No sir-I did not.
Q. Was not Jemima Bolton in a family way


Page 403
William McGill (Justice of the Peace, Hamilton County TN)

Q. Was this character that of a white person or negro, or of what race did he have the character of being?
A. He was a mixed blooded man in some way, that was his character. We generally called them Malungeons when we talked about the Goins and them—the Goins that were mixed blooded.

John Cummings
Page 407
Q. With what race of people did Solomon Bolton associate in eating and sleeping? Was he classified in society as a white or colored man.
A. I believe he had nothing to do with the white people in eating and sleeping. He generally eat and slept with negroes as far as I ever knew about him.

Page 408
Q. Describe the color and appearance of Solomon Bolton?
A. He was tolerably yellow, about as yellow as gingerbread colored negroes. His hair was a little sorter kinky—and his lips were rather thick.

Page 409
Q. Do you know the race of people from which Solomon Bolton was descended?
A. I do not.
Q. What did he and Mr. Dykes claim as to their pedigree, or the race from which they were descended?
A. When he was drinking he said he was a Portugese. He said some called him n*****gee, and some one thing, and some another. When he was sober, I never heard him say any thing about it. Dykes claimed about the same as Bolton.

Page 410
Q. Whose negroes did Bolton eat and sleep with to your knowledge?
A. Alexander Kelly’s and old Johnny Kelly’s.
Q. When did you see Bolton in bed with a negro?
A. I never saw him in bed with one. I only know what I heard other negroes say.
Q. Do you know that Jerome Simmerman’s wife had any negro blood in her?
A. I do not—only from her looks.

Page 411
Q. Did you ever see a Spaniard or Mexican of as dark complexion as Bolton?
A. I have seen some Mexicans as dark as any body. I do not know any thing about Spaniards. Mexicans’ hair is always straight.
Q. Was not Bolton bout the color of a mulatto with one fourth negro in him?
A. If there was any, it looked like there was more than that in him. I do not know that thee was any negro blood in him.
Q.  Was Solomon Bolton’s hair Kinky or curly?
A. It was sorter curled up with a kink in it. When it was cut close it was sorter kinky.
Q. Did you ever know a family of free negroes, who kept a family record showing the marriages, births and deaths of members of the family?
A. I never did.

Page 412
Q. Did you ever inquire or try to know whether any free negroes kept family records or not?
A. No sir.
Q. If you have a personal knowledge of Bolton eating and sleeping with negroes, state what you know about it!
A. I have seen him eating with negroes.
Q. Did you ever be with any of Solomon Bolton’s family or with Solomon Bolton, when hot and seating, and smell them?
A. I never smelt Solomon, but I have worked with the Perkins boys, grand children of Solomon Bolton. I could smell the negro on them and it was in them too.

J.C. Rowden (Justice of the Peace, Hamilton County TN)
Page 413

Q. Did you ever as Justice of the Peace or otherwise marry any of Bolton’s daughters to any person?
A. I did not.
Q. Was Solomon Bolton colored or white people? What was the color of skin, eyes and hair and general appearance?
A. I would have taken him for a colored man. His skin was very dark, eyes a sort of dark grey, rather on the n***** show. His hair as well as I recollect was a dark kinky hair; he always wore it short. His general appearance was that of a free negro.
Q. Do you know anything of Solomon Bolton ever voting, or being sworn when white persons were interested, or of any of his children marrying white people? If so, tell all you know about it:
A. I did not.
Q.  Do you know anything bout Bolton’s race of people of your own knowledge?
A. I do not.
Q. What did he and Mr. Dykes claim as to their race? Are they now dead?
A. I never heard either say. Dykes passed as a white man, and preached for us. I did not know of their relationship then. They are both dead.
Q. From your knowledge of the negro race would you say that Dykes had any negro blood in him?
A.  I do not know.

James Cummings
Page 418
Q. Describe Solomon Bolton, his features, color, hair, eyes and generally, and there state of what race of people he was?
A. I can’t tell what race he was, only what he said, when drinking—he has said a great many times that they called him a negro, but that he was not, he was Portugese—he was a yellow or copper colored man. His hair was black. He had long hair.

Page 420
Q. What akin was preacher Dykes to Sol. Bolton? Was he not a respectable, good citizen?
A. Sol. Bolton was preacher Dykes’ uncle. He (Dykes) was a clean nice old man, Everybody in the neighborhood went to hear him preach.
Q. Did he preach for negroes or white people?
A. He preached for white people.
Q. Was not Bolton and Dykes of the same race of people, about same color, hair of the same kind?
A. Bolton was darker than Dykes. They were of the same race of people. Dykes mother was Bolton’s sister. Their hair was like, being black and long.
Q. Did Bolton and Dykes associate with white people?
A. Dykes did, I was not much acquainted with Boltons. I was there occasionally.



Note: page 425-- Between years of 1845-60 patrols were appointed to keep negroes or slaves from the house of any free negroes in the 3rd District.

Page 436
November 1875 before Chancellor Bradford upon the pleadings, exhibits, and proof in the causes.
Page 437
And the court being further of the opinion upon the Cross Bill of Martha A. Simmerman, and all the proceedings in these causes that Jerome C. Simmerman and Jemima Bolton were legally and lawfully married on the 14th day of June 1856, and that said Jemima Bolton was not of mixed African or negro blood within the third generation inclusive, and that her said marriage was not prohibited by the laws of either the State of Tennessee or Georgia—and the Court being further of the opinion that the said Jerome C. Simmerman at the time of his said marriage had sufficient mental capacity to contract a valid marriage with the said Jemima Bolton, and did contract such marriage and afterwards lived and cohabited with the said Jemima as his wife, and that he treated and recognized her as his wife, and she was so treated and recognized. --------
Page 438
The Court is pleased to adjudge and decree, and does decree that Jerome C. Simmerman and Jemima Bolton were lawfully and legally married on the 14th day of June 1856, and that Martha Simmerman is the only living issue of such marriage, and that Elizabeth Jack and Richard and Mollie Stringer, children of Mary Stringer dead are not heirs apparent of the said Jerome C. Simmerman.----

Martha Simmerman
Page 449:
Question:
Are you the Martha Simmerman who was complainant to the Cross Bill in this case? State where you lived when this Cross Bill was filed? Who brought you to this place, and at whose expense were you brought?
Answer:
I am the same Martha Simmerman. I lived in Illinois when the Cross Bill was filed. Mr. Williams brought me here at his own expense.
Question:
Who has provided for you since you came here?
Answer:
Mr. Saml. Williams.
Page 450
Question:
With whom did you live in Illinois?
Answer:
With my aunt, Elizabeth Bolton.

Page 451
Question:
State with whom you have resided since the death of your mother? Has your aunt Elizabeth Bolton been in a condition to procure necessaries for you since you returned to Tennessee?
Answer:
I have lived with my aunt Elizabeth Bolton since my mother’s death. I was raised by her. My aunt has not been in a condition to procure the necessaries for me since our return. Mr. Williams has provided for her the same as he has for me.

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