================================================================================ *** Jackson Co., TN Loose District/Chancery Court Papers ================================================================================ ================================================================================ reel #103 Permelia Gates Langford ================================================================================ -------------------------------------------------------------------------------- [NEW] OGLESBY, LANDON w. vs ROBERTS, JOSEPH B., et al Chancery 1866 [Note: Bills and cross-bills of Roberts vs Oglesby, L. T. Armstrong vs Permelia Langford et al]. DEPOSITIONS beginning 17 October 1867, Celina, Jackson County, Tennessee: W. M. Savage age 30. Acquainted with Joseph B. Roberts, S. Cross Armstrong and L. W. Oglesby. They resided in Celina, Jackson County December 1860. Armstrong had been merchandising prior to that date in Celina. S. Cross Armstrong sold Jo B. Roberts a stock of goods... took notes on which Landon W. Oglesby was security. I have heard Jo B. Roberts say he sold his land to Mrs. Langford. I and J. B. Roberts were both clerking in the house [store] of Stone & Oglesby in Celina in 1860. /s/ W. M. Savage Wm C. A. Griffith age 37. Ques: State if you purchased the Kinderhook farm or [also known as] the old Amonett farm in Jackson County. Ans: I made the trade with Permelia Langford. I paid for said farm in a farm in the State of Texas valued at $6,000, $1,000 in cash and gave my note for $1,000 which remains unpaid, making in all $8000. I first contacted Jo B. Roberts about the farm and he said Permelia owned it. I asked him to talk to her about selling it. Jo B. Roberts was present when I made the trade, but from what I could see Mrs. Langford controlled the trade. My understanding is that Jo B. Roberts has moved to the farm in Texas. Ques: State if the object of the trade was for Jo B. Roberts to avoid a debt in Louisville. Ans: I have heard Jo B. Roberts say he owed a debt to the Langford heirs and he sold the land to her in order to pay that debt. He wanted to give that debt preference over his other debts. Mrs. Langord said she bought the land from Roberts in order to save the debt. I understood her to mean the Irvin Langford estate. Mrs. Langford wanted to make a quit claim deed because she heard of Amonett heirs bringing a suit about the land and since she was a widow and I was a man I could attend to the suit better. Being a widow she did not want to be involved in a law suit. Ques: You say Jo B. Roberts moved to Texas on the land you sold to Mrs. Langford do you not know her other son in law Smith has gone there to live on the same land? Ans: My understanding is that Mrs. Langford has sold her other son in law Smith one half of said Texas tract. /s/ W. C. A. Griffith Jesse M. Skipworth [blank] years. My wife rented a part of the Kinderhook farm from Jo B. Roberts in 1865. I heard Jo B. Roberts say he had sold a part of the farm to Dr. Plumlee provided Mrs. Langford was willing to make a deed. This was before August 1865. After August I tried to rent and he said I would have to go to Mrs. Langford that he had sold the land to her. Ques: State if Jo B. Roberts was not dissipated in his habits. Ans: He drank a rite smart and gamboled [sic] some. /s/ J. M. Skipworth Micaja Stone [No age given]. Had a conversation with Jo B. Roberts. He said Mrs. Langford had sold part of the farm to Dr. Plumley. I told him I would have liked to buy it myself - that I would trade a note I held as guardian of my father on Ausburn Stone and a note I held likewise on him Jo B. Roberts. He said the trade was not confirmed with Plumley... no writings had been drawn. He said he would not have let Mrs. Langford have it but for a debt hanging on him and L. T. Armstrong in Louisville and Armstrong had put his means out of his hands and Roberts did not want to pay Armstrongs part... Jo B. Roberts was on the farm and remained there until he moved Novr 1866 or about that time. He told me where the land lay in Texas. I told him I had seen it and he was badly cheated. I know Arch P. Green he is acting for L. W. Oglesby and L. T. Armstrong in suggesting questions to their solicitors in this suit. Luke T. Armstrong and L. Cross Armstrong are brothers. L. W. Oglesby is their nephew. I held a note on Jo B. Roberts at that time [1860] for a negro for $500 due 3 or 4 years past and the balance my father held some notes on him, in all $600-$700. My conversations with Roberts were in 1866. Money was scarce, times hard and property low in this country. A came here [to Celina] a little before Christmas 1865. Said debts were owing some two years before that time. Ques: Is your father William Stone of sound or unsound mind? Ans: He is unsound mine. I & James S. Stone is his guardians he has no will in existence to my knowledge. I will be entitled to a share of his estate. I have known the Kinderhook farm thirty years, same owned by Amonett and then his heirs. The Ausburn Stone note was $1200 or $1300... note on Brother John Stone for about $1200 and a note on Brother James S. Stone for about $1200, in all with interest about $4000. I was afraid it would trouble me a great deal to collect them. I think now they can be collected. Ques: Did you not report the same debts as doubtful to the County Court of Overton County as guardian of your father? Ans: I did two of them the other I don't think I did. Ques: Say if the notes at the time you proposed buying his [Jo Roberts] land would be his share in your father's estate. Ans: I thought probably the notes he owed Bennetts estate and the debts he owed my father - would amount to more than his share in Bennetts estate and the estate of my father which I considered all my fathers estate. James S. Stone, John Stone and Ausbon Stone... did all own good farms. After I was appointed guardian of my father... I filed an inventory June or July 1867. Ques: Who has been attending to L. W. Oglesby's business since he left here? Ans: My understanding Arch P. Green. Jo B. Roberts is my sisters son and he married Mrs. Langfords daughter. Ques: Did not Jo B. Roberts sign a petition to Overton County for your removal as guardian of William Stone? Ans: He did not that I know of. /s/ Micajah Stone J. H. Roberts [No age given]. Some time in July or August 1865 I found a note in the road at the nine mile post on the road from here [Celina] to Gainesboro executed by Jo B. Roberts to Mrs. Permelia Langford for $1500. I think I gave it to Mrs. Langfords oldest son. My best recollection it was dated 1861 or 1862. Mrs. Langford later said Jo B. Roberts had paid off the note in a land trade. Where I found the note is 7 or 8 miles from Mrs. Langfords and the place is on the road from her house to Gainesboro. /s/ J. H. Roberts Samuel Brown age 42. Been living on the Kinderhook farm three years, rented from Jo B. Roberts in 1865, contract first of the year, on the thirds. He got my rent corn & my Brothers for 1865. Some hog man Mr. Officer came with him in 1866 and bought the corn don't know who got the money. Samuel [his X] Brown James S. Stone age 46. Jo B. Roberts came to my house... two oil men were there. I asked if he had leased his land... said he was going to sell to Mrs. Langford. He was talking about going to Texas, wanted me to sell out and go. Jo B. Roberts is my nephew and Mrs. Langford is his mother in law. In 1865 and 1866 he drank to excess... gambled. I drank too much frequently at that time but was sober when I had my conversation with Jo B. ...I am at law [lawsuit pending] with Permelia Langford. My recollection has not been good. It has got much better since I quit drinking. Ques: Are you a son of William Stone and Brother of Bennett Stone, decd and joint guardian with Micajah of William and joint administrator with Micajah of Bennett Stone? Ans: I am all of these. I have been acquainted with the land 30 years. When I first knew it David Biggerstaff owned it Amonett & Bransford purchased of them [Biggerstaff] afterwards Amonett purchased Bransfords interest. At Amonetts death it descended to his heirs and afterwards was sold for distribution among the heirs and Hall Holeman who married one of Amonetts heirs purchased it. Bennett Stone as I understood purchased of Holeman and Jo B. Roberts purchased of him. I understand Jo B. sold to Mrs. Langford who sold to W. C. A. Griffith. Ques: Say at the time of the sale of Amonett heirs if any were minors or married women. Ans: Nancy Amonett was the wife of Hall Holeman and all the others were minors. /s/ J. S. Stone Amos K. Tinsley, age 45. Am acquainted with Jo B. Roberts handwriting. He signed the notes for $582.66 dated August 1, 1861 and $500 dated March 11, 1861. I am the administrator with will annexed of E. F. Langford and successor to Bennett Stone who was Executor. After my appointment I found the notes among the papers belonging to the estate. I have known Mrs. Langford 30 years or more... character good... honesty...integrity. Her husband E. F. Langford has been dead several years, man of good estate, left her a considerable property and she has managed the estate very well. Jo B. Roberts married one of Mrs. Langfords daughters - his wife has two children. He was in the confederate army - became considerably demoralized... drank to excess and gambled. Ques: Say what amount Jo B. Roberts and wife had coming from E. F. Langfords estate. Ans: Nothing - Bennett Stone had made a settlement with them... $1720. Many debts were owed estate... if they can be collected she may get a small amount. Ques: State what is one distributive share - what was paid to Nat Smith and wife. Ans: It is not all collected. I paid Smith and his wife $15_0 [smear] and paid Wm P. Stone $1500 and took his receipt. They only claimed as much as Jo B. Roberts had received and I loaned them $200 and took notes for same. RECEIPT [Submitted by Tinsley as Exhibit]: $1720, Celina, August 1st 1861. Received of Bennett Stone Executor of E. F. Langford deceased... our distributive share or - as the will provides and if it is more than my part I bind myself to pay back... make equal with other heirs. /s/ Jo B. Roberts, s/s Florintha Roberts Ques: Who is Florintha Roberts? Ans: Florintha Roberts is a daughter of E. F. and Permelia Langford and was the wife of Jo B. Roberts. The Smith and Stone referred to by me married other daughters of E. F. and Permelia. Jo B. Roberts was a nephew of Bennett Stone. He had lived with and clerked for Bennett Stone in his store. He [Roberts] was about 21 when he married. I do not believe he had sufficient estate to pay for the land... had no estate of his own. He had interest in a tract of land left by his father worth about $1000. I believe he purchased the Kinderhook farm from Bennett Stone some time after he and Florintha were married. I don't know the value of Jefferson Roberts, deceased estate. Jo B. was a son of Jefferson Roberts, a nephew of Bennett Stone and a grand son of William Stone. /s/ A. K. Tinsley W. H. Botts age 42. Am a practicing attorney in Jackson County, Tennessee... attorney for Mrs. Langford and W. C. A. Griffith. /s/ W. H. Botts William P. Stone age 23. I married Mrs. [Permelia] Langfords daughter, a sister of Jo B. Roberts wife. Jo B. Roberts occupies the land in Texas as Mrs. Langfords tenant. She said she thought if he moved to Texas he would quit drinking... he would never do any good in this county with his associations here. I have lately removed from Texas to this county. While I lived in Texas I lived in an adjoining county to where Mrs. Langfords lands lie. Mrs. Langford sold half the land to Nat Smith and proposed to sell me half. I have been married 12 months the 4th day of this month - I left Jackson County for Texas in March last and got back to Gainesboro 19th August last with that exception I have been living at Gainesboro since my marriage. I was on Mrs. Langfords land in Texas - 400 acres, worth $10 an acre. CROSS-EXAMINATION: Land has risen rapidly in Texas since the close of the war. There was no floor in the house when Roberts went there, no fence but he has put up some. Some was in cultivation but had grown up in bushes. Raw land nearby is $.50 to $2.50 an acre. /s/ W. P. Stone ?Esibinus Brown, age 28. Lived on Jo B. Roberts tract in 1865 and 1866. Jo B. Roberts got the rent corn in 1865 for his own use. In 1866 John Officer got it and fed it to his hogs. /s/ E. Brown Foregoing depositions certified by County Court Clerk 20 October 1861. COPY OF DEED: J. B. Roberts to Pamelia Langford... land north side of Cumberland river on procters creek District 6, Jackson County bounded by... procters creek with its meanders... little procters creek... in Savages line now ?Call [or Cale/Cole] line... dower line of Mrs. Martha Amonette... bed of procters creek with its meanders to the beginning... 2nd tract... northeast corner of the cower... ?Coes spring branch north side of procters creek... near the Brink of a Cliff... Spears field... Savages line of 25 acre survey... Savages line of 65 acre survey... corner of Browns 100 acre survey... being 300 acres for $4500. 1st August 1865. /s/ J. B. Roberts ANSWER of Permelia Langford, Jo B. Roberts and William C. A. Griffith to Bill of Complaint of Luke T. Armstrong. Respondent Griffith knows nothing, was not acquainted with co-defendants until fall 1865... knows nothing of debt which Roberts or the firm of Armstrong & Roberts owed. He bought the farm from Mrs. Langford. Respondent has been informed co-defendant Roberts is planning to remove to Texas. Respondent conveyed to co-defendant Langford 404 acres in Grason [Grayson] County, Texas. Respondent lives within one mile of Celina and did before he bought the land... wanted to trade. Respondent Langford has no money or other effects of her co-defendant Roberts. Denies fraud. Respondent Jo B. Roberts admits that he and complainant once were partners, denies liability of extent set out by Complainant, that he eventually plans to pay his debts but does not want to pay those of Armstrong. Complainant is insolvent. Respondent Roberts sold land not to hinder creditors but to pay debts. /s/ W. C. A. Griffith, /s/ Pamelia Langford DEPOSITION 13 December 1867: Martha Jane Stone age 21. Gave deposition at house of her mother Pamelia Langford. /s/ Mattie Jane Stone ANSWER of Landon C. Armstrong and Landon W. Oglesby to cross-bill of Joseph B. Roberts [Details notes and debts on which judgment was recovered, no relationships given - mlj]. ANSWER of Joseph B. Roberts and Pamelia Langford to Bill of Complaint by Landon W. Oglesby and cross-bill of Joseph B. Roberts of Jackson County against Landon W. Oglesby and L. Cross Armstrong, the former a citizen of the State of Texas and the latter a citizen of the State of Kentucky. On 31 December 1860 Joseph B. Roberts executed to L. Cross Armstrong with Landon W. Oglesby as security two promissory notes... executed in the State of Tennessee. BILL OF COMPLAINT of Landon W. Oglesby of Jackson County against Joseph Roberts and Permelia Langford. Complainant was security for Joseph Roberts, failed to pay, judgment was rendered. Believes sale of land was to avoid paying debt. DEPOSITION of Mattie J. Stone. Her mother Pamelia Langford let Joseph B. Roberts have money several times... was on banks of this state [Tennessee], not confederate money. /s/ Mattie J. Stone