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Defendant to be read as evidence, in a certain cause now pending in the chancery
court, held for the 31st Chancery District of the State of Alabama at Athens, on
the 4th Monday in May next, wherein John Hardin is complainant and Susan
Hardin is defendant, and the said Joel Woolley, Francis Woolley and John R.
Mitchell, being first duly sworn and charged by me, to speak the truth the
whole truth and nothing but the truth in the premises, deposes and says, by
Joel Woolley first.
Testimony of Joel Woolley
Ansr. to 1st Intry. - I am.
Ansr. to 2nd Inty. - I have no recollection of ever hearing any such charge
made, or of ever hearing complainant acknowledge that he had accused his
wife with having criminal intercourse with any man, but admitted that
he was jealous or had been of his wife.
Ansr. to 3rd Inty. - I never did.
Ansr. to 4th Inty. - He said he reconed or expected he was to blame, for accusing
his wife with other men, without first seeing things plain, but was still of the same
opinion.
Cross Interrogatories,
Cross 1st - I have no recollection of the time or place, that we had any
conversation on the subject. I never did.
Cross 2nd - I live within a short distance of Complainant, and have seen
him and his wife often together, and from every thing I could see between them
they appeared to live together very peaceable and loving, and I never heard any
thing to the contrary before they parted.
Ansr. to 3rd Cross. - He said he loved her, and was willing to live with her under any
circumstances, his wife was at my house, and he came over, as he said for the
purpose of seeing her, but she would not be seen by him, and shut herself up
in a room for the purpose of keeping out of his sight.
Ansr. to 4th Cross - I do not know, I know of none.
And further this deponent saith not.
By Frances Wooley next,
Testimony of Mariale Wooley
Ansr. to 1st Intry. - I am.
Ansr. to 2nd Inty. - I never did, but admitted that he was, or had been jealous of her
Ansr. to 3rd Inty. - I never did
Ansr. to 4th Inty.- I know of nothing else,
Cross Interregatories
Ansr. to 1st Cross. - I have answered this part of cross Intr. in my answer to 2nd
Ansr. to 2nd Cross. - I live near to complainant, I never was at his house, but
him and his wife have been to my house frequently, and they appeared to
be as friendly and loving as any other people,
Ansr. to 3rd Cross. - Some months after him and his wife had parted he came
over to my house, and asked me to see his wife for him, and to try and get
her to come back home and live with him again, he said he was sorry for
saying what he had said, before seeing things plainer, and that he had lost
one wife, but that did not hurt him as bad as parting with her and that his
son John lived with him, but if that would be any satisfaction to her he
would send him and his family away, and what property he should have
after giving John his share, he intended for him and her, accordingly.
I did go and see his wife, and made the statements to her, that I was