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M. Forney. Because it is leading - vague, too general and
indefinite - Subject to the foregoing exceptions the following are
propounded to said witnesses as
Cross Interrogatories
1st Cross. To both the witnesses - Do you or either of you know
that Richard Hunley, in his lifetime, bought and paid for the
lands, which he and his son Ransom cultivated together? If
you or either of you do not Know this of your own knowledge
please state if you ever heard Ransom. G Hurley, in his lifetime
say any thing in relation thereto? If yea - state what he said on
that subject and all that you may have ever heard him say
going to show that his Father, Richard Hunley, or that his Farthers
means paid for said lands, or any portion thereof? -
2nd Cross - Did Richard Hunley own any slaves while
he and his son Ransom farmed together? - If yea - how far Where did they stay, and work? If together
apart were they? How far apart were the residences of each of
their white families? Were they not near enough together for the
little negroes of each, and the white children of Random G. to
play & mingle together?
please state if both did not supervise and control to some extent
their farming operations? =
To both the witnesses
3rd Cross - Did each one have his own negro Houses
while they thus lived and planted together? If yea - how far
apart were they - How far apart were the residences of each of
their white families? were they not near enough together for
the little negroes of each, and the white children of Ransom G.
to play & mingle together
To both the witnesses
4th Cross - who was the most active agent in the
management of said joint plantation and in paying the
expenses thereof: Richard or Ransom G. Hunley? - -
To Daniel M Forney Seperately
1st Cross - If in your answer to 1st and 2nd Interrogatories
in chief. you give any declarations of Richard Hunley, in relation
fo any gift he pleased to give his precise language as near as
you can recollect it? - State also the time or times, and place
or places, when said declarations were made, and who
was present, and what led to the conversaton or conversation,
and if the negros or any One or more of them were
present or pointed at or referred to, during such conversation
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