[Testimony pages 4385+]
(Depositions of Robert Bell, taken at Henryetta, Oklahoma, July 10, 1935)
ROBERT BELL, of lawful age, being first duly sworn, testified as follows:
DIRECT EXAMINATION
BY MR. DICK JONES:
Q. State your name. A. Robert Bell.
Q. Did you know Jackson Barnett, the man who died in California? A. Yes, sir, I did.
Q. Where do you live? A. I live nine miles west of Henryetta.
Q. How old are you? A. About thirty-two.
Q. Do you remember the occasion when a white woman took Jackson Barnett away from his home, about 1920? A. I do.
Q. Where were you that night? A. I was at Jackson's home.
Q. Were you living with Jackson? A. I was.
Q. How long had you been living with him? A. I think ever since 1912.
Q. During that period that you lived with Jackson were you the boy that went around with him interpreting for him, and talked for him? A. I did.
Q. Where were you living during that period, from 1912, to 1920? A. In 1912 I was with Jackson Barnett.
Q. I mean, where were you and Jackson living? A. We were living seven miles west of town, and about six miles to the rock store, and a mile north and half mile east.
Q. Did you know Dave Barnett? A. I did.
Q. Did Dave Barnett ever visit Jackson? A. He did.
Q. Did you hear Jackson Barnett and Dave talk to each other? A. I did.
Q. Did you ever hear them refer as to whether they were related to each other? A. I believe I heard that Jackson was his brother.
Q. Did Jackson ever go to Dave's house and visit with him? A. He did.
Q. About how often would he go to visit with Dave? A. Some times once a month, and some times twice a week.
Q. What would he say when he would go to visit Dave? A. He would say: "Let's go talk with brother Dave."
Q. And you would go over there several times during the year? A. Yes, sir.
Q. Did you know any of the Fishers or Fishes? A. I did.
Q. Did he ever refer to them in any way as being kinfolks? A He did.
Q. What did he tell you with reference to them? A. He told me that John's mother --.
Q. When you say John do you mean Frazier Fish? A. I called him John Fish. He said that John Fish was his nephew.
Q. Was it John's mother that was his sister, or John's father his brother? A. John's mother, Eliza Fish.
Q. Did he ever tell you who his father was, that you recall? A. It seem like he did one time.
Q. What was Jackson's father's name? A. I believe it was Siah Barnett.
Q. During this period that you lived with Jackson, went around with him, interpreted for him, did he ever associate with any woman? A. No.
Q. That's all.
CROSS EXAMINATION.
BY MR. LYTLE:
Q. Bell, you lived with Jackson Barnett all the time that he lived out there by the rock store? A. Yes, sir.
Q. You were hired by Carl J. O'Hornett, guardian? A. No, sir, I was not hired by Carl O'Hornett.
Q. You got your pay from him? A. Well, I drew only one time pay from him.
Q. Who paid you the rest of the time? A. I didn't get no pay, I just stayed.
Q. You were out there when the white woman came after Jackson A. I was.
Q. Just what happened on that occasion?
BY MR. TAYLOR: We object, it is incompetent, irrelevant and immaterial.
A. What happened when the white woman came after Jackson?
MR. TAYLOR: I want the record to show at this time that on behalf of Anna Laura Barnett we object to all this character of evidence as incompetent, irrelevant and having no bearing upon any issue of this case, and particularly now that Jackson Barnett is dead.
Q. I want to know what happened when the white woman first came up where Jackson Barnett was? A. You mean the first time that she came out there? Q. Yes, sir. A. Her and Jackson had a talk out there by the well, on the east side of the house, between the barn and the house, and what they were talking about I never did understand.
Q. Did Jackson go off with her that time? A. Not that time.
Q. How long after that was it that she came back again? A. I judge it would be about two weeks.
Q When she came back there was a white man with her in a car was there? A. Yes, sir.
MR. TAYLOR: We object; incompetent, immaterial and irrelevant.
Q. Just what happened then? They wanted to get you to go along, didn't they? A. No, sir, not me.
Q. What happened that time? A. When she came back the last time they parked the car in front of the house, and I believe it was Mrs. Lowe came in first, and they asked for Jackson and some of the boys told them Jackson was in the house, and so he was sitting there bare footed, with his boots off, and some of the boys told him there was some one wanting to see him, and he went to the door bare headed and bare foot, and she took him off and carried him to the car and put him in the car and sent back after his boots.
Q. Did you see her put her arms around him? A. I did.
Q. Did she help him, shove him in the car?
MR. TAYLOR: We object, incompetent, irrelevant, and an effort on the part of counsel to put answers in the witness' mouth.
Q. Did you see any whisky on that occasion? A. No, sir, I did not.
Q. Anybody been drinking on that occasion? A. No, sir.
Q You say they didn't try to get you to go along? A No, sir.
Q Did they try to get the other colored boy to go along? A They did.
Q And they took Jackson in the car when, did they? A. Yes, sir.
Q. Jackson was in the car without any top shirt on? A. I believe he had on his top shirt.
Q. But he didn't have any hat, and didn't have any shoes? A. No, sir.
Q. Didn't have any stockings? A. No, sir.
Q. And the car went away? A. Yes, sir.
Q. And when did you next see Jackson? A. The next time I seen him after he went away was in Winfield, Kansas.
Q. Did you go up there to the trial in Kansas? A. I did.
Q. And you told your story up there? A. Yes, sir.
Q. And when they tried the case of United States vs. The Equitable Trust Company, in the Southern District of New York, they took your deposition at Okemah, didn't they? You testified over there? A. At Okemah? No, sir.
Q. Where did you testify? A. I testified in that case that time in Winfield, Kansas.
Q. And then you testified at another time, when the case of United States vs. Anna Laura Barnett was being had in California, when Mr. Selby took depositions, didn't you? A. No sir.
Q. Did you know who this woman was that came after Jackson, like you testified about? A. Mrs. Lowe.
Q Is she the one they call Anna Laura Lowe? A. Yes, sir.
Q You have seen her, you saw her at Winfield, Kansas, and you have seen her down here since, haven't you? A. Yes, sir.
Q Now, Bell, isn't it a fact that when you were living with Jackson up there and he would want you to go off with him he would say: "I want to go down to Dave's". Isn't that what he would say? A. He would say down to his brother Dave's.
Q. Jackson Barnett had a guardian all the time you were with him, didn't he? A. Yes, sir.
MR. TAYLOR: Objected to as incompetent, irrelevant and immaterial.
Q. And the court had found that he was crazy?
MR. TAYLOR: We object to that as being incompetent for the reason that the record is the best evidence and the further reason that it is not a fact that the court found he was crazy.
A. I hear several say he was crazy.
Q. People in the neighborhood called him "Crazy Jackson", didn't they? A. Yes, sir.
Q. You lived with him all the time that he lived up there north of the stone store? A. Yes, sir.
Q. During any part of that time did Jackson Barnett have any woman with him? A. Any woman living with him? Q. Yes, sir. A. No, sir.
Q. And during any part of that time did he live with any woman? A. No, sir.
Q. Did you ever know of Jackson Barnett at anytime, or any place, having a child? A. No, sir.
Q. Did you ever hear him speak of a child? A. No, sir.
Q. You stayed right there in the same yard with Jackson Barnett all the time, didn't you? A. Yes, sir.
Q. And whenever he went any place you went with him, to talk for him, practically all the time? A. Yes, sir.
Q. He could talk just a little bit of English but he didn't like to talk to whites, did he? A. No, only to some one that he knew.
Q. And then just a little bit of English. He knew, he could talk Creek much better? A. Yes, sir, he liked to talk Creek, Judge.
Q. Jackson was quite a hunter, wasn't he? A. Yes, sir.
Q He would take one arrow and get several squirrels with it? A. Yes, sir.
Q. That's all.
BY MR. HARROD:
Q. How old were you when you stayed out there? A. Ten.
Q. Who did his cooking while you were there? A. Well, there was one woman by the name of Mrs. Harris cooked for him.
Q. Mrs. Scott, do you remember her, Mrs. George Scott, commonly spoken of as Mrs. Scott; did any woman like that stay there? A. Not as I knows of.
Q. Was it a colored woman or Indian woman? A. Colored woman.
Q. Then there wasn't any Indian woman out there at all? A. Well, she had Indian in her, Mrs. Harris did.
Q. What kind of a looking woman was she? A. Indian looking woman.
Q. Large lady? A. Yes, sir.
Q. Where is she now? A. I don't know, sir.
Q. She was a fullblood, wasn't she? A. I don't know whether she was or not.
Q. And she was Jackson Barnett's sister, wasn't she? A. Not as I know.
Q. She would go to Henryetta with him and go back with him in the wagon, wouldn't she? A. At times, yes, sir.
Q. And the little boy would go with him? A. What little boy?
Q I am asking you. A. I mean what little boy?
Q. Wasn't there a boy that came with him, a small child? A. It was me.
Q. You are the boy that was there? A. Yes, sir.
Q And that was your home? A. No, sir.
Q. And you were then about ten years old? A. Yes, sir.
Q. How long did you stay out there, ten or twelve years? A. About ten years.
Q. And you were there when the white woman came and got him? A. Yes, sir.
Q. Do you have Indian blood in you? A. No, sir.
Q. You spoke a while ago that some of the boys called Jackson and told him there was a woman out there that wanted to see him? A. Yes, sir.
Q. Which one of the boys called him? A. I believe it was Anderson Griffin.
Q. Who is he? A. That is the boy that is dead now.
Q. How long has he been dead? A. I don't know how long he has been dead; about four or five years, I guess.
Q. You never did see that boy out there (pointing towards a man seated near Mr. Harrod)? Did you ever see him out there? A. No, sir.
Q. Bennie Scott Valentia?
The man indicated by Mr. Harrod as Bennie Scott Valentia,
seated near Mr. Harrod, arose and said; "My name is
Bennie Barnett Scott."
Q. You say you never saw him out there? A. I didn't see him out there.
Q. Isn't it true that his mother stayed there all the time? A. Who was his mother?
Q. I am asking you the question. A. I don't know who his mother was. If Mrs. Harris was his mother---.
Q. Who did you refer to a while ago when you said one of the boys told him to go out? A. I meant Anderson Griffin come and told at the house that there was some one out there looking for Jackson.
Q. And Anderson is now dead? A. Yes, sir.
Q. And Mrs. Harris, you have never heard of her? A. No, sir, not since she left.
Q. As a matter of fact you knew that woman was Jackson Barnett sister? A. No, sir, I didn't,
Q. And you know that this is her child, (pointing at man seated near him) don't you? A. No, sir, I do not.
Q. As a matter of fact you were not there, were you? A. Yes, sir, I was there.
Q You didn't live there ten or twelve years? A. Yes, sir, I was there when Mrs. Harris cooked there.
Q. Then he did have a woman there cooking for him? A. Oh, yes.
Q. He never did batch, did he? A. Yes, sir, he batched some.
Q. Who would do the cooking when he would be batching? A. I don't understand it.
Q. Would he do it, would you do it, or some other woman? A. Whenever he didn't have a cook out there I and him would mess up something.
Q. When did this woman die, that woman that stayed out there? A. When did she die?
Q. When did she die or disappear? A. I don't remember the time she left there.
Q. She had the appearance of a fullblood? A. Not to me, she didn't.
Q. And you mean to tell this court that you are the boy that came to town with him and that woman? A. Yes, sir.
Q. What other boy was out there, outside of you and Griffin? A. Well, there was several boys that came there all the time.
Q. At the time this trouble is supposed to have happened, when Jackson disappeared? A. At the time that he was kidnapped?
Q. Yes, sir. A. Well, there was a bunch of us there at the time he was kidnapped.
Q. Tell who they were. A. I couldn't name all who they were.
Q. You can't name any of them outside of the one that is dead? A. Sure, I can name them.
Q. Well, give them to us. A. Willie Griffin, Anderson Griffin, Lloyd Bell, he is dead now, that's my brother, he was there, and Johnny Guy and Shedrick Bruner.
Q. Where are those people now? A. They are different places.
Q. Over the country? A. Yes, sir.
Q. Do any live around close? A. No, sir, not around here.
Q. Have you mentioned all that was there? A. No, sir, not all.
Q. Give all that you can. A. Well, there was a lot there that night; I can't remember who all was there, but I know there was a house full.
Q. What time of night was it? A. It was between, I judge, seven and eight o'clock.
Q. This wasn't your mother that stayed there? A. No, sir.
Q. How come that you went over there and lived? A. Jackson Barnett came over after me to my mother's.
Q. Is your mother still living? A. Yes, sir.
Q. And do you recall when it was that Jackson came over and got you? A. It was in 1912, I believe, at the time he came and got me.
Q. Why did he come and get you? A. Because he knowed me a good while, and my mother.
Q Did he feel like he wanted some children there? A. Yes, sir.
Q. How do you know he did? A. He asked mother could I stay with him.
Q. That is how come you went over and stayed? A. Yes, sir.
Q. And you were there when the woman come and took him away? A Yes, sir.
Q. And you had been there ten years before that? A. I had been there since 1912.
Q And the only woman you ever saw there with him was this Indian looking woman there with him? A. No, that isn't the onliest woman that I have seen there.
Q. Tell me the different women you have seen. A. Well, I seen Hattie Vidreen.
Q. Where is she? A. She is back west of town.
Q. How long did she stay there? A. I guess about four or five months.
Q. Go ahead. Somebody else? A. I believe it was Adele Dixon cooked a while.
Q. And where is she now? A. She is dead.
Q Anybody else? A. Birdie Griffin.
Q Some relation of yours? A. No, sir.
Q. Some relation to this boy that stayed there? A. Willie's wife.
Q. And where is she now? A. She is dead.
Q. Anybody else? A. Not as far as I know.
Q. During the time you stayed there he had some four or five or six women there with him, cooking for him? A. Yes.
Q. How long had the woman been there that had been living with him at the time the white woman took him away? A. Which one of the women?
Q. Well, the one you refer to as Mrs. Harris. A. Mrs. Harris was the last woman cooked there before Mrs. Lowe carried him away.
Q. How long had she been there? A. Mrs. Harris, I don't remember how long she had been there.
Q. Was she there when you first went out there? A. No, sir.
Q Had all these different women stayed there while you were there? A. Yes, sir.
Q. Had any woman stayed there before you went there? A. I think Hattie Ida Johnson's sister, she was the first woman that I knew cooked for him.
Q. Where is she now? A. She is now dead.
Q How did this woman that was there when the white woman took him away compare with Jackson Barnett in weight? A. I believe Jackson was a larger man than she was a woman at that time.
Q. Do you mean she was stouter, or what? Which was stouter, Jackson or the woman? A. Jackson was at that time.
Q. Jackson looked considerably stouter than the woman? A. To me he did.
Q. Then the woman was a slim woman, was she? A. Yes, sir.
Q. Jackson would weigh more? A. Yes, sir.
Q. How, did they compare in height? A. The woman seemed to be taller than Jackson to me.
Q. And how did she compare with him in appearance as to Indian blood? A. Mrs. Lowe?
A. No, I am talking about this woman that stayed there with him. I am not talking about Mrs. Lowe.
MR. PHILLIPS: I don't know how long counsel that have put up money in this case will have to sit here and have Jackson Barnett compared with every colored woman that cooked for him, and I would like to invoke some sort of rule to stop it. There ought to be some rule invoked on the length of time in comparing Jackson Barnett to the size of some nigger woman cooked for him.
Q. I want to know about the woman that was there when the white woman come and got him. I am not talking about Mrs. Lowe.
MR. PHILLIPS: The reason is indefinite, and does not distinguish the woman he called Mrs. Harris.
Q. You don't know how long she had been there. Was she a larger woman? You understand now who I am talking about, don't you? A. You are speaking about Mrs. Harris. She was larger than Jackson.
Q. I am asking about the one you called Mrs. Harris. I want to know, now, how did she compare with Jackson Barnett in flesh? A. Well, she was larger then Jackson.
Q. More fleshy? A. Yes, sir.
Q. Weighed more? A. I believe so.
Q. Was she as tall a lady as Jackson? A. Yes, she was.
Q. And she was full Indian blood, wasn't she? A. No, sir.
Q. How much Indian blood do you think she had? A. Well, she didn't show much Indian, to me, but she talked good Creek, alright.
Q. Would she show more Freedman blood than Indian blood? A. Yes, sir.
Q. How much do you think she would weigh? A. Oh, I don't know, about maybe 195, or 180, something like that.
Q. Do you think she was taller than Jackson Barnett? A. I don't think she was taller; she might have been the same size in height.
Q. That's all.
BY MR. MAXEY:
Q. Robert, you were at the house with Jackson when Mrs. Lowe came there both times, weren't you? A. Yes, sir.
Q. Now, the first time she came you say that she had a talk with Jackson out by the well? A. Yes, sir.
Q. Did you hear any of that conversation? A. No, sir.
Q. How long did she stay there the first time? A. I guess she stayed maybe about an hour, I guess.
Q. Did they stay out there by the well all the time or did they come in the house? A. Stayed out by the well.
Q. How was Jackson dressed that day? A. Well, just in his every day clothes.
Q. Did he have his shoes on? A. Yes, sir.
Q. Have a hat on? A. Yes, sir.
Q. How did she come out there the first day, in an automobile, or how? A. She came in an automobile.
Q. Somebody drive her car or was she driving? A A man driving it.
Q. You say it was two weeks until she came back again? A. I judge it was about that time.
Q. About that time how did she come? A. She came in a car.
Q. Automobile? A. Yes, sir.
Q. Was the same man driving the car that drove it the first time, or do you know? A. No, sir, they said it was her lawyer from Tulsa.
Q. Some lawyer from Tulsa? A. Yes, sir.
Q. When they get there Jackson was inside of the house? A. Yes, sir.
Q. Who was in there with him? A. Well, a bunch of the boys.
Q. Were you there with him? A. Yes, sir, I was.
Q And Anna Laura Lowe came to the door? A. She did, yes, sir.
Q She had a conversation there with Jackson? A. Not in the door, she didn't.
Q. Where did they go from the door? A. They went to the car.
Q. Did you follow out to the car? A. No, sir, I didn't.
Q. You didn't hear any of the conversation? A. No, sir.
Q. Robert, didn't you hear any of the conversation between Mrs. Lowe and Jackson at all? A. During that time?
Q. Or any time. Did you hear them talk any, Robert? A. I heard them talking, but a never did understand anything.
Q. You understand English, don't you? A. Yes, sir.
Q. You heard them talking. Did you hear Anna Laura Lowe tell Jackson how much she loved him? A. No, sir, I didn't hear that.
Q. Do you know whether Jackson had ever known Anna Laura Lowe before the first time she come there? A. No, sir.
Q. Did he know her before then? A. No, sir.
Q. After Anna Laura Lowe came there the first time and went away what did Jackson tell you about her?
MR. TAYLOR: Objected to as incompetent, irrelevant, and hearsay.
Q. Go on. What did he tell you? After she came the first time and went away, what did he tell yon? A. He told me that was a lady come there to see him.
Q. Did he say what the lady wanted to see him about? A. No, sir, he didn't tell me.
Q. Didn't he tell you the lady come there and wanted to marry him? A. No, sir, He didn't tell me that.
Q. Didn't he say anything about this lady at all except that she just come to see him? Is that all? A. He said she came out to carry him a cary ride.
Q. And did he say anything about why he didn't go car riding? A. He didn't go the first time, did he? A. No, sir, the first time he didn't go.
Q. Did he say anything about why he didn't go? A. No, sir.
Q. Now, we just want you to tell the truth about it, what you know about it. You ought to tell the court. Do you mean for the court to understand that you did not hear any conversation between Anna Laura Lowe and Jackson at all? A. The first time they came out there?
Q. Any time. A. Well, I believe I did hear Jackson tell me that they went down to Holdenville and she wanted to marry him and his guardian wouldn't accept for them to issue no license.
Q. He told you that? A. Yes, sir.
Q. Did he tell you whether he wanted to marry? A. Yes, sir, he said that he didn't want her.
Q. Did he tell you whether or not she wanted him? A. He didn't say about that.
Q. But he said he didn't want her? A. Yes, sir.
Q. The next time she came back there and they went away in the car did you know what she had come for? A. I had an idea in my own mind what she came for.
Q. You thought you knew what she came after? A. Yes, sir.
Q. But Jackson hadn't told you in the meantime anything except what you told the court here? A. That is all.
Q. Did you see Anna Laura Lowe put her arms around Jackson? A. Yes, sir.
Q. Did she kiss him? A. Yes, sir.
Q. How many times did she kiss him? A. I saw her kiss him but one time.
Q. Did you hear Anna Laura Lowe tell Jackson how pretty he was, and how much she loved him? A. No, sir.
Q. And didn't she say to him: "Jackson, I just can't live without you."? A. I believe she did tell him that.
Q. What did Jackson say when she told him that? A. He just grinned.
Q You say that Anna Laura Lowe took him out to the car? A. Yes, sir.
Q. Did she put him in the car? A. She hoped (helped) put him in.
Q. Did anybody else help him? A. I believe the man on the outside did.
Q Did Jackson say anything to you as he went away? A. No, sir.
Q. Didn't say anything at all? A. No, sir.
Q. Did Anna Laura Lowe have her arm around him as he went to the car? A. As he stepped off the porch she did.
Q. And she kept her arms around him as long as you saw him? A. Until they got to the car.
Q. Did she appear to you to exhibit affection towards Jackson? A. No, sir.
Q. You know what that means; you know when a girl is in love with a man you can kind of tell it.
Q Did Anna Laura Lowe look like she was in love with Jackson? A. She made out like she was.
Q. Did Jackson look like he was in love with Anna Laura Lowe? A. No, sir.
Q He didn't seem to take much interest in her? A. No, sir.
BY MR. TAYLOR:
Q. You are now thirty-two years old? A. Yes, sir.
Q. Where do you live? A. Out west of town.
Q. Are you married? A. No, sir.
Q Who do you live with? A. I live with my brother.
Q. How far west of town? A. Nine miles.
Q Do you live at your brother's now? A. Yes, sir.
Q. Is your mother dead? A. No, sir, she is living.
Q. You don't live with your mother? A. No, sir.
Q. When you first went to live at Jacksons' place you were about ten years old? A. Yes, sir.
Q. And that was about 1912? A. Yes, sir.
Q. You lived there up to about 1920? A. Yes, sir.
Q. Now, you say that Jackson came to your mother's house and got you? A. Yes, sir.
Q. Had he known your mother a long time? A. Yes, sir.
Q. He just took you there to give you a home? A. Yes, sir.
Q And let you live there? A. That is right.
Q. Did you do some chores or work around the place? A. Yes, sir.
Q. How large a house was that that Jackson lived in there? A. It was a four-room house, square out.
Q. Four-room frame house? A. Yes, sir.
Q. Did you live in the house with Jackson? A. Yes, sir.
Q. Who else lived in the same house with Jackson? Who else was living in the same house with Jackson beside you? A. The cook, Mrs. Harris.
Q. This Mrs. Harris was a negro woman? A. Yes, sir.
Q. She looked like a negro to you, didn't she? A. Yes, sir.
Q. She didn't look to have very much, if any, Indian blood? A. No, sir.
Q. Did Mrs. Harris - is her name Harris or Harrison? A. Harris, is what I learned.
Q. Now, did she cook for Jackson most of the time while you lived there? A. Well, I don't know how long she cooked there, but she cooked there, I couldn't say how long. It was one or two years, I disremember now.
Q. Now, you say she was the last woman that you knew of that cooked for Jackson? A. Yes, sir.
Q. What was the rest of her name? A. Mrs. Harris is all I knew.
Q. Did she have a husband? A. Not as I know of.
Q. Did she have any first name? A. Not as I known of.
Q. Is she still living? A. Not as I knows of.
Q. You don't think she is? A. I heard some one say she is dead.
Q. Who else lived there at that house that did any work, besides you and Mrs. Harris, for Jackson? A Well, Willie Griffin and his wife.
Q. Did they stay there when Mrs. Harris was there? A. No, sir.
Q. That was before, was it? A. Yes, sir.
Q. This Willie Griffin and his wife were negroes, too? A. Yes, sir.
Q. All the women that you know of, that you spoke of that worked there, were colored women? A. Yes, sir.
Q. You never knew of any Indian woman or white woman working there? A. No, sir.
Q. Jackson could talk English, couldn't he? A. Yes, sir.
Q. He talked English pretty well, didn't he? A. Yes sir,
Q. He didn't need to have an interpreter go to town with him to buy things did he? A. No, sir.
Q. Did he ever go to town by himself? A. Yes, sir.
Q. Did he ever go to town and buy anything, buy groceries and clothes? A. Yes, sir.
Q. So he didn't have to have anybody go along with him and look after him, and talk for him, when he was doing his shopping? A. No, sir, not altogether.
Q. Of course he was a Creek Indian, wasn't he? A. Yes, sir.
Q. This first time that you say Mrs. Barnett came there to see Jackson, they talked out there in the lot by the barn, didn't they? A. Out there by the well.
Q. Was that out somewhere near the barn? A. Yes, sir, between the barn and the house.
Q. Was Jackson out there when Mrs. Barnett came? A. No, sir, we was down in the woods when she came.
Q. Where they met and held this conversation was by the well? A. Yes, sir.
Q. You say they talked there for about a minute? A. Yes, sir.
Q. Where were you while they were talking? A. I was around the house drawing some water.
Q. You were just working around the house? A. Yes, sir.
Q. You didn't hear their conversation, and wasn't any place where you could hear it? A. No, sir.
Q. And you don't know, or pretend to know, what they were talking about? A. No, sir.
Q. Was there a water trough by the well or the barn? A. Yes, sir, there was.
Q. Was there a kind of trough between two trees? A. Yes, sir.
Q. Were they near that when they were talking? A. Yes, sir, right at that trough.
Q. Do you remember of her being there more than two times? You have mentioned two times. A. She was there more than two times. I believe she was there three times altogether.
Q. This time that you say Jackson told you they went to Holdenville, that was the time between, wasn't it? A. That was the second trip that she made.
Q. That was between the first trip and the time you have testified about him going in the car without his coat and hat? A. Yes, sir.
Q. And he told you that on this second trip they went to Holdenville and tried to get a marriage license? A. Yes, sir.
Q. When she came this last time you spoke of there was a man with her, driving the car? A. Yes, sir.
Q. How do you know he was a lawyer from Tulsa? A. Well, Willie Griffin told me .
Q. You don't know whether he was a lawyer or not? A. No, sir.
Q. Anybody else with her besides this man? Just the two of them in the car, wasn't there? A. It seems to me like there was three of them in the ear, but I can't tell whether it was another man or woman.
Q. At might have been a woman? A. It might have been a woman.
Q. When they came there Jackson was in the house, was he? A. The last time?
Q. Yes. A. Yes, sir.
Q. And you were in the house?
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