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DEPOSITION OF JAMES JEFFREY

STATE OF WEST VIRGINIA

Vs.

Edgar Combs

STATE OF WEST VIRGINIA, KANAWHA COUNTY, as:

James Jeffrey, Who, being first duly sworn by me says that he now lives at Jeffrey, Boone County, West Virginia, and has lived in that section of the country all of his life; that he has been connected with the Prohibition Department of the State as a Prohibition Officer, and at the present time is a Coal Miner by occupation; that he is familiar with what is known as the Mine Guard System in Logan County under which large numbers of Deputy Sheriffs are employed and paid by the Coal Companies of that County; that the principal purpose of employing such Deputy Sheriffs is to prevent the Coal Miners from joining the United Mine Workers of America; that he knows the general reputation of the said deputy Sheriffs as to their attitudes toward the members of said Union; that the said Deputies have a long record for assaults upon members of the United Mine Workers that there is a feeling of deep hostility and enmity between the said Deputies and the members of said Union; that practically the whole of Logan County excepting only the small position lying along Coal River is non-union and this is due wholy to the war made upon the said Union by the deputy sheriffs; that it is dangerous for any member of the said union to remain in said County, by reason of the said Deputies; that Affiant knows that the members of said union are afraid to go to Logan Court House, as a witness and there testify fully and freely in any matter that might arise the hostility of the said deputies or the company by which they are employed and the conduct of the said deputies toward the employees of the said Union primarily caused the Armed March of the miners in 1921; that by reason of the above facts this affiant knows that it would be impossible for the defendant to get a fair and impartial trial in the said County of Logan.

Taken, sworn and subscribed by me on the 29th day of September 1923.

Sallie Starr Chambers

Notary Public, Kanawha County, West Virginia