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The deposition of Anderson Hatfield taken on the 20th day of August 1869 at the house of Greenville Taylor near the mouth of Peter Creek in Pike County Ky. To be read as evidence in behalf of the defendant (Jacob Cline) in the suit of M.C.W. Sowards, Lewis Sowards, and Thos. J. Sowards, plantiff, against Jacob Cline, defendant, pending in Pike Circuit Court.

The deponent Anderson Hatfield of lawful age and being by me first sworn deposeth and says:

Question: State your age residence and occupation.

Ans. I am 30 years old my residence in Logan Co., West Virginia. My occupation is farmer.

Question by same: Are you acquainted with the defendant Jacob Cline?

Ans. Yes sir.

Question by : Do you or not know how deft Cline happened to go with the squad to take Sowards goods at Peach Orchard Ky.?

Ans. He had come back from the Federal army and give up to the rebels and they were talking around that if he did not join the rebels that they would kill him and he joined the rebels under these circumstances and went to Peach Orchard. He made several excuses to get out of going but none of them were availing and he had to go.

Question by same. Did he go willingly or unwillingly?

Ans. He went unwillingly.

Question by same. State if you know where defendant Cline was at the time Sowards goods were taken.

Ans. He was on the point this side of the store of Sowards. Something near half a mile distant. He was placed there as a _____.

Question by same. Do you or not know who got the goods after they were taken from Sowards?

Ans. I do not know who all did get goods.

Question by same. Did Jacob Cline get any of the goods taken?

Ans. If he did I do not know it. He did not take any from the store. I was with him and come out with him from there and if he had any goods I did not see them. If he had any goods I think I would have certainly seen them.

Question by same. Would he not have endangered his life by refusing to go, taking everything into consideration that is all the surrounding circumstances of the case?

Ans. He was threatened that if he did not join the company and go he would be killed and this was by men who did kill sometimes.

Question by same. State as near as you can the amount of goods taken from Sowards also how much they had in store at the time of the robbery.

Ans. I don’t think there was exceeding $500.00 worth of goods in Sowards store at the time and I think $300.00 would be the greatest possible amount of the goods taken. And further this deponent saith not.

Attest. Abe C. Ferrell, Ex                                           Anderson (his mark) Hatfield

1 days attendance 26 miles $2.04

State of Kentucky

Pike County

I Abe C. Ferrell Examiner for County and state aforesaid do certify that the foregoing deposition of Anderson Hatfield was taken before me and was read to and subscribed by him in my presence at the time and place and in the action mentioned in the caption the said Anderson Hatfield having been by me first sworn that the evidence he should give in the action should be the truth, the whole truth, and nothing but the truth and his statement reduced to writing by me in his presence the defendant Jacob Cline being above present at the examination. Given under my hand this 20th day of August 1869.

Abe C. Ferrell, Examiner

Pike Co.

Examiners Fee 1 Deposition $1.00

Entering 1 witness 25 80 miles $4.00 $4.25



1 witness claim                                    $7.29


[On the reverse side of the last paper:]

Jacob Cline & C

Ans: Deposition of Anderson Hatfield

M.C.W. Sowards & C

Filed Aug 24th 1869.

Abe C. Ferrell, D. for R.M. Ferrell, CPC