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The deposition of Plotimy L Watkins of lawful age taken at Goochland Court on Monday the 16th day of October agreeably to notice to be read as evidence in a suit now in the circuit supr. court of law and chancery for Goochland County in which Thomas Brooks Jr is plaintiff and [Urichack?] Hicks admr. of Fielding Brooks decd. is defendant. This deponent being first duly sworn according to law answerith and saith Question by the pltff. How long have you known the pltff in this cause? Answer. Ever since the year 1827. Question by same. How long were you engaged in business at Goochland CH? Answer. about 5 or 6 years Question by same. Was old Mr. Brooks in the habit of dealing with you during the time Answer. Yes, from the year 1827. until 1830 when his accounts were finally closed. Question by same. Did Mr. Brooks usually settle his accounts annually. Answer. He paid me some money every year Question by same. Did you generally receive those payments from old Mr. Brooks himself Answer. All the payments were made by old Mr. Brooks except the last. Question by the same. From whom did you receive the last payment which was made to you? Answer. From his son James Brooks