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The deposition of Frederick W Isbell of lawful age taken at the same time & place of the foregoing deposition Wm Jones and to be read in the same case. The deponant being first duly sworn deposeth & saith. Quetston by the Pltffs. Please state if you know the negro man Edmund bought by Wm J Isbell from Seth Halsey (the subject matter of this controversy) from the day of this purchase till his death. If so state whether or not the negro was sound at the time of the purchase - what labour he performed whilst in Wm J Isbells possession - whether or not he was kindly & humanely treated before he died and what you considered his value. Answer. I lived with my father at the time of the purchase, and knew the negro man Edmund from the time of the purchase, to the day of his death, the negro did not appear to be sound, at the time of the purchase, he went up the river to the plantation about nine miles by water in my fathers boat - the head man staid away longer than common, in consequence of Edmund doing no labour from the time the boat started untill its return. Edmund remained at my Fathers house untill his death - which was about four, or five months. Edmund done no labour from the time of the purchase until his death. The negro was well treated whilst in Fathers possession & well attended to during his sickness. I did not consider him worth one cent, and further this deponent saith not. Frederick W Isbell

Campbell County to wit. The foregoing depositions of Wm Jones and Fred W. Isbell was taken subscribed and sworn to before me a justice of the peace in & for said County at the time & place mentioned in the Caption. The defts Peters and Halsey were present during the whole time & stated they had no questions to ask the last witness. Given under my hand this 29th August 1835. James Bullock