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(16) Office of William H. Stewart, Portsmouth, Va. 5th, day of December, 1900. Present Wm. M. Reid, attorney for plaintiff, Edwards & Hepper for the defendant. Witness Samuel Fisher being duly sworn deposes as follows: 1st. Q. What is your name, age, occupation and residence? A. Samuel Fisher, age near fifty years, occupation undertaker, live at #312 Effingham street, Portsmouth, Va. 2d. Q. Do you know George Joiner and Cornelia Eley the parties to this suit, if so how long have you known them and where have you know them? A. My first knowing of them was on North street in the lane known as "Hunter's Lane" I knew him from boyhood we were boys together and that is where I first got acquainted with him. I first knew Mrs. Eley about the year 1870. 3d. Q. Did you know the father of George Joiner the plaintiff, if so what was his name and how do you know that he was the plaintiff's father? A. Yes i knew his father's name it was George Joiner, He owned him as his son and he served for his father as I did for my father, his father being a lighterman and my father was a drayman, and I knew by his father's acknowledgements. 4th. Q. State whether or not the plaintiff lived in the house with his father, George Joiner deceased and at what places did he live with him? A. The first place he lived with him was "Hunter's Lane" in the first double house. The second place of my knowing he lived with him was "Lincolnsville" on Stonewall street as some or rather one of the first settlers out there. 5th. Q. Was the house in which he lived the same which George Joiner deceased owned at the time of his death? A. Yes 6th. Q. What was the reputation in the community and among the people where the plaintiff and his reputed father lived