(c) 2001 Barb Wise (wisebarb@home.com)

EXHIBIT "D"

DEPOSITION TAKEN BEFORE A FIELD EXAMINER OF THE VETERANS AMDINISTRATION

DATE: 16 MARCH 1954

DEPOSED BY:  A. W. HENDRICKS

PERSON DEPOSED:  BILLY DAVIS	

Billy DAVIS:  I am white, male, age 26, married, reside at Ethel, Indiana, with my wife and two children in my mother's home.  She is Blanche LAND, who runs a small grocery there.  My occupation is machine operator for Indiana State Highway Commission.  I am not related to James DAVIS or Inice Belle HOLLEN, nor do I have any interest in this case.

Q:  Were you acquainted with Woodrow HOLLEN?  How long did you know him?
A:  Yes, I knew him when I was a very small boy.  He used to come in my parents grocery with his stepfather, Jim DAVIS, or sometimes with his brother or sisters.

Q:  Did Woodrow work for farmers around here, particularly between 1929 and 1936?
A:  That goes pretty far back for me, but ever since I first saw him he used to come into the store or be around here and he might have worked for some farmers during planting seasons or harvest seasons, but I don't remember him being gone very long, if at all.  He came in here pretty regular.

Q:  Can you describe how Jim DAVIS and Woodrow treated each other when you saw them together?
A:  They seemed to get along O.K.  Sometimes you would see them in the woods together, digging sassafras roots and such, to sell, and they always seemed friendly to each other.

Q:  Who supported Woodrow, that is furnished his food, shelter, and clothing, if you know?
A:  Why I think Jim DAVIS did, the best he could.  The depression was on and they were very poor.  Sometimes the township trustee helped out.  I know Jim DAVIS used to carry a lot of groceries on his back away from here.

Q:  I have no further questions.  Do you have anything to add?
A:  Yes, I do.  Woodrow was a good boy and Jim DAVIS was good to him.  He saw that all those kids attended church, and he might have been a little strict, I don't know, but if he was, he was doing it for their own good, in my opinion.

I certify that I have read the foregoing and my statements are true, to the best of my knowledge and belief.

					/signature of Billy Davis/

Subscribed and sworn to before me this 16 day of March 1954; and I hereby certify that the foregoing statement was read by affiant before signing.

					/signature of A. W. Hendricks/
					Field Examiner

(c) 2001 Barb Wise (wisebarb@home.com)