(c) 2001 Barb Wise (wisebarb@home.com) EXHIBIT "A" DEPOSITION TAKEN BEFORE A FIELD EXAMINER OF THE VETERANS AMDINISTRATION DATE: 18 MARCH 1954 DEPOSED BY: A. W. HENDRICKS PERSON DEPOSED: JAMES F. DAVIS James F. DAVIS: I am white, male, married, age 65, occupation, none, reside at Paoli, Indiana, on Horton Street. I am a claimant in this case for benefits as the stepfather of Woodrow HOLLEN. Q: When did you begin to live with Inice HOLLEN? A: On September 29, 1929 Q: Where did you live when you first set up housekeeping? A: In Sam HOLLAND's house in Greenfield Township, Orange County. He let us live there without paying him rent. I did work for him, but he always paid me for that. We lived there about a year. Q: Did Inice's children live with you? Name them, if so. A: Ethel, Woodrow, Pauline, Margaret, Lula, Clovie. Another of her children, Fern, who had been living with her grandmother (Inice's mother) came to live with us 5 or 6 months later. She sorta came in and out, going back and forth between the two homes, depending on who she was mad at. Q: How long did they live with you? A: Ethel was about 12; she stayed till she was married at age 18. Pauline was about 6; she stayed till she was married at 18. Margaret was 4 or 5 and stayed till she was married at about 17. Lula was close to 4 and stayed till she was married at about 19. Clovie was between Margaret and Pauline and he stayed till he went to WWII, then he came back. He was there until I had to leave. He beat me up, and I left the next morning. Woodrow was about 14. A the time we were married he was staying with Ad APPLE for his board. Ad APPLE was Elmer APPLE's dad. After a month or more, Woodrow came home, complaining that he was supposed to get a shoat for his work and the APPLES wouldn't give it to him. I went over with him; we went to Ad APPLE's and got the shoat and raised some pigs from her. Q: Did Woodrow ever attend school after you and his mother were married? A: No. She had gotten him out of school to put him out to work and he never went back. I blame Inice for that. He got no education at all. Q: After he came home, how long did he stay home? A: He never ever again worked for Ad APPLES. He stayed all winter that year (1929 to 1930) and I supported him. Sometimes he would go to the woods with me and help me score railroad ties. He didn't do this too much, just when he wanted to. Q: How long did he stay? A: Well, after that winter, he went to work for Clyde APPLE, now dead, about 4 miles from where we lived. He went about the time to put out a crop in the spring and he stayed until cold weather, October or November 1930; it was hog killing time. He got no pay but they gave him a hog and I helped him carry that dressed hog all the way home. He stayed at home all that winter and in the spring of 1931, he went to work for Sam HOLLAND, helped him put a crop out and stayed until a couple months later. I don't know what Sam paid him; I never spent any of the money - I never even saw it. When he was working and staying at these places, he always came home on Saturdays and Sundays and sometimes overnight during the week. He would go to his uncle Sam HOLLAND's every spring form then on and work anywhere from a few days to a month or so - Sam just lived about 2 miles from me over the hill, but he just jobbed around the rest of the year, maybe a day with Clarence PEARSON, a couple of days with someone else. Nobody had any money around there to keep a man very long at a time and times were bad. When night came, though, he was home and lots of the time loafed at home in the daytime. He just thought of my home as his home and I always let him stay there. Q: Did he pay you board or bring anything in? A: No sir, he never brought in anything except that hog I was telling you about. Q: Who supplied his food when he was home? A: I did. I cut railroad ties for $0.50 each after paying $0.25 for the wood. I sold a many a one for $0.50. Later, they brought a dollar. I would make about six ties a day and after about 10 days I accumulated 60 ties, a truckload, I would hire somebody with a truck, once I got Lawrence PEARSON, Clarence's brother, other times other people, to haul the ties up to Mitchell, Indiana for $3.00 to $5.00 - I don't remember if it was a nickel or dime a tie - anyway I would wind up with only a few dollars for an awful lot of work. Other times I cut firewood for $0.50 a cord. I dug roots for herbs and made a very little. Q: Where did you buy your groceries? A: At Ollie WALTON's at Fargo - that place is gone now - and at LAND's grocery store at Ethel, Indiana. I had to walk to get to these places. It was about a mile to Fargo, and 2.5 miles to LAND's. I packed all the groceries home on my back. Q: Did Woodrow go to the store with you? A: Yes, and one time in Land's store I saw him swipe a can of tobacco and I corrected him for it. Q: Did you generally have to correct him? A: I never did switch him or anything like that. Oh, I might have told him what he should or shouldn't do but we always got along fine. He was a good boy. Never had any trouble with him. I had a mean stepmother when I was a boy and it was on my mind and that was why I was trying to be good to those kids. I treated those kids just as if they were mine - just as good as I could treat them. Q: How did Woodrow treat you? A: He treated me all right, like I said. Q: Did he pay any attention to any advice you gave him? A: Yes, he listened to me pretty well. Right before he went into the Army he asked me what he should learn there. I suggested engineers. I think that's what he took. Q: Who owned the house you lived in back behind George NEWKIRK's? A: It belonged to Inice's mother till she died somewhere in the early 1930's. Inice inherited 1/5 share and I sold a cow for $40 I had saved and borrowed $25 from Warren MELTON, now dead, to make up $105 to pay the other 4 heirs off. The deed was then made out to Inice, but I considered I had bought most of it. Q: Whose furniture did you use? A: at first we used Inice's junk. Then I bought a table, davenport, stove, chairs, rug, mattresses, etc. Q: Did you ever give Woodrow any spending money? A: You know I couldn't have given him too much, but I did give him a little once in awhile and I bought him some tobacco. Q: Who is Wayne SCOTT: A: That is Inice's son in law; the husband of her daughter Mae. She and he were married before I married Inice. I never raised her, but back in WPA times they came with their two kids and stayed all winter with us. Q: Did Woodrow stay with them at any time? A: Yes, he stayed with them occasionally for a week or so at a time. Wayne had nothing - was hard up - and couldn't afford to keep him. Woodrow was just visiting. Q: Did he stay all winter in 1931, 1933, and 1938? A: No, definitely not. Q: When did you and Inice separate? A: October, 1945, I think. Q: How much of the time was Woodrow in your home as a member of your family from the time he was 14 years old until he was 21? A: I would say that most of the time - better than half the time and maybe even more. Q: Did he ever call you "Dad"? A: No, he usually called me "Jim". He was pretty big when I married his mother. I usually called him "Son" or "Woodrow." Q: Was he ever in Illinois working for 3 years or so about the time he was 21 years old, 1935-1938? A: He went to Illinois about that time but didn't stay even one summer. They drove a car into a freight train got afraid they were going to get into trouble and came back home. He and Wesley GOFORTH did this. Maybe they were out there 2 or 3 months. Q: Where did he live from then till he went into the Army? A: He made his real home with me. He would be in and out like I said - but he never paid me a dollar in his life for board and he lived with us most of that time too. Q: I have no further questions. Do you have anything to add? A: No, except that after I drew two checks for insurance from the VA, Inice, Lula and Clovie came up to the chair factory last fall where I was working and threatened to drag me out of there and take me to Lawyer Tucker's office and sign what they called a "dowry" or something to sign away my rights to the insurance. They came right into the factory and the foreman made them get out. They threatened to come back at noon, so the foreman had the town marshall wait all noon but they never came back. I had Justice of the Peace Leslie TROUP put them under a $1,000 peace bond. I haven't been threatened since. Clovie is the one who beat me up that time before. I certify that I have had the foregoing read to me and my statements are true, to the best of my knowledge and belief. /signature of James F. DAVIS/ Subscribed and sworn to before me this 18 day of March 1954; and I hereby certify that the foregoing statement was read to the affiant before signing. /signature of A.W. HENDRICKS/ Field Examiner (c) 2001 Barb Wise (wisebarb@home.com)