(c) 2001 Barb Wise (wisebarb@home.com) EXHIBIT "B" DEPOSITION TAKEN BEFORE A FIELD EXAMINER OF THE VETERANS AMDINISTRATION DATE: 18 MARCH 1954 DEPOSED BY: A. W. HENDRICKS PERSON DEPOSED: INICE BELLE (HOLLAND) HOLLEN Inice Belle (HOLLAND) Hollen: I am white, female, divorced, age 60, reside at R. R. #1, Paoli, Ind., occupation, keep house for myself and son, Charles Samuel Davis. I am the mother of the veteran in this case. Q: Please state when you married James Davis, and the places you lived and the members of your household. A: I married him at Paoli on September 28, 1929. We moved to a house on the farm of my brother, Sam HOLLAND, about 2 miles from Ethel, Ind. We paid no rent for this place. The children that moved in with me were Ethel, age 13; Pauline, age 8; Jack (or Clovie), age 11; Margie, age 6; Lula, age 4; I had 3 other children who didn't live with me: Fern ASH, who was married to Charles ASH on June 1, 1932 (she lived at the home of Charles Ash and his first wife as a housemaid at the time James Davis and I were married); Mae L. (HOLLEN) SCOTT born August 16, 1913, who was previously married to Wayne Scott; and Woodrow, the veteran. Q: Where was Woodrow? A: He was working for and living in the home of Clyde APPLE, now deceased, about 4 miles from our home. Q: How long did he stay there? A: A couple of years. Q: You mean he worked there year around? A: He was home only on Saturdays and Sundays. Q: Do you recall his coming home and complaining that the APPLES wouldn't give him a shoat they had promised him? A: Yes. He wanted me to go with him to get it, but I had Jim DAVIS go over with him. They got it and brought it home to our house on the HOLLAND Place. Q: Did Woodrow go back there and work for them again after they treated him like that? A: No, he did go to work for Ad APPLE, Clyde's nephew. Q: When was this? A: Right after he brought the shoat home. Q: There wasn't any interval at all when he stayed home with you? A: No, he went to work for Ad APPLE's right away and stayed there. I want to say all this over again: When Jim and I were married, Woodrow was working for and living with Clyde APPLE. He stayed there that winter. I don't recall when he worked for Clyde's dad, Harrison APPLE, but he did, I don't know how long, but he worked there some. Then he worked for Ad ADAM some but I don't know how long. It might have been 2 years I don't know. Q: Which of the APPLES gave him the shoat? A: It seems to me that Ad APPLE gave him that. Q: Who gave him the one that was butchered? A: That was Clyde APPLE. Q: Which one did he get first? The shoat or the butchered hog? A: The butchered hog. Q: Where after he left the APPLES did he work? A: He worked for his uncle Sam HOLLAND - helped him put out a crop. When apple picking time came, he went up to my daughter's, Mae SCOTT's to help pick apples. He lived at Mae's in Paoli while he picked apples, beginning in May and winding up in November. Q: But he didn't come home? A: No - I was afraid he and Jim would not get along because Jim being jealous of me. Woodrow might have said something about Jim being jealous of me and caused trouble. He didn't come home every week end, sometimes it would be a month other time it would be six weeks before he came home. When he came, he didn't stay very long at a time. If he came on Sunday he would go right back with Mae when they went back. He was at their place when he joined the Army. Q: Did he give that address? If not, why? A: No, he gave my address. I guess he thought he was helping me. Q: Did he own a car before he entered service? A: Yes. Q: What address was shown on his license and title? A: He gave my address. Q: Did he vote before he was in service? A: No. The first time he voted he was in service, I think. Q: Did Woodrow ever work for Clarence PEARSON? A: No, my other boy, Clovie, did, but Woodrow didn't. Q: Did Jim Davis support you and the other children? A: He did part of the time and part of the time he didn't. Q: Where did you buy your groceries? A: First one place, then the other. We had no car and had to get them at whatever place we were closest to. Q: How did you get them home without a car? A: Davis and the girls or sometimes Clovie when and got them. Q: Isn't it a fact that you bought groceries at Fargo and at Ethel, Ind.? A: Yes. We bought them at both places. Q: Isn't it a fact that Davis used to carry the groceries home on his back in a sack? A: Yes, he did that lots of times before we got a horse. Q: Isn't it a fact that Woodrow and Clovie used to go to a neighbors and play games? A: Yes, they used to go over to neighbors and play Rook and other card games with their boys and girls. Q: When did you move out of the HOLLAND house? A: About a year after we moved in there. We moved in a house that belonged to me and my mother. Q: Isn't it a fact that when your mother died, you bought out the other heirs? A: Yes. We gave them each $25.00. There were four of them. Q: Where did the money come from? A: I sold a cow for $150.00 for her. She was a black jersey. Q: When did you mother die? A: October 30, 1937. Her name was Mary A. HOLLAND. Q: It has been alleged that the cow was sold for $40.00 and the rest of the money was made up from other sources. Do you want to comment? A: That was a heifer of the Jersey's. I paid the money for the home from the $150.00. Q: It has been alleged that Woodrow was with you more than half the time from the time he was 14 till he was 21. Do you care to comment? A: I don't know, but I don't believe it was half the time. I aint going to say for sure, but I don't think it was. Q: Would you say he was there a third of the time during that period? A: That would come closer to it. Q: Did Woodrow ever work over in Illinois from 1935 - 1938? A: Yes. Q: Who did he work for there? What city was he near? A: I don't know who he worked for. I believe it was near Milford or Hoopeston. Q: Isn't it a fact he was there only a few weeks; that he went in a car with Wesley GOFORTH and hit a train and got afraid they would get into trouble and they came right back to your house? A: Yes. Q: That conflicts with your prior answer that he was there over 3 years. Do you want to explain? A: No, I'm not going to try to. I'm just going to let it go at that. Q: Did he ever pay you or DAVIS for such time as he did spend with you? A: He bought groceries and try to help us. Q: This was before he went into the Army? A: Yes. Q: Was Davis willing to work when it was available, during your marriage to him? A: Sometimes he was, sometimes he wasn't. He said he was sick and he was afraid to go to a hospital. He was good to get wood and build fires and do things for me around the house. He was of a jealous disposition. Q: Did he ever mistreat Woodrow? A: Maybe on little things he'd say, but not on big things. Q: How far did Woodrow go in school? A: To the 6th grade. He went to school a little after he was working for Clyde APPLE. I don't know what school. Q: Where is your family now? Do any live with you? A: Just my son, Charles DAVIS. The others live around Paoli. Q: I have no further questions. Do you have anything to add? A: No, I guess not. I certify that I have read the foregoing and my statements are true, to the best of my knowledge and belief. /signature of Inice Belle (Holland) HOLLEN/ Subscribed and sworn to before me this 18 day of March 1954; and that I hereby certify that the foregoing statement was read by the affiant before signing. /signature of A. W. HENDRICKS/ Field Examiner (c) 2001 Barb Wise (wisebarb@home.com)