In the circuit court of the State of Oregon for Lane County,

M. A. Poill Plff

J. J. Poill Deft

M. A. Poill a witness in her own behalf after being duly sworn testified as follows.

Q1: State your name, age, occupation and place of residence.

A1: M. A. Poill age 33 years reside in Springfield OR occupation housekeeper.

Q2: When & where were you married.

A:2 The 29th day of Aug 1873 in Cottage Grove Lane County.

Q3: How long have you lived in Lane Co prior to the commencement of this suit.

A3: Have lived in the county ever since 1871.

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Q4: What has been your general treatment of the defendant since your marriage to deft.

A4: To the best of my ability I have been a good housekeeper and a good faithful wife. I have done my best ever since our marriage. I have done my part. I have gardened & raised berries to help support the family.

Q5: What has been the treatment of defendant towards you since Oct 1878. State what if anything he did then continuing on up to the present time.

A5: When we were living at the mountain place 1st he told me to get up. He said God damn you get up or I will make you get up. I told him it was Sunday morning. It was no use in being in a hurry & he swore at me the same way again & he said he would have me taken home.

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Q7 (sic): What language did he use when he cursed you.

A7: He called me a damn son of a bitch and damn bitch.

Q8: State whether or not in 1882 he deserted you & how long he remained away.

A8: Yes and remained away a year & a half.

Q9: Who supported the family while he was away. State how you did it.

A9: I did keep some boarders. I also had the mail contract and carried the mail a good deal of the time myself.

Q10: How did he get back home.

A10: I went after him and brought him home.

Q11: After he returned home what was his conduct toward [you].

A11: He soon fell back in the same way and commenced abusing me. He threatened to kick me into w [missing word] and after that without cause he commenced to abuse me & I asked him to be quiet & let us have no

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A11 (cont): quarrel and he jumped up & said he had had all the damn nonsense he would have & would put an end to it. He went to the bureau & got a pistol & snapped it at me, at least the children raised up screaming & said he did.

Q12: How many times did he draw the revolver on you

A12: I can’t say exactly but several times. At one time he commanded me to sew buttons on our son Eddy’s shoes and jerked has revolver form over the window and said I could not live if I did not put the buttons on. I sewed them on as soon as I could. He appeared to be very angry & violent. Eddy & Jennie Smitson [Mila Ann’s sister] heard him.

Q13: Where is Jennie Smitson now.

A13: At Springfield sick with typhoid fever

Q14: What occurred about

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Q14 (cont): two years ago

A15 (sic): He got mad because I had forgotten to do some repairing on his overcoat and he cursed me and slapped me in the face.

Q16: State what followed that later on.

A16: About 2 months ago he was coming to town and was mad about something and I went out to the barn to tell him to get some things & he struck me with the buggy whip and went in the barn & struck me again.

Q17: What occurred on the 17th day of Sept 1891.

A17: He brought the ax in & laid it on the table & ordered me to cook him something to eat. This was about 10 o’clock. He had already had his breakfast at the usual time. After he got to eating I took the ax

& slipped it on the corner of the table. He would not let me

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A17 (cont): take it away. Mrs. Robinson who was working for me slipped it away & hid it.

Q18: What occurred on the 18th day of Sept 1891.

A18: I threw out a few bread crusts out at the door & he got mad & had a sack in his hands & struck me in the face with it when I came in the hose.

Q19: What occurred on the 19th of Sept 1891.

A19: He laid the pistol on the table and said in the morning we will have a little fun [and] all will die together & he also set a bottle of strychnine on the table & said he would take it. He frequently said he would take strychnine.

Q20: How long since you ceased to live and cohabit with deft.

A20: About three months ago he slept in the barn awhile.

Q21: How are you supporting

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Q21 (cont): yourself now.

A21: Keeping boarders

Q22: How many children have you and what are their names and ages.

A22: Four—Eddy age 16 yrs. Lulu age 12 yrs. Mabel age 8 yrs. May age 6 years. The children are with me in my care & custody.

Q23: What threats if any did he make six or eight weeks ago/

A23: He told me if I would raise him $600 he would deed me the place & he would leave me & I should never see him anymore.

Q24: State whether or not defendant & yourself have agreed to separate mutual or otherwise.

A24 No sir we have not. There is no agreement between us to separate.

Q25: State whether or not he has deeded you any property & the

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Q25 (cont): circumstances under which it was done

A25: After I commenced this suit deft came to me and told me that if I would not ask for support for the children & for property he would deed me half as he did not want to be forced to do anything & he did deed one half and I have asked for nothing but the divorce, the children, & for costs.

Q26: State whether or not you have forgiven deft for the different acts of ill usage as testified to[day] by you.

A26: I have not.

Q27: Can you live with him with safety to yourself & without fear of bodily harm.

A27: I cannot

Cross

Q1: You say in your direct examination that your

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Q1 (cont) husband has deeded you certain property. Further than this has there been any agreement or understanding between you by which you were to secure a divorce without opposition from him.

A1: None at all. We had no agreement.

Q2: No collusion at all

A2: Not any at all

[signed} M. A. Poill