Ashworth and Gill are witnesses for the defendant, Abner Tate. Ashworth's deposition is first. He answers questions regarding Elizabeth Routt and her husbands, particularly of her character and what others said and thought of her. He includes at the end that he has heard of her destroying the lives of her husbands, stealing cotton by way of her slaves, and was accused of having one of her slaves shoot Abner Tate. Thomas O. Gill's deposition follows. He is asked about Elizabeth Routt and her husbands as well, including her character and what others said and thought of her. Gill also confirms hearing of the "great many charges alleged against her." Gill is then cross examined by the plantiff's, Elizabeth Routt, counsel. He is asked whether the charges against her character are of his knowledge or the publics'. Gill names those whom he heard the information from and admits that the charges were rumors rather than facts. He also details the pamphlet written by Abner Tate that he received from an unknown sender. He was also asked about the sicknesses of Routt's husbands and the attending physicians which he was unable to answer.