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Depositions of William Ashworth and Thomas O. Gill.

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.

Depositions of Joseph Whitaker and Newton Whitaker.

The Whitakers were witnesses for the defendant, Abner Tate. Joseph Whitaker's deposition is first. He answers questions regarding Elizabeth Routt and her husbands, particularly the death of Alexander Jeffries. Joseph states that it is his opinion that Jeffries was poisoned. He also states that rumors have spread that she had ordered a slave to murder Abner Tate. Newton Whitaker's desposition is second. He also answers questions regarding Elizabeth Routt and her husbands, including the death of Alexander Jeffries. Newton states that he is also of the opinion that Jeffries was poisoned. Like Joseph, he also adds that she is said to have destroyed the lives of her husbands, stole cotton, and sought to harm Abner Tate.

Deposition of Nancy Whitaker.

Nancy Whitaker acted as a witness for the defendant, Abner Tate. Nancy responds to questions about Alexander Jeffries, her father, and Elizabeth Routt. She expresses her belief that her father was poisoned by Routt though she was not present until the morning after he died. Nancy details the dark color of her father's body and how it was swollen and "unnatural" in appearance. She also includes the rumors she has heard regarding several charges brought against Routt. She concludes by stating that it is her opinion that Routt is guilty in the case of her father's death.