Deposition of James M. Frost, Jr. taken ^at^ the house of his father in Owen County Ky. near New Liberty on the 5^th day of December 1865.

Question. Do you know anything of a sorrel or chestnut dun mare with flaxen mane and tail said to be stolen from a man in Fayette County by the name of Baysie and found in the possession of your brother Joseph L. Frost?

Answer. I do. I was present at my brothers house near Lexington Ky. during the latter part of January or ^1^st of^ February last when a man called there calling himself Keiser and offered to sell my brother an animal of the description mentioned, and after my some consideration between them my brother bought said animal at about sixty dollars — the exact amount I do not now recollect.

Question. Did your brother say anything to Mr Keiser in regard to requiring a bill of sale for the animal in question before purchasing her?

Answer. He did. He told Mr Keiser that he was in the habit of giving and requiring bills of sale for all animals of the horse and mule kind that he sold or bought in consequence of the near certainty about [...]titles growing out of the unlawful impressment of such animals by irresponsible parties.

Question. Did Mr Keiser agree to give your brother a bill of sale for the animal in question, and was there any such paper executed in your presence?

Answer. Mr Keiser did agree to give my brother a bill of sale for said mare and after the trade was concluded such a paper was executed in my presence by Mr Keiser.

Question. Do your think the paper now shown to you bearing date "Bachelor Dome Jan. 27^th 1865 and signed William Keiser purporting to be a certificate

of sale of a chestnut Dun mare with flax mane & tail for sixty three ($63.) dollars, and hereto appended, is the same paper executed in your presensense by Mr Keiser to your brother?

Answer. I think it is.

Question. Did you notice at the time your brother bought said mare any appearance of a sore or other disfigurement about her face?

Answer. I did not at that time, but on the next day or the day after I did notice something of the kind and heard my brother tell one of the boys to put some grease on it. I did not notice at any time the appearance of the mares face very particularly and could not therefore state about the matter very definitely or accurately.

Question. Where did your brother keep the mare after he bought her of Mr Keiser? [...]

Answer. For the first two or three weeks after he bought her he kept her in the stable near the house, and he then had her turned out in the pasture with the other stock where she run for some time — I can't recollect exactly how long when he sent her down with some three other mares to Col M^cLeans for pasture. My impression is she staid until there until she was taken away as I heard by Mr Baysie.

Question. Were you living with your brother Major Frost at the time he bought this mare and whilst he had her in possession?

Answer. I was.

Question. How old are you Mr Frost?

Answer. I was sixteen years old the 10^th day of last February.

Further deponent saith not.

James M. Frost Jr.

Sworn and Subscribed before me by James M. Frpst Jun^r the 5_ day of December 1865

[...] J. P. O C