The claimant in this case sues as the heir of her deceased mother. The claim accrued in her life time so that the loyalty of the mother is in question. The proof is as certain as it is reasonable to require in a case of this kind. The record shows no act that can impeach it, but does substain the claim of loyalty as fas as it is possible to do so. The witnesses who are called were well acquainted with the deceased, and say that her sentiments were in favor of the union. She conversed in that way and there was no other manner in which she could evince her loyalty; she was known as a union woman by her neighbors.

The evidence in this case shows quite conclusively that the claimant was a loyal adherent to the United States government during the late war. She was an old lady who kept quietly at home during the war and her Union sentiments have been spoken of by witnesses who have been examined in her behalf. These were close acquaintances and her near neighbors and were shown to have been in a position to know the facts that they relate. She did all she could to keep her sons from joining the Confederate army. She advised them not to do so. Her expressions and sentiments were universally in favor of the success of the Federal cause. From these facts it will be confidently urged that the claimant should be found loyal by this Honorable Court.

Respectly submitted,

Gilbert Moyers
Attorney for Claimant