(See official record of Board hearing, under date of November, 30th, 1936, at page 54).

Another question by Mr. Burr to Pete Dulaney: and at the time he asked the question he was referring to some reports he held in his hand:

Q. "On August 12th, did you say, "I expect I will be in the bunch that will be cut off, and I want to know about it so that I can give them plenty of hell"? (See page 550, of official record of said Board hearing under date of November 30th, 1936.)

Mr. Burr, while holding a report on a Union meeting in his hand and looking at the same later asked Pete Dulaney the following:

Q. "On another occasion at the Union Hall before your Union members, didn't you tell them that Dr. Chandler had turned against you, or against them and that you wanted to get him fired, or that in substance?"

(See page 57 of Official record of said Hearing under date of Nov. 30, 1936.) On the same page Mr. Burr, examining Mr. Dulaney, and while Mr. Burr was holding a report on union meetings in his hand asked this question:

Q. "On August 1, 1936, didn't you say this (Mr. Coleman Attorney for the Miners interrupting by asking, Where?). Ans. by Mr. Burr: At the Union meeting.

Q. "We are not going to have that Incentive Plan, they might as well call it off. We have been out on a strike so long that we don't care whether we work or not, we are getting plenty to eat, and if any men try to go back over there it will be too bad?"

(See page 57, of official record of said Hearing under date of Nov. 30, 1936.) Mr. Burr, continuing to examine Mr. Dulaney on the occasion above referred to asked this question:

Q. "On June 27th, at the Muscoda Local didn't you say this? "I heard the other morning that a truck load of men were going up there that is to say, on the mountain, and "I was ready to go.?" That any time they need help they can count on us".

Also, on the same occasion the following questions were asked by Mr. Burr, representing the Company;

Q. "Another time, on July 30th, when you were presiding, you preside sometimes didn't you? Ans. Sometimes, yes, sir.

Q. By Mr. Burr: What Office do you hold in the Union?"-A. I am member Executive Board.

Q. What do you hold at this time?-A. I was Chairman.

Q. Chairman?-A. If that is the date.

One night when you were presiding, didn't you make this statement? "I have appointed extra guards to watch Mr. Jones and Mr. Barksdale's houses tonight, we have to do this because I think the Company is going to try to start something. I keep hearing that the Company is going to try to start up the mines about the first of the month. They will either sign our agreement, or try to run with the scabs, and if they do they will get a dose of what they got before"? (See page 59 of official record of Board Hearing under date of Novmber 30th, 1936.)

STATE OF ALABAMA

Jefferson County

Personally appeared before me the undersigned authority in and for said County in said State, Mr. E. C. Curtis and Mr. V. C. Finch, who being known to me and who being by me first duly sworn, each deposes and says that, the contents of the foregoing three pages, wherein same is referred to as quotations from records, are the true and exact copies of the referred to records, and same has been verified by each of them.

Affiants further say on information and belief that the quotations above referred to were given at a Board Hearing wherein the witnesses testified under oath. E. C. CURTIS

V C FINCH.

Sworn to and subscribed before me this 13th day of January, 1937. [SEAL]

My com. expires: 3/8/1938.

WILLIE RUSSELL, Notary Public.

89562-38-pt. 15-c-4

EXHIBIT 2856