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Rebels on Lake Erie Chapter IX - The Lake Erie Conspiracy

reprinted with permission of the Ohio Historical Society



The most elaborate of many plots for escape from Johnson's Island had its roots in the very early days of the war, but in its final form the piracy on Lake Erie and the proposed raid upon the prison at Johnson's Island had their beginning with the appointment of Confederate Commissioners Clement Claiborne Clay of Alabama, J. P. Holcomb of Virginia, and Jacob Thompson of Mississippi, to operate in Canada. Thompson had been U. S. Secretary of the Interior under President Buchanan, and Governor of Mississippi.


Richmond, Va., April 27, 1864 Hon.Jacob Thompson: 

Sir: Confiding special trust in your zeal, discretion, and patriotism. I hereby direct you to proceed at once to Canada; there to carry out the instructions you have received from me verbally, in such manner as shall seem most likely to conduce to the furtherance of the interests of the Confederate States of America which have been entrusted to you.


Very respectfully and truly yours, Jeff’n Davis[i]


Thompson and Clay left Richmond on May 3, and sailed from Wilmington, North Carolina, May 6, running the Federal blockade in the swift steamer Thistle during that night, and landing at St. George, Bermuda. From there they sailed on May 10 to Halifax, Nova Scotia, arriving there the 19th, and at Montreal ten days later. In his peculiar position as special commissioner, Thompson had to make decisions largely on his own authority, operating in a country whose neutrality he was charged to observe, and being far distant from, and out of communication with, his own government. Undoubtedly, through agents reporting to him, his purposes were to interfere with or destroy supply lines and stores of the Federal government, and to embarrass it in any possible manner. The so-called “Northwest Conspiracy” was conducted from headquarters in Montreal.


One of the first inquiries made by Commissioner Thompson after his arrival in Montreal concerned the strength of the Federal defenses on the Great Lakes, and how to encompass the capture of the Federal gun-boat, Michigan,* which was the only United States war vessel permitted on the lakes under the Ashburton Treaty.[ii] W. L. McDonald, a Confederate naval officer, was not successful in drawing up plans, and on July 14, Mr. Thompson appointed Captain Charles H. Cole to perform the service. The latter submitted a report which included a statement that "Lake Erie furnishes a splendid field for operations ...I have formed the acquaintance of Captain Carter, commanding United States steamer Michigan. He is an unpolished man, whose pride seems to be touched for the reason that, having been an old United States naval officer, he is not allowed now a more extensive field of operation. I do not think that he can be bought." At this point, Cole requested further authority:


Hon. Jacob Thompson


Sir: I have the honor to ask to be placed in secret detached service, in undertaking the capture of the gun-boat Michigan* at Johnson's Island. Combination can be made without infringing the neutrality laws of Canada. I send this by special messenger. An immediate answer requested.


Charles H. Cole,

Captain, C.S.A.



Charles H. Cole.

Captain C.S.A. and Lieutenant C. S. Navy




By the authority in me vested, specially trusting in your knowledge and skill, you are assigned to the secret detached service for the purpose mentioned in your letter. To aid you in this undertaking, John Y. Beall, Master in the Confederate States Navy, has been directed to report to you for duty. In all you may do in the premises, you will carefully abstain from violating any laws or regulations of Canada or British authorities in relation to neutrality. The combinations necessary to effect your purposes must be made by Confederate soldiers, with such assistance as you may draw from the enemy's country.


Your obedient servant,

Jacob Thompson[iii].


Cole spent much time during August and September in Sandusky .He registered several times during that period at the West House, sometimes with his "wife."[iv] The West House was a five-story hotel situated at the southwest corner of Columbus Avenue and Water Street, several hundred feet from the waterfront. It afforded a clear view of Johnson's Island and the.U.S.S. Michigan, which would often ride at anchor off the prison compound on the Sandusky side of the Island. The entrance to Sandusky Bay was not more than a mile to the right of Johnson's Island, viewed from the hotel, but while there was much shallow water in a direct line from the entrance to the Island the channel used at that time also ran in that direction.


The West House was built by brothers of that name, one of whom was one of the contractors for the prison buildings on Johnson's Island. The West House (torn down in 1919) had opened in time for the Ohio State Fair in Sandusky in 1858, and was the center of the social and business life of the bustling city of 25,000.


Cole represented himself to be secretary of the Mount Hope Oil Company of Harrisburg, Pennsylvania. He opened accounts in the local banks, made use of the telegraph office on many occasions (not an ordinary occurrence in those days), spent much time in the saloons and places of entertainment, and became known as a heavy spender. He wined and dined officers of the U.S.S. Michigan, and of the prison post, and entered into the social life of the hotel. His "business" connections gave good cover for his activities and his travels, and the supply of money  which he seemed to command.


In a report of his own story Cole said that he had men who enlisted in the service at Johnson's Island and on the Michigan, but there seems to be no confirmation of this. John Yeats Beall, in his diary, said: "Immediately on my arrival in Canada, I went to Thompson at Toronto, and made application to start a privateer on Lake Huron. He informed me of a plan to take the Michigan (14 guns), and release the Confederate officers confined at Johnson's Island. I immediately volunteered, and went to Sandusky, Ohio, to meet Capt. Cole, the leader. We arranged our plans, and separated. Cole stayed at Sandusky. I came to Windsor to collect men, and carry them to the given point.”[v]


Rumors of border raids had been frequent during the years of the war, but thus far nothing alarming had followed the rumors, so it was with some skepticism that Lieutenant Colonel Bennett H. Hill, Acting Assistant Provost Marshal General at Detroit, listened to a story told him on September 17, 1864, by a visitor who claimed to be a refugee rebel soldier. He gave information that some of the officers and men of the steamer Michigan had been tampered with, and that under the rebel agent Jacob Thompson's direction, a party would be sent from Windsor, Canada, which, with the assistance of the ship's officers and men, would attempt to get possession of the steamer. He said he had been asked to be one of the party and had agreed to do so, and that he would receive further information the next morning; that the general purpose was to have control of the lakes for a couple of months and attack the cities on the lakes. He promised to return again on Sunday evening, September 18.[vi] The following telegram was then sent to Captain J. C. Carter, of the Michigan, on September 17, by Lieutenant Colonel Hill:


It is reported to me that some of the officers and men of your steamer have been tampered with, and that a party of rebel refugees leave Windsor tomorrow with the expectation of getting possession of your steamer.[vii]


The following was the telegraphic reply:


U.S. Steamer Michigan

Off Johnson's Island,

Sandusky, September 18, 1864


Lieut. Col. B. H. Hill,

U. S. Army Military Commander:


Thanks for your dispatch. All ready. Cannot be true in relation to the officers or men.


Jno. C. Carter

Commander, U. S. Navy[viii]


The informant again returned on Sunday evening as he had promised, and reported that he had agreed to join the party, and had obtained all the information he could, but failed the party at the last moment. He said that the party was to take passage on the steamer Philo Parsons** at Malden, and would take possession of her before reaching Sandusky; that certain officers and men of the Michigan had been tampered with by a man named Cole; that an officer named Eddy could not be bought and was to be drugged with others.[ix] He also reported that he thought the captain of the Philo Parsons had been bought, and if he received any hint on the subject he would give information and would himself be compromised.


As a result of this information, Lieutenant Colonel Hill went down to the Philo Parsons at six in the morning, Monday the 19th, and observed that she was too small to be of any danger if taken, and concluded that it would be better to let the steamer go, and place Captain Carter more strictly on his guard, so that the whole party could be taken.


On the morning of the 19th, Hill sent the following telegram to Captain Carter:


It is said the parties will embark today at Malden on board the Philo Parsons, and will seize either that steamer or another running from Kelleys Island. Since my last dispatch, am again assured that officers and men have been bought by a man named Cole; a few men to be introduced on board under the guise of friends of officers; an officer named Eddy to be drugged. Both Commodore Gardner and myself look upon the matter as serious.[x]


Part-owner and clerk of the Philo Parsons was Walter 0. Ashley, known in subsequent accounts as Clerk Ashley. He was on board Sunday evening, the 18th, the ship secured to her Detroit dock, when a stranger came up and addressed him by name. In the hearings that were to follow, the stranger was minutely described: he was a thick-set man of about 25, evidently Scotch or English, dressed in English clothes. A little below the medium height, he had light-colored hair and a thin, light-colored beard. He had "the bearing of a gentleman".


The stranger, later identified as Bennet G. Burley, said that he and a party of friends were planning a pleasure trip to Kelleys Island in the morning and wished to have the boat stop at Sandwich (a Canadian town below Detroit) to take on his friends, one of whom was lame. Ashley thought that the skipper, Captain Sylvester F. Atwood, would agree, but said that they could take no baggage as there was no custom-house on Kelleys Island.[xi]


The Philo Parsons duly sailed next morning at 8 (Monday, September 19) and Burley was on board to remind Clerk Ashley of the unscheduled stop. Captain Atwood obligingly picked up Burley's four friends, including one whose feigned lameness was no longer noticed after he was brought aboard.


About 40 passengers had sailed from Detroit, and at the next regular port of call --Malden, now called Amherstburg, on the Canadian side -- 20-some men took passage for Sandusky, bringing with them a large old-fashioned black trunk tied with ropes. There was nothing unusual in that sort of group; the Parsons often carried "skedaddlers", or draft-evaders, back to Ohio after a brief Canadian vacation. It was thus that Ashley thought of them, he recalled.


This second group seemed to have no connection with the first; there were no signs of recognition and no conversation between them. They were dressed in worn and ragged clothes, and each paid his fare singly, in greenbacks.


Once the little steamer was out of the Detroit River and in the open water of Lake Erie, Burley and his friends made a point of being sociable with the other passengers. Burley was reportedly most attentive to the ladies, turning the pages for those who sat down to play the piano in the cabin, chatting freely and attending to their comfort on deck, in general confirming that he had "the bearing of a gentleman".[xii]


The boat made its regular stops at the Lake Erie islands -- North Bass, South Bass (Put-in-Bay), and Middle Bass, where Captain Atwood, who lived there, went ashore to spend the night with his family, as he normally did about once a week. Nothing unusual occurred. Freight and passengers came aboard and went ashore at each stop in routine fashion.


After Middle Bass came Kelleys Island, and Clerk Ashley reminded the men who came on at Sandwich that this was their destination. However, after talking to four men who came up the gangway from the island dock, they said that they had decided to go on to Sandusky, and the newcomers from Kelleys Island joined them.[xiii]


The Parsons left Kelleys Island at 4 o'clock in the afternoon. A bit later, perhaps 15 or 20 minutes, she met and passed the steamer Island Queen, at a distance of about 300 feet. No kind of signal, private or otherwise, was exchanged.[xiv]


Immediately thereafter, however, one of the passengers ("a man apparently 30 years of age, about five feet, eight or ten inches tall, fair complexion, brown hair, no side whiskers or mustache, wearing a Kossuth hat”) presented himself with an air of authority to the mate, D. C. Nichols, who was in command in the absence of Captain Atwood.


“Are you the captain of this boat ?" he asked.

"No, sir. I am mate."

"You have charge of her at present, have you not?"

"Yes, sir."


The man then said, "Will you step back here for a minute. I want to talk to you." The two walked aft on the hurricane deck and stood near the smokestack. There the man in the Kossuth hat said, "I am a Confederate officer. There are 30 of us, well armed. I seize this boat and take you as prisoner. You must pilot the boat as I direct -- and here are the tools to make you." Whereupon he pulled out a revolver. "Run down and lie off the harbor."


In the meantime, as Clerk Ashley was standing in front of his office, four of the conspirators came up to him with drawn revolvers and told him he would be shot if he offered any resistance.[xv] The old black trunk that was brought aboard at Malden was opened up, disclosing revolvers, hatchets and enough other weapons to arm the whole party. Two guards were left with Ashley, and others went into the cabin, threatening to shoot anyone who resisted, and thoroughly frightening the many women passengers.


Michael Campbell, the wheelsman, was standing in the cabin at 4 o'clock when the Parsons left Kelleys Island. He heard a shot, a yell, and another shot. He ran out on deck to see a man with a cocked revolver in his hand chasing the fireman and shouting to him to go down the main hatch or he would be shot.[xvi] The fireman got away, and the man turned and gave the same order to Michael Campbell who told him to go to hell and scrambled up the ladder to the upper deck. The intruder shot at him, but the ball passed between his legs.


When the wheelsman reached the upper deck he saw five armed men driving the passengers forward and ordering them into the cabin. They were required to give up their guns, if any, and some of them were searched. They were then forced at gun point down into the fire-hold, Campbell along with them. He was allowed to go up again when inquiry was made for the pilot. Deckhands were ordered to throw the cargo of pig iron overboard.


James Denison, engineer of the Parsons, was below in the fireman's cabin as the boat left Kelleys Island. Hearing the commotion, he went on deck just in time to see the man fire at Campbell, and to see eight or nine others driving the passengers into the fire-hold, after which they closed the hatches and weighted them down with pig iron. The women were all herded into the cabin. All the crew, with the exception of the firemen and engineer, were put below with the other men, and Denison was told to operate the engine under rebel orders.[xvii]


The mate, Nichols, was under guard in the pilot house, Campbell was at the wheel. Denison and his fireman were in charge of the engines. All were under the eye, and the cocked pistol, of a leader later identified as Captain Beall, assisted by the gentlemanly Burley.[xviii]


The entire take-over occupied about half an hour. Under Captain Beal!'s direction, the Parsons was held to the east of her regular course to the entrance to Sandusky Bay. She continued on that course to a point eight miles off Cedar Point, according to Nichol's later testimony, and there, about 5 o'clock, the U.S.S. Michigan was plainly visible in the bay. Beall asked many questions about her and her position in the harbor.


The pirates then learned from the mate and engineer that the Parsons had not sufficient fuel to run the seven or eight hours that Captain Beall had planned. It was the usual custom not to carry more than enough to take her to Sandusky and back to Middle Bass, which was the normal fueling station. The only recourse now was to return to Middle Bass.


There chance brought another unlucky little ship into the piratical venture. She was the Island Queen,*** which had been plying between Sandusky and the Lake Erie Islands since 1855. The docks at Middle Bass were on the south side of the island, opposite South Bass and approximately a mile from the harbor of Put-in-Bay. Captain Atwood's home was in the southwestern part of the island, and the road from the docks passed his property.


Naturally the unscheduled re-appearance of the Philo Parsons between 7 and 8 o'clock that night created great excitement. When she docked for fuel, several shots were fired at the uncooperative owner of the wood-yard and at two other men who refused to go aboard when ordered to do so. Captain Atwood hurried to the dock after a boy came running to his house with the news that men from the Parsons were shooting at his father.


When the captain demanded to know "what the hell was up", he was faced by a number of armed men and ordered aboard. In the cabin he found the passengers and some of the crewmen under guard. Clerk Ashley told Atwood the ship had been seized by rebels and that there was no use resisting.


One of the intruders, inviting Captain Atwood to sit beside him, identified himself as a surgeon in the Confederate Army. He said it was an unpleasant situation, but he had his duty to do and that if the captain complied willingly he would not be hurt. He was refused permission to leave the boat, but he would be introduced to the leader of the raiders. The surgeon thought that Atwood would get his boat again.


The conversation was interrupted by the whistle of the Island Queen, and they heard an order to the guards -- "as many as can be spared from the cabin, come this way." The Island Queen came alongside, but there was no one to help take the lines. Deckhands from the Queen jumped to the deck of the Parsons to make fast. Immediately some of the rebel gang made a rush to board the Queen, and her skipper, Captain Off, sensing some mischief, made an attempt to ring for speed forward, but too late.


Henry Haines was at his post as the Queen's engineer. Someone exclaimed, “Shoot the s -- of a b ---!” and a ball passed through the engineer's nose and through his left cheek and ear. The raiders secured him and confined him with the other prisoners on the Philo Parsons. When it was learned that he was the engineer of the Island Queen, essential to her operation, he was returned under guard to his engines.


All the Queen's passengers were put aboard the Parsons in the hold with the crewmen and passengers already captured. The newcomers included a group of some 25 soldiers from the 130th O.V.I., who had gone to Toledo to be mustered out.[xix] They had learned on Saturday, September 17, that the mustering-out officer would not be there until the following Tuesday, so, on a basis of “AWOL with permission," they took the train for Sandusky, “borrowed" a sailboat and took off for Kelleys Island where they spent Sunday visiting relatives and friends. One of the returning soldiers was related to one of the Island Queen's owners, and Alfred Kelley, the boat's agent, proposed that if they would wait until Monday afternoon, he would send the Queen to Toledo with them. In response to this generosity the returning soldiers were aboard the Island Queen as it made its rounds among the Bass islands before setting course for Toledo. Now, having survived the rigors of various campaigns, they were prisoners of the rebels in their own home territory.


Some of the captured deckhands had been released to help load wood on the Philo Parsons. When the job was done, all the men passengers on the Island Queen, including the unarmed men from the 130th, as well as those of the Parsons, were "paroled" on condition that they would not fight against the Confederacy until they were properly exchanged. The women were also put ashore, and they were all warned not to try to get in touch with the mainland for a period of 24 hours. The telegraph had not yet reached the islands at that time, and boats were the only means of communication.


Captain Beall was then introduced to Captain Atwood and they went together to the captain's quarters on the Parsons. Atwood was asked to pledge his word that he would not leave the island for 24 hours unless the Philo Parsons returned. Beall asked him to go ashore and take charge of the passengers and those crewmen who had been released. He was not allowed to take any clothes or personal property. Beall promised that his quarters would not be disturbed. Captain Atwood took the women to his home where they were lodged as comfortably as possible.


Shortly after 8 o'clock the Parsons set out, towing the Island Queen. Before the officers of the Queen were transferred to the Parsons, one of the raiders, Captain Morgan, asked Engineer Haines where the valves were. When the "pony pipe" in the hold was pointed out to him, Morgan chopped it off, then with a sledge hammer broke the valve off the side of the boat, so letting the water in. About halfway between Middle Bass and Kelleys Island, the Island Queen was set adrift, an act easily visible from shore in the bright moonlight.[xx]


At this point the captive officers and crewmen of both boats, excepting only the engineer and wheelsman of the Parsons, were ordered down into her hold. When she came opposite Marblehead Light at the end of the Peninsula, Campbell, who had the wheel, told his captors it was dangerous to run into Sandusky Bay at night because the channel was narrow. He was told not to try if there was any danger of going aground. After a brief conference with fellow pirates, the captain ordered Campbell to come about and head for Malden. He said they were going to destroy every craft they met on the way up, and thereupon the rebels established a regular deck watch.[xxi]


Captain Beall had determined to go ahead with the original plan of running into Sandusky Bay, seizing the U.S.S. Michigan, and releasing the Southern prisoners on Johnson's Island. Incidentally, Clerk Ashley had been told of this far-reaching plot when he was put ashore on Middle Bass with the rest. There he would be helpless to interfere until the deed was done.


But apparently things went wrong at the other end. Possibly some signal expected from Sandusky failed, possibly some looked-for information had not been brought aboard at Kelleys Island. But the inexperienced pirates now in charge of the Philo Parsons grew suspicious and apprehensive. The only report as to the state of affairs which has so far been discovered is contained in a written protest to Acting Master Beall. It reads as follows:


On Board the Philo Parsons

September 20, 1864


We, the undersigned, crew of the boat aforesaid, take pleasure in expressing our admiration of gentlemanly bearing, skill, and courage of Captain John Y. Beall as a commanding officer and gentleman, but believing and being well-convinced that the enemy is already apprised of our approach, and is so well prepared that we cannot by any possibility make it a success, and having already captured two boats, we respectfully decline to prosecute it any further.


J. S. Riley, M.D.

H. B. Barkley

R. F. Smith

David H. Ross

R. B. Drake

James Brotherton

M. H. Duncan

W. B. King

Joseph Y. Clark

Wm. Byland

Robert G. Harris

W. C. Colt

Tom S. Major

U. S. Johnson John Bristol

F. H. Thomas

J. G. Odoer


This protest -- actually evidence of mutiny -- was written on the blank side of a bill of lading. It is dated September 20, a Tuesday; but whether the document was prepared during the passage from Middle Bass after the refueling, and after the scuttling of the Island Queen, or whether it was written as a justification on the way up to Malden after the raid was abandoned, is anybody's guess.[xxii]


The mate of the Philo Parsons, D. C. Nichols, confined with the others in her hold after the Island Queen was set adrift, was ordered on deck after the ship struck something (later learned to be the enclosure of a fish pound net off Middle Bass) and he was ordered to set a course for the Detroit River.[xxiii] The anxious officers marooned on Middle Bass could descry their ship again in the moonlight, about 1 o'clock in the morning of September 20, running, as Clerk Ashley described it, "under a full head of steam".


Once in the river, Captain Beall inquired about the vessels they were passing. Being told they were now in Canadian waters, he remarked that it was a good thing for the ships, otherwise he would have boarded them. They also made inquires about a banker named Ives who lived in Grosse Isle, and said if it were not so late they would have landed there and robbed him. They reached Malden between 4 and 5 in the morning and proceeded up the British channel. About three miles above Malden a small boat was sent ashore loaded with goods taken from the Philo Parsons. A little farther on all the passengers and all but three of the crew were set ashore in two boat-loads on Fighting Island. It was then about 8 o'clock in the morning.


The rebels made fast to the dock at Sandwich and put ashore their plunder, including the piano from the cabin, mirrors, chairs, trunks and bedding. One of them threatened to take the ship across the river into American waters and burn her, but finally took the engineer below to cut the injection pipes, thus sinking her.[xxiv]


Campbell and Denison, wheelsman and engineer of the Parsons, started for Windsor afoot, accompanied for a short distance by some of the booty-laden pirates. There had been but two or three persons, apparently Canadian, on the dock at Sandwich; one of them objected to the proposal that the ship be burned there. Nichols and those who had been put ashore on Fighting Island were taken by a small boat to Ecorse where they boarded the steamer Pearl. When she made a stop at Sandwich, they landed and took possession of the Philo Parsons, abandoned there but not badly damaged, and sent word to Detroit by the captain of the Pearl of the adventures of the preceding day and night.[xxv]


The Island Queen drifted into nine feet of water on Chicanolee Reef, off Pelee Island to the south. She was easily raised and repaired and resumed her inter-island runs less than a week later -- Monday, September 26.


As for the Philo Parsons, she was back in service before that, resuming her old schedule on Saturday, September 24.[xxvi]


*U.S.S. Michigan, built in 1844 in Erie, Pennsylvania; one of the earliest iron hulls in existence and the first iron ship in the U.S. Navy; 163'3" overall length, 27' beam, 9' draft; 685 tons.


**Philo Parsons, built in 1861 in Algonac, Michigan (possibly in Detroit); wood hull, side-wheeler; 136' overall length, 21' beam, 8' draft; 221 tons.


***Island Queen, built in 1854 at Kelleys Island; wooden sidewheeler; 121'6" overall length, 20'6" beam, 7' draft; 179 tons.

horizontal rule

A new book (pub 2010) contains many first-hand accounts of this incident as it related to the Kelleys Island soldiers who were on board the Island Queen when it was captured. There are excerpts from official documents as well as letters from the soldiers who served in the 24th, 38th, 100th, and 101st Ohio Infantries, the 1st Ohio Heavy Artillery, 3rd Ohio Cavalry, and the 130th Ohio Volunteer Militia.
Kelleys Island 1862-1866 - The Civil War, the Island Soldiers, & the Island Queen


[i] “Northwest Conspiracy,” in Southern Bivouac, II, 444, hereinafter cited as “Northwest Conspiracy.”

[ii] Ibid., 567-568.

[iii] Ibid., 568.

[iv] West House registers, Sandusky Public Library.

[v] Daniel B. Lucas, Memoir of John Yeats Beall (Montreal, 1865), 296. Hereinafter cited as Lucas.

[vi] O.R., 1, XLIII, Part 2, 233. [O.R. refers to The War of the Rebellion: A Compilation of the Official Records of the Union and Confederate Armies (Washington, 1880-1901).] 

[vii] Ibid., 234.

[viii] Ibid., 235.

[ix] Ibid., 233.

[x] Ibid., 235.

[xi] Ashley Deposition, ibid., 242-243.

[xii] “Famous Canadian Trials,” in Canadian Magazine, XLV, 190. Hereinafter cited as “Canadian Trials.”

[xiii] Ashley Deposition, O.R., 1, XLIII, part 2, 244.

[xiv] Nichols Deposition, ibid., 240.

[xv] Ashley Deposition, ibid, 243.

[xvi] Campbell Deposition, ibid., 237.

[xvii] Denison Deposition, ibid., 235-236.

[xviii] Nichols Deposition, ibid., 240.

[xix] D. K. Huntington Mss., Western Reserve Historical Society.

[xx] Haines Deposition, O.R., 1, XLIII, Part 2, 244-245.

[xxi] Campbell Deposition, ibid., 237.

[xxii] “Northwest Conspiracy,” 700.

[xxiii] Nichols Deposition, O.R., 1, XLIII, Part 2, 241.

[xxiv] Campbell Deposition, ibid, 238.

[xxv] Nichols Deposition, ibid., 241.

[xxvi] Ibid., 227.






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Revised: 01 Mar 2011 20:19:17.