Question. Was it practicable for the enemy, after the forts had been passed, to transport is army through these bayous and canal to New Orleans without encountering the forts?
Answer. It was practicable to do so. A portion of the enemy did come that way after his fleet passed the forts.
Question. How long have you lived in that country,and what was the state of the river at that season compared with others years?
Answer. I have lived in Louisiana upwards of a quarter of a century, and for many yards owned a plantation 15 miles below the city. I was very familiar with the whole country. I never have known the river so high as it was that year.
Question. What was the condition of the country above the forts for 30 or 40 miles in regard to the overflow?
Answer. On the left bank of the river the whole country was one vast sheet of water from the river to the Gulf, commencing at Point a la Hache, about 40 miles below New Orleans. On the other side the country was not overflowed, but, on account of the high water and the transpiration resulting therefrom, the road (there being but the one) was impassable. The country was such that when the river was high no earth could be had for a levee in the rear without letting in water from the gulf. In the front an alluvial mud from the river, when low, might be had for levees. While General Lovell was in command at New Orleans the water was high, and no earthworks could be put up in that neighborhood. Even at Fort Jackson, at the time of the bombardment, the water was from a foot and a half to two feet deep.
Cross-examination by the JUDGE-ADVOCATE:
Question. State the reason for the surrender of yourself and a portion of your command.
Answer. When the forts were passed, just about break of day, the fleet came upon my small camp and opened fire. After losing some 30 men killed and wounded, without a possibility of escape of rescue-perfectly at the mercy of the enemy, he being able to cut the levee and drown me out-I through it my duty to surrender. A single shell could have cut the light embankment.
Question. Could not earthworks have been pu up on the river banks a distance of 20 or 25 miles below New Orleans?
Answer. They might have been put up at English Turn, a commanding position, where the river makes a sharp turn, commanding, not from its height, but from the course of the river.
Question. State the elevation of that point above the water in high stages of the river.
Answer. It was not more than 6 inches above high water, but the ground was firm, and would have supported heavy works.
Question. Is English Turn above the debouches of the bayous and canals through which the enemy might have turned Forts Saint Philip and Jackson?
Answer. It is; but there is above that point water communication through Lake borne with the Gulf of Mexico by other bayous and canals of the same character, principally by Bayou Bienvenue.
Examination by Major General M. LOVELL:
Question. In that high stage of water, during the year 1861, was not the river higher than the surface of the country below New Orleans? If so, state about how much.
Answer. It was, varying in depth from 2 to 14 feet.