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The original document is part of the Missouri State Archives St Louis Circuit Court collection.
This electronic document is published as part of the St Louis Circuit Court historical records project.
The original document is part of the Missouri State Archives St Louis Circuit Court collection.
by
State of
Ss.
on this reading and
of
and an
a poor person. Ordered also that the said
counsel and the Court as
that he be not
this our
and that he the said
to
for freedom Ordered also that the Sheriff of St
Louis County take
Foy and hire him out to the best advantage from
time to time during the
suit and take
to the state of missouri in the penalty of one thousane
dollars
attest
Excuted this writ in the
on the
to read it and the order of the Judge to
hear, and by delivering to said defendant
a time copy of the petition hereto attached
We command you
that he be and
before the Judge of our
next term thereof, to be held in the
within and for the
day of
annexed.
And have you then there this Writ.
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The original document is part of the Missouri State Archives St Louis Circuit Court collection.
I
manner and form following that is to say
First I desire, that out of my Personal Estate that my
Second I will and bequeath to my Daughter
aged about 14 years also one negro girl named
about 17 years also one negro girl named
Third I will and bequeath to my son John Buckner Brown
one negro woman named Mill aged about forty eight years
also one negro man named Amos aged about 21 years also
one negro
his heirs forever
Fourth I will and bequeath to my son
Negro man named
woman named
also one Negro girl named
one Negro girl named
heirs
Fifth I will and bequeath to my som
one negro
85 Dollars money that I
16 years ago to him & his heirs forever
Sixth I will bequeath to my Son
Negro man named Sandy aged about 20 years also one
negro Bay named Luke aged about 13 years to him & his heirs
forever
Seventh I will and bequeath to my Grand Children to wit:
Adaline, Buckner, William, Charles, Virgil and Narcisson
being all the Children of my son
tract of Land on which
and ninety two
bequeath to my said Grand Children above named Children
of my said son Thomans F Brown
named
aged about 16 years also one negro Boy named
about 13 years also one negro Boy named
years
to them & their heirs forever
Eighth I will & bequeath to my Daughter
wife of John
Ninth I will and bequeath to my grand Children
Daughter
years also one Negro Boy named
to my said Grand Children & thier heirs forever said Negroes
Tenth I will and bequeath to many in
of seventy five Dollars to be paid out of my Personal estate
Eleventh I will and bequeath the
forever one fifth part thereof to my said son John Buckers
personal estate I will & bequeath to my
was given to my said two sons in consideration of my said
sons
Sum of money Joseph Brown others of my said son
one fifth part of my estate above above mentioned should not be
sufficient to pay and discharge the
&
will and Desire that my son
ing slaves David &
as
slave are to be the property of the said Children of said
12
I have
praised
13th I hereby
of this my last will and testament.
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The original document is part of the Missouri State Archives St Louis Circuit Court collection.
At an intermediate
of Law and
Thursday the
and
& recorded as the last will and
A
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On motion of Elizabeth Brown Widow of
Guardian for Adaline Brown,
William T Brown
& Chloe
of
said
accepted of said appointment and entered
into Bond in the penalty of $ 2000 Dollars
conditioned
following Justice composing the court
A copy
I
of
that the above is a true copy taken from
of the said Court In tesitmony where of I have
hereunto set my hand and the
seal of the said Court this
I
of the peace in and for the county of
state of
of said county and that the within
form of Law and by the proper
due faith and credit
to
I have hereunto set my hand and seal
this
"A"
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To
day
whereas complaint has been made before
me the undersigned Justice of the Peace that
a
patient Examination of the charge a
gainst said
hibited before me it appears the said
Negro is the property of the
you to convey and
slave to the heirs of the said Thom
as F. Brown or to the persons entitled
to the case of said slave, or to the
keeper of the common Jail of
County, and you the said keeper are
hereby commanded to receive the
body of the said
tain him
shall take him
lawful changes, or until he be oth
erwise discharged according to Law
Given under my hand this 13th dy of December
vs
Warrant
Officer
We claim all Lawful fees
for arresting & committing
said
slave
Executed this writ by delivering the body of
the within named
County, done at the City of
on the
fee 75
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vs
David
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personally
in and for the
Sworn says, that on or about the
December 1849
arrested a Negro man who called
say which he has good reason to belive
and does belive the said Negro is a
ponent saith not
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There was committed to the common
on the
a justice of the peace in and for said county as a
the upper font teeth as
had on when committed
is suppossed to belong to the heirs of
of
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The original document is part of the Missouri State Archives St Louis Circuit Court collection.
There was committed to the Common jail of St Louis County
on the
a justice of the Peace in and for said county as a run away
slave a negro man who calls
scar over the right eye- has
has a wide space between the upper front teeth as though
one was out had on when committed blue cloth coat
and pants- black wool hat
to belong to the
First advertisement by sheriff is same as within, except that
he is then called "
estate he belongs- and that after the
advertisement, thereis added in first the
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The petition of
Sheweth
That he the said
that he was born a freeman in
in the
entire life been a freeman of
has and herewith submits affidavits establishing
his citizenship according to the statute requirment
of the state of
man calling himself by the name of
arrested and taken before
of the justices of the Peace & c to whom the said so
called
was the property of the Heirs of one
the administraiton of the estate of the said
F Brown that your petitioner was a runaway
slave and that he had ran away from
that thereupon & at the instance of said
of St Louis County as a runaway slave. That
it is the intention of said
petitioner off out of the state & take him or sell him
into bondage and that he your peition is
of commencing a suit for his freedom
And your petitioner further showing that he
is a poor man and unable to bear the expenses
of bringing and prosecuting a suit or action
against the said
Court to grant him permission to sue as a
poor person, and to secure to him such rights
and priveleges as may enable him to prosecute
successfully a suit for his freedom against
the said
that an order may be granted restraining him
the said
petitioner from the state of
jurisdiction of this
your petitioner being restrained of his reasonable liberty
in attending his counsel & this honorable court and that
an order may be made placing him your peti
tioner in the care & possession of the sheriff of
St Louis County the said
being a non resident of the
souri.
The above named
Foy being duly sworn says that the above
petition and the matters and things therein
state are true
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On the reading and filing the petition and affidavit
of
color and an due consideration thereof
Ordered that the said
commence and prosecute the action mentioned
in said petition as a poor person
Ordered also that the said
ble liberty to attend his counsel and the court, as
occasion may require; that he be not removed
out of the jurisdiction of this our
cuit Court for St Louis County; and that he the
said
on account of this application for freedom.
Ordered also that the Sheriff of St Louis County
take possession of the said
him out to the best advantage from time to
time during the
and take a
dollars- in such form and
So conditioned as directed by the statute in such
cases made and provided
Order
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in a plea of trespass for that the said
ber A.D. 1849
Louis state of missouri with force and
arms assaulted the said
and him then and there arrested or caused
to be arrested taken and impresoned
and restrained of his liberty and held
or claimed to hold him the said
estate of one
said estate, he the said
claimed to be the administrator against
the law of the
of the said
the peace, he the said
being as he was
of his said arrest & imprisonment a
free person and that he was then and
is now a freeman of the state of
and that the said
still holds him the said
Slavery and thereupon he
David McFoy
vs
Declaration
P. A
atty for plff.
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Your petitioner respectfully represents
that a certain slave, by
belonging to the estate of
of
is administrator and agent for the heirs of this
estate, and
Estate, is illegally confined and kept from
the Custody of your petitioner in the St Louis
County jail by virtue of a
and within the county of
a
refered, on the
That said slave according to law ought to be
delivered to your petitioner and not confined in
jail. He therefore prays that the writ of Habeas
Corpus
and
things in the above petition stated are true.
Sworn to and subscribed
this
before
To the Jailor of St Louis County Jail
you are here commanded to have the body
of the slave
before me at the county Jail on this
Dec: 1849
and the law may be
Sworn and subscribed to
before me this
of December 1849
David Chambers
In obedience to the command of the above writ
I have here the body of the above named negro
on warrant from justice Johnstone, which
warrant is hereto annexed and made apart of
this my return this
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vs
Motion to
Filed
Atty: for Dft
And the said defendant by his Atty
brought to
said plaintiff into the
the following reasons: first, because said
against the law and equity in and cases made and
instructed because the petition is not sworn to according
to law, and no costs for security given as
statute; also because said suit is
Term of this court because said suit is brought
with no
of delay and
a
that said plaintiff is
because said defendant is entitled to the
of said plaintiff as guardian of
others and as administrator of the estate of
in the capacity aforesaid has fully complied with
the statute in such cases made and provided and
is still ready and willing to show to this honorable
court by
that he is
as a slave as aforesaid to wit as a slave of
in the state of
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Before
Justices
was brought before the undersigned
Justice a Negro Man calling himself
gro
that he knows the Negro
he knew him in
to be a slave and that he is the property
of the heirs of
he is not mistaken in his identify that
be knows him from his general ap
pearance his size and face, and from
his voice is positive he cannot be
mistaken
the administrator of the estate
tate further than being administrator and
has known him since he was four
years old - he is a slave and belongs
to the estate of Thomas F. Brown late
of preston county
said Negro man
about two years ago for the benefit of
said estate and that he ran away from
service I have no knowledge of any mark,
upon him - I know him well he has been
under my
next
not be mistaken in the man for I have
known him from his
now about 40 years of age - if he has
any marks he has got then since he ran
away - I know I cannot be mistaken
for he was rasied with me and I know
him as well as I know any of my
This Negro was willed by
and I am
Officer Williamson
as soon as he saw him when he was
arrested at his instance
I
do hereby certify that the above is the
evidence produced before me an the
arrest of the Negro man
upon which evidance I gave an order
to the office to deliver up the said
slave
him in the said of
subjected to his order he paying all law
ful
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You are hereby commanded, that setting aside all manner of excuse and delay, you appear be
fore our
testify and the truth to say in a certain matter of controversy now pending in our said Court,
wherein
plaintiff and
defendent on the part of
and herein you are in nowise to fail.
vs
for
the day police
Excuted
Louis
By Leon
Service = 50cts
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The original document is part of the Missouri State Archives St Louis Circuit Court collection.
Take Notice, That on the
year of our Lord one thousand eight hundred and
at
depositions will be taken by the undersigned, to be read on the trial of the above entitled
case, on behalf of the
completed on that day, will be continued from day to day, at the same place, and between
the same hours, until completed.
To the above named Attorney
P. A.
Served this notice in the
to P A
plaintiff.
By
Service = 50 cts
paid by atty for deft
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The original document is part of the Missouri State Archives St Louis Circuit Court collection.
Know Ye, that we, in confidence of your prudence and fidelity, do, by these presents, au
thorize you to cause to come before you, to be examined as witnesses in a cause depending in our
is defendant, all
and every such person, and at such time and place, as shall be named to you for that purpose by the
said
Attorney or Agent. And we command you to examine all and every such person upon his oath or
solemn affirmation first made or taken before you, to testify the whole truth touching his knowledge of
any thing relating to the said matter in controversy between the said parties; and that you do take
such his examination, and reduce the same into writing. When you shall have so taken his examination,
you are to cause the witness to sign the same, and to that and each examination, at the foot thereof, you
are to append your certificate, setting forth the facts that the examination was subscribed and sworn to
or affirmed by the witness, and the day, as well as between what hours of the day, on which it was
done, as also the place of residence of the witness, if known to you. Should any paper or exhibit be
produced or proven, or referred to by the witness, you are to describe the same in his examination, or
cause it to be so marked by him, as to establish its identity,and attach the same to his examination.
The examinations thus taken you will cause to to be accompanied by a certificate of your official
character, attested by the seal of State; or,should it be more convenient, such authentication and proof
of your official character may be made by the certificate and seal of the clerk of any court of record
of any county of the State, District or Territory in which you reside, stating also, in addition to the
facts of his beging clerk and that the court is one of record, that, at the time when the depositions were
taken, you were an acting judge,(or other such officer to whom this commission is addressed,) and
duly commissioned as such. And you will eturn the same and all exhibits produced to you,annexed
hereto, carefully closed up amd under your seal, directed to the Clerk of the
the
convenient speed.
McFoy
vs
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No 37
vs
Plff asks
Commission to lake
Depo
P.
atty for plff.
The plaintiff by his attorney
at this day comes and prays the court that
a commission may be issued to take depo
sitions in this cause on the part of the plain
tiff in the
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The original document is part of the Missouri State Archives St Louis Circuit Court collection.
the above named
witnesses to be read on the trial of the above cause on behalf of
Arthur,Esq in the city of
on the
thousand eight hundrerd
in the forenoon and
deposition, if not completed on that day, will be countinued from day to day at the same place, and
between the same hours, until completed
Served this notice in the
February 1850
copy there of to C E
vs
Notice to take Depo
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The original document is part of the Missouri State Archives St Louis Circuit Court collection.
Also
being duly sworn deposeth & says. he has known
ed to the
and State aforesaid it has been about 2
years & 6 months
says
when talking & when walking
on his
an open space in his upper front
a thick black beard- & was a dark
color- & he could read very well- says he
was about 5 feet 10 or 11 inches high &
was thin
And further says. that
of said
And further this Deponent saith not-
I certify that the above deposition was sworn to
and subscribed by Alexander Turner or the Court
House in
about the hour of 2 O clock P M of the
day of April 1850
county
Thomas Cartwright called again & sworn says-
that the got the scar on his Knees & legs by
off of a
fall of
this Deponent Saith not-
I certify that the above deposition was sworn to
and subscribed by
House in
about the hour of 2 O clock P M of the
day of April 1850
County
Also
sworn deposeth and says I have known
or more. & that he belonged to
he was a dark copper color with
front tooth And further This
I certify that the above deposetion was sworn to & subscribed
by
Monday the
Also came
duly sworn deposeth & says- I have been
with a negro man named
says
& was
there was a considerable space between his upper front
teeth, witness says that he knew
of
has a long
& when he walked his head
I certify that the above deposition was sworn to and
subscribed by Henderson B
in
of 3 O clock P M of the
Witness
my hand This
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The original document is part of the Missouri State Archives St Louis Circuit Court collection.
Also came Ashford Brown of full age who being duly
sworn deposeth and says- I have known a black
belonging to
said negro then called himself David
known by the name of
thinks he was about 5 feet 11 inches high & had a
witness says he understood
negroes of
had a
side of his hand. Witness supposes
Witness says he knows of
of said
a good opportunity of
defenitely how long- Witness sys
quick speech &
And further this deponent
I certify that the above
subscribed by Ashford Brown at the Court House
in
of 3 O clock P M of the
under my hand
Also
sworn deposeth and says- I have known a negro
man named
of
until the time he ran away
5 feet 10 inches
upper front teeth
a scar above his right eye & a Scar on his head
and slender
years witness also says that
wards took said negro & was oveseer
11 years & was well
could not
he had the best of opportunities of
and further this deponent saith not-
I certfy that the above deposition was sworn to
and subscribed by
at the
of April 1850
county
I
in the state of
that
such and that the foregoing signatures are his
Presence
In testimony whereof I have hereunto set
my hand and affixed the seal of said Court
at
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The original document is part of the Missouri State Archives St Louis Circuit Court collection.
You Are Hereby Commanded, that setting aside all manner of excuse and delay,
you appear before our
of March 1857
testify, and the truth to say in a certain matter of controversy now pending in our said Court,
wherein
plaintiff and
defendant on the part of
and herein you are in no wise to fail.
vs
for dft
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vs
Mo. to Suppress
depositions
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The
by me
peace in and for the
and state of
house in the town of
county aforesaid by virture and in per
suance of the
and notice said depostitions were severally
taken he
A.M. and five O clock P M. on this
the
ositions to be read on the trial of
the cause of
iam
uis state of
duly sworn who deposeth and said that the
witness was acquainted with a black
man called
of said
heirs of
the will of said
true copy of which is hereunto
marked A. David named in the
provision of said will was at the date
of said will about 36 years old fine
but some ten or eleven in his high
he had a
and had a space between his
away since which witness knows no
thing about said negro
and further saith not
I do certify that the above deposition
sworn to and subscribed by said
of ten o clock A.M on the
of April 1850
the county court of
and resides near the said town of Knig
wood witness my hand this the
April 1850
Then
duly sworn deposeth and says he has been acquainted
with black man named
before his death
space in his
walk says
5 feet ten or eleven inches
head
and wrote a tolerable
was hired to a man by the name of
to one
and 6 months ago. And further this Deponent
I do certify that the above deposetion was sworn to
and subscribed by said
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Court House in
about the hour of 12 O clock
April 1850
State of
1850
Also came. Thomas B. Johnson of full age who being sworn
deposith & says- he has been acquainted with
owned at the time he ran away by the
F. Brown some 40 years past. he
over his right eye he is a
he had an open space in his upper front teeth
& had a dark
about 5 feet 10 or 11 inches
that
And further this Deponent saith not
I do certify that the above deposition was sworn
to and subscribed by said Thomas B Johnson
at the
on the
on
Given under my hand
1850
Also came
duly sworn depsith and says, he know
12 years age said
hired to
and that he knew nothing of him from the
ran away till the 13 day of
he saw him working on the
manners
he told witness that he
slave, as stated by the officer who arrested him &
witness says he was arrested as the slave of Thomas
F Brown's
said he would be a good slave. and work out his
time- witness says when he was
& further this Deponent saith not-
I certify that above deposition was sworn to and
by
of the
hand
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Know ye, that we, in confidence of your prudence and lidelity, do, by these presents, authorize
you to cause to come before you, to be examined as witness in a cause pending in our
for the county of
and every such person, and at such time and place, as shall be named to you for that purpose by the
said
Attorney or Agent. And we command you to examine all and every such person upon his oath or
solemn affirmation first made or taken before you, to testify the whole truth touching his knowledge of
any thing relating to the said matter in controversy between the said parties; and that you do take
such his examination, and reduce the same into writing. When you shall have so taken his examination,
you are to cause the witness to sign the same,and to that and each examination, at the foot thereof, you
are to append your certificate, setting forth the facts that the examination was subscribed and sworm to
or affirmed by the witness, and the day, as well as between what hours of the day, on which it was
done, as also the place of residence of the witness, if known to you. Should any paper or exhibit be
produced or proven, or refferd to by the witness, you are to describe the same in his examination. or
cause it to be so marked by him, as to establish its identity, and attach the same to his examination.
The examination thus taken you will cause to be accompanied by a certificate of your official character,
attested by the seal of the State; or, should it be more convenient, such authentication and proof of
your official character may be made by them by the certificate and seal of the clerk of any court of record of
any county of the State, District or Territory in which you reside, stating also, in addition to the facts
of his being clerk and that the court is one of record, that, at the time when the deposition were
taken, you were an acting judge, (or other such officer to whom this commission is addressed,) and
duly commissioned as such. And you will return the same and all exhibits produced to you, annexed
hereto, carefully closed up and under your seal, directed to the Clerk of the
the county of
convenient speed.
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To The Above Named
witness to be read on the trial of the above cause on behalf of
Arthur esqr in the city of
of
on the
thousand eight hundred
in the forenoon and
depositions, if not completed on that day, will be continued from day to day at the same place, and
between the same hours, until completed,
vs
Wm Brown
Notice to take Deft
Served this Notice in the
this
a true copy thereof.
50
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To The Above Named
You are hereby notified that depositions of
witnesses to be read on the trial of the above cause on behalf of
Robert
and state of
on the
thousand eight hundred
in the forenoon and six
depositions, if not completed on that day, will be continued from day to day at the same place, and
between the same hours, untill completed
vs
Notice to take
Depos.
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The defendant states that he did cause the above
plaintiff to be arrested and imprisoned and
of his liberty on the
at the city and county of
claim the said plaintiff to be the slave of
the estate of
the said defendant is is administrator, and
of the minor
to wit, that he is
Brown
Brown, that he the said defendant was appointed
Term of the County Court of
state of
October 1844
copy of his appointment filed with this answer
and marked (A) that said
slave of said minor children aforesaid and that
he the said defendant has the control of him
the said plaintiff as administrator of the estate
of
of the children aforesaid, that said plaintiff
a slave for life was
by will
that said plaintiff is not and never was
a free person that he the said plaintiff is not
was a freeman of the state of
the county of Prince
and run away from service from the County of
to the laws of the
a slave for life and is the property of the afore
named
claims control and
by his
57
vs
Answer of Dft
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You Are Hereby Commanded, that setting aside all manner of excuse and delay,
you appear before our
tify, and the truth to say in a certain of controversy now pending in our said Court,
wherein
pliaintill and
defendant on the part of
and herein you are in no wise to fail.
McFoy
vs
Excuted this writ in
the
this
1857
the within named
is
the witnesses live at william was about a half
This electronic document is published as part of the St Louis Circuit Court historical records project.
The original document is part of the Missouri State Archives St Louis Circuit Court collection.
I
Pleas in and for the County of Allegheny in the Commonwealth of
presents certify, that
Esqurie, before whom the foregoing
taken, and who has thereunto, in his own proper handwriting, subscribed
his name, was at that time, and now is,
an acting Justice of the Peace, in and for the said county, duly commissioned and sworn, and authorized
by law to
such, due faith and credit are, and of right ought to be given, throughout the
elsewhere.
In Testimony Whereof, I have hereunto set my hand, and affixed the seal of the said Court,
at
in the year of our Lord one thousand eight hundred and fifty
ereignty and independence of the
Attest:
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The original document is part of the Missouri State Archives St Louis Circuit Court collection.
Deposition of witness produced sworn and
examined before N. Buckmaster an Alderman in
and for
9th and 10th of May between the hours of eight
O C. in the forenoon & six O clock in the afternoon of said
days in pursuance of a notice proceeding out of the
the Defts. atty and which is hereto attached to be read
in the trial of a cause depending in said Court
in which
is Defendant on the part of the Plaintiff.
John
and of lawful age- & who resides in
city being by me first duly sworn doth depose
and say-
I am fifty five years of age- and
am acquainted with a
a child- I should think be was about four
years old when I first knew him he was born
in the State of
His
Lizzy
fathers name was
freeman also- I was well acquanted with
the whole family-
about twenty five years ago- The Plaintiff
County until about five years since- when
he removed to
as a fireman on Steam Boats- While the Plff.
bore a good character & taught school he came
there highly recommended- he taught a coloured
school- I should think he was about
forty years old- I should think that he
is about six feet high- rather spare build
his colour a dark brown- clean
I mean by dark brown- That he was of
or negro
of
two years since I saw him- he was then
running on a steam Boat I think as a
fireman - I know that he was a
freeman & never was a slave. and further
Sarah Scott of lawful age being first duly
sworn doth depose & say
I am about fifty two years
of age and live in the seventh ward
of the city of
six years or thereabout- He worked a good
deal for me in chopping wood & forming
business- I always understood that he
came from Westmoreland County
He always
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The original document is part of the Missouri State Archives St Louis Circuit Court collection.
as a freeman- had no actions like a slave-
after he quit working for me he went upon
the
with my sons who run on the River as
fireman also - He run on the north river & the
American star- and other Boats- Which I dont
remember- I should think it was about
two years since I saw him- The Plaintiff
or may be a little over-
to his
shouldred- his colour was dark- was little
burned in the face with powder which made
some spots on the face darker than the general
colour- was darker about the eyes- His age
I should judge to be forty or
year or two over that- There are some
scars about his head- and little bald headed
a scars over one of his eyes- cant now remember which
eye- some scars on the back part of the head & I
think some on the front- He was always con
sidered & reputed to be a freeman -
amd further this deponant saith not
till the 10th
an account of the inability of the
I am fifty four years of
age and reside in the seventh ward, city of
the Plaintiff- I have known him for about five
years- When I first knew- him he was living in
the country with
farm about three years ago, he came to the
city & I employed him in the business of
washing & smoking meat He had
the city before this- I think he worked
four or five weeks for me that season and
the next season I employed him again
after he left work for me he went to work
on a steam Boat- I think it is going on
two years since he left me and went down
the
came to me as a freeman- and always
as such- and I never heard any thing
to the
of his bring in prison- I should consider
that he was six feet high
man- he was rather a brown coloured not
black - rather round or
when he walked- I should think him
of age
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The original document is part of the Missouri State Archives St Louis Circuit Court collection.
I
in & for said city & Ex officeo a Justice of the
Peace in & for the County of
hereby certify that the foregoing witnesses were by
me duly sworn to testify the whole truth touching
their knowledge of
matter in controversy and that
was taken down in writing, at the time, be me
they did, after hering did read over to them, sign
their respective depositions in my presence.
In testimony whereof I have hereunto set my hand
and seal this
I
President Judge of the Court of Common Pleas
of Said County do hereby certify that George,
J.
and was as the time of making the same
of the said Court of Common pleas.
In testimoney whereof I have hereunto
subscribed my name this
day of
vs
Mr
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The original document is part of the Missouri State Archives St Louis Circuit Court collection.
Now at this day comes the plaintiff
and moves the court to suppress the
depositions so called claimed to have been
taken in this cause by defendant for the
reasons:
1. That there was no notice, as required by law
of the time and place of taking the so called
depostitions served upon plaintiff or his
attorney.
2.That, Plaintiff had no sufficient notice
of the taking said so called depositions.
3. Because the certificate of the officer before
whom the so called depostitions
have been taken is not
4 Because the so called depositions were
not reduced to writing
ed by law
cer taking there
taken in accordance with the law.
5 Because the witnesses were not sworn or
affirmed in accordance with the law