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The original document is part of the Missouri State Archives St Louis Circuit Court collection.
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The original document is part of the Missouri State Archives St Louis Circuit Court collection.
Plaintiff states that she is
a free woman of colour and that she is a
free person and entitled to her freedom for the
reasons herein after stated to wit
That
many years ago when she plaintiff was a
child the exact time she does not know that
she was the slave and belonged to a man
named
who was
that her said master and owner removed from
the
took her the plaintiff with him and there
continued and resided permanently in
said
keeping plaintiff in his possession at his aforesaid
residence in the
Plaintiff Claims that on account of her
said residence in the
is entitled to her freedom and that she is a free
person. Plaintiff states further that after
her said residence in the
she was carried back by the said
the
and was put in the possession of one Bryson
Stilwell who brought her to this State where she
had been but a short time when she was sold by
the aforesaid
negro and slave trader and dealer and she was
immediately shipped by him the said Owsley from
city of Hannibal in this State to the city of
trader and dealer plaintiff being then ignorant of
her right to freedom and that she was a free person and
upon its being made known to said Butler that
the plff was a free person he sent immediately
back to Hannibal where she removed sometime
and the contract for her sale having been
as she was informed, she was again sold by said
to one George. W. Harris and by
Owsley who sold & sent her to Dr. Bonnett of
and since the sale to Dr. Bonnett she the plff
has been put in possession of Lynch and
Tooley & the defendant in this suit who now has
her in possession and holds her as a slave and
various other persons all negro and slave traders
and dealers and to all of whom except the deft
in this suit plff has been informed she had been
sold and pretended sales all being made with a
view as plff believes to annoy and perplex her and
thereby make her abandon her suit for freedom
against the aforesaid
the suit has been dismissed by her attorney
at Hannibal in the Court of common pleas of said
order of Plff where suit had been commenced
against said
no certain knowledge of who is now her pretended
owner and master brings her suit against
defendant who now holds her in possession as
a slave as aforesaid.
Plaintiff also states,
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that she has received much other bad
treatment and abuse from some of the
persons who have had her in possession
such as confinement in their negro yards
or jails and while in said yards or
jails refusing to let her all her
Plaintiff also states that she has two
children one about three years old
named
about six months old named
both born since the time at which she was
brought to this State by the aforesaid Bryson
Stilwell which children and as she believes entitled
to freedom and are free because she was a
free person herself at the time said children were born and the aforesaid children
are now in possession of and held as
slaves by the defendant in this suit and
the plaintiff asks for her children as well
as herself the tender consideration of the
Court and that such order and proceedings
be made and had in the premises as to the Court may deem
fit and proper.
And plaintiff now asks for
herself and her said children in consideration
of their many wrongs and grievances and their
so ignorant and unprotected
the tender consideration of the Court and that
that herself and children be declared free and
released from the claim or claims of all
persons whatsoever to their services of that
of others of them and that they be and are free persons
of colour.
Your petitioners
children
state that they are free persons of colour and
now held as slaves by
the city of
and she
against said
and her children and that she & they are poor persons
without any property or means of any
kind and therefore she prays the Court for
leave to sue for the freedom of herself and children as poor
persons according to the statute in such
cases provided.
Personally appeared before me this
who being duly sworn says that the statements in the above petition are true.
It is hereby ordered
that the above and within named
a woman of colour for herself and children
of herself and her said children without giving any security
for costs and that she have reasonable liberty
to attend her counsel and the Court as occasion
may require and that she and her children be not removed out of the Jurisdiction of this Court and that
she be not subject to any severity on account
of her application or suit for freedom
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makes oath and says that he believes the
above and within petition and the matters
as therein stated are true.
Sworn to and subscribed before me
this
& official seal.
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And that the above said woman
and her children
before me at on the day of
woman of colour
& Children
Against
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Dismissed
and children
to sue for the freedom of herself and
said children without giving Security for
Costs and that she have reasonable liberty
to attend her Counsel and the Court
as occasion may require and that she and her children be not
removed out of the Jurisdiction of this Court and
that she be not subject to any severity on account
of her application or suit for freedom
5th 1850
Executed this writ in the county of
this
and further executed this writ by offering to
and the order of the
We command you to
to
before the Judge of our circuit court on the first day of the
next term thereof to be held in the city of
within and for the
day of
And have you then there this Writ.
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Defendant demurs to the petition of plaintiffs
because there is a defect of
In this that the suit is brought by plaintiffs
jointly whereas they have as petition shows
no joint or common interest in each others
freedom that is to say in the cause of action
set forth in the Petition.
Demurrer to petition
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Defendant admits that plaintiff
is a woman of color, but he utterly denies
that she is free or ever was free.
no knowledge sufficient to form a belief
to whether
or as to whether she was taken back again to
He admits that said slave was brought
to this State but he does not know when or by
whom.
And as to each one of the other allegations
in said petition defendant says that he
has no knowledge thereof sufficient to enable
him to form a belief.
Launcelot H. Calvert above named plaintiff,
being sworn on his oath says he believes the foregoing
petition, & the matters therein, as stated, are
true.
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Plaintiff
amends her petition as follows viz -
By striking from the petition the names
of her two children
and presenting this suit henceforth in her own name only.
She also adds to her
petition the following
Plaintiff states that before and at the
time of the committing of the grievances
in the petition named, she was and
still is a free person, and that the
defendant held and still holds her in slavery.
Filed
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Depositions
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You are
hereby notified that depositions to be
read in the above entitled cause will
be taken at the office of
in the town of
and state of
September
the forenoon and six in the afternoon
and will if necessary be continued from
day to day until completed.
Service of the within notice
to take depositions by receiving a
copy of the same, acknowledged
Notice to take depo
case of
vs
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1st
Depositions of witnesses produced
sworn and examined at the town of
and
. W. Richards a Justice of the peace
within and for the County and
State aforesaid in a certain
case now pending in the
the
a woman of color is plaintiff
and
and for said plaintiff in pursuance
of a notice hereto attached and at
the time and place therein mentioned.
P H Hastings Atty for plaintiff
and Thornton F Marshall Atty for Deft
present
the
sworn by me as hereafter certified deposes
as follows
Question by plaintiffs Council
state what you know about a colored woman
named
in the County of Brown in the
Answer
I did know a colored girl who lived
in
of
Question by same----State when
and how
and how long
she
Answer.
about the year
could state who brought her there
She came
to
She remaind in said
State between one and two years immediately
following the removing of said
Question by same Did said
live with and in the family of said
during the time
or two years above mentioned.
Answer.
of
as a servant and
lived in
Question by same.
State how long
he came from when he came to
Answer
from the
Question by same ----- When you speak
of the time said
of said
Answer.
I did
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3rd page
Please state how old you think said
to
Answer
I think
and fourteen years old from her appearance
and size.
Her colour is what I would call
a dark copper colour not Black or yellow
Question by same - Did you ever see
said
Answer
I seen said
the family of said
Question by same - How long has
it been since you have seen said
Answer
It has been between six and seven years
The Deft atty comes and objects to the foregoing
interrogatories because they are leading and otherwise
illegal
Question by atty for Deft - Where you acquainted
with
to the
immediately preceding his removal to
Answer
I was not acquainted with
I never had seen him.
By same - Where you acquainted with this
negro girl
to that time, if so when?
4
Answer, I was unacquainted with the girl
and never seen her until she came
to the
By same - Where did you reside during the
years of
Answer
I resided on the farm of
Martins about a mile and half from the
I was farming
By same.
How did
to the state of
if by steam boat what was her name &
about what time in the day or night did
she land him in said state.
Answer
He came to the
Steam Boat Maysville Packet down the
River between twelve and one o clock
in the day
By same - Did any person besides
and family get off of the boat on said occasion
and if so who.
Answer
There was several of
that I do not know who got off of the
boat.
By same - Do you know whether
was brought to the
above alluded to by coercion or voluntary
or how or by whom she was brought
here. Answer I do not know She
came with
he brought her to
By same - What were you doing at the steam
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(5)
boat at the time referrerd to - had you business
then if so what business had you.
Answer
I has no particular business but was down there when the steam
boat came.
By same - What was the height of
when she first landed in
time spoken of.
Answer
and a half high when she landed
By same - When you well acquainted with
her after she came to the state of
you frequently see her during that time.
Answer
I seen her frequently
By same - What was her size when you
saw her last.
had she any blemish or marks
either upon her face or person.
Was she delicately
made or would you know her if you
would now see her.
Answer
She was perhaps a little over
She would weigh about one
hundred and thirty lbs.
I do not recollect
of her having any scars about her.
I think
I would know her now.
By same.
How long was it after
saw her last, and was she then
Answer
I think it was near two years She was grown
at time.
6
By same.
State as nearly as you can her
weight when you last saw her
Answer
I suppose she would have weighted
about a little over one hundred and thirty
By same
Where you in the habit of
visiting James Bowd's family or his house
after he left the state of
Answer
I frequently visited his house while he lived in
By same
Has
negroes besides
their names.
Answer
He has one negro woman and
a child besides
eight years old
I do not recollect
the names of the woman or child
By same Was there any other negro or negroes put off of the Maysville
packed in the
Bowd's family at the time you have
stated that
Answer
There was one negro woman.
I do not know her name.
By same Have you had any conversation
with the counsel for the plaintiff or any other
person in relation to said negro woman
you been shown any written questions upon
this subject.
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7
Answer
I have not talked with any
person about the negro girl recently>
I have been shown the old depositions.
By same
You state you have had
no conversation recently in regard to
said negro, have you had at any time
if so when and with whom and what do you mean
by old deposition.
Are they depositions
of others taken in regard to this same
negro at some previous time
Answer
I have talked with different
persons about the negro woman have talked
with Mr. Hastings today.
The depositions referred to were the depositions
taken before about the same woman
and showed to me by Mr. Hastings the
attorney in this suit for plff.
By same You have stated
in your previous answers that you
were well acquainted with said negro
woman
house and family. Now please state in
what manner said negro was employed
and whether she was active, industrious
and sprightly or what her habits were.
Answer
She was employed part of the time as
a nurse part of the time in the kitchen.
She was a keen looking girl pleasant looking
with a smiling
was
By same,
was of was of industrious or indolent
Answer
I
industrious
By same- was she healthy & stout or
was she delicate & frequently sick?
Answer
She was generally healthy when she was grown up she was stout & healthy
By same- You state
negro
with
came to said
height,
your
not from what others have told
and her name:
She would
one hundred and forty ponds she was
was
was about twenty years old from her
appearance -
By same- How long did the
woman live with
Answer -
She lived with him about
or
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(9)
By same. How do you know where
came to the state of
Answer
He told me they came from Louis
County
Witness
Question by Plaintiffs counsel
State if you know
color plaintiff in this case if so where
and how long and under what
circumstances
Answer
I know one
color lived in the family of
I do not know whether she is the
plaintiff in this case or not.
I knew her about the year
and two years.
She lived in the family
of
Question by same
State what you
suppose the age of
living with
describe her size and appearance.
Answer
From her size and appearance she was about twelve or fourteen years of
age. I think she was about four feet and a half high. Her colour was what I would
call a dark copper colour.
(10)
Question by same
When you speak of said
woman living with
one to two years do you mean
the whole time she
or only the time she was with
him in
Answer
Only the time she was with him
in
Question by same
Do you know of said
in the state of
how long and under what circumstances
Answer
I do know
two years after she left
him as a servant girl.
Question by same
Did
with him to the state of
Answer
Yes he took her with him to the
state of
Question by same
in the state of
say said
Answer
In
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(11)
Question by same
Where were you living
at the time said
Answer
I was living on the farm of
half from
Question by same
Who brought said
state of
Answer
I do not know who brought her
She came in the family of
Said
there to the state of
The defendant by his atty comes and
objects to all the foregoing interrogatories
propounded by plaintiffs atty because
they are not rebutting in their character,
but questions in chief.
Further this deponent saith not.
Lakins depositions in the case adjourned
to
also
duly sworn as hereafter certified deposes
as follows.
Question by plaintiffs
State if you know
color plaintiff in this case if so when
and how long and under what circumstances
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(12)
Answer
I
of
in the family of
girl in
there about two years.
Question by same
State if you know who bought
Answer
She came with the family of
Question by same
Had
persons in his family besides
at the time said
house if so how many and what were their
names
Answer
He has one colored woman
besides
Question by same
State the size age and color of
said
Answer
I suppose her age to be about twelve
years at the time she landed in
She was
at that size.
Question by same
Where did said
came to
Answer
She came in the family of
o clock they landed in the day.
(13)
He
Lewis County
the name of the Steam Boat it was the
Marysville Packet.
Question by same:
do you know what became of
if she left
know about that matter
Answer
She lived in
two years.
She moved with the family of
I was frequently at
when she was there some year or two
after she left
Question by same - What was the
color of the other colored woman at
said
Answer-
I would call her a dark mulatto
I would suppose her to be twenty or twenty
five years old - she was of
size at the time said
Question by same --- has
Answer - I do not know as he did - in particular
Question by same
Was it the two years immediately after said
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(14)
Answer-
It was
Question by same
Where were you living at the time you
say that said
state what year that was
Answer
I lived on what was called
about a half mile from
house - it was about the year
Question by same
do you know what finally become of
said
Answer -
I understand from
general talk that
to some person in the
The Defendant by his Atty comes & excepts to the last answer of the witness as
otherwise illegal, and to all the interrogatories
of Plaintiff as illegal
Question by Defts Atty -
habit of visiting James Bowd's home & family
during his residence in
you well acquainted with this negro
woman
Answer
I was in the habit of visiting them
frequently
I was well acquainted with
the girl
By same - was she quiet & active in
her movements, of a lively &
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(15)
& expression of the
otherwise, and had she any marks or
blemishes on her person or face that
were visible & if she had any marks or
blemishes describe them, and when you last
saw her was she healthy & stout or delicate.
Answer
I would say she was sprightly
quick in her movements lively and pleasant
countenance lively expression of the
eye quick spoken I do not recollect any
mark or blemish her appearance was
stout and healthy when I last seen her
By same - How old was she when you
last saw her?
Answer-
I would supose she was about
sixteen.
By same - Did
with his family to the
they moved to this State; was their any other
persons besides
landed at that time, if so who were they,
and do you know that then two negroes
belonged to Bowd's family or some
other person & if you do how do you
know that fact.
Answer
He was on the boat when they
landed he came off the boat employed
hands to assist him to move - I do not
know how long he staid with his family
there was. there was a young lady by the name
of Racheal Bell no other strangers to my recollection
that time - I do not know who the
Negro belonged to that were with
By same - How do you know whether
the Plaintifff in this suit is the same negro that
lived in
stated.
Answer this question from what you
know of your own knowledge & not from
Answer
I do not.
By same - Where you present at the departure
or removal of
State to
on that occasion and did you see the
negro woman
at that time & how were they conveyed
across the river and by
Did
other negroes in Ky either before he
came first to
to that State of Ky and if he did how
many and their names & color, and
how, when and at what time did you
see
was it his house or kitchen or
where.
And do you know whether said
negro came to
was she compelled.
Answer-
I was not present no further than
I seen them moving across the river I do not
recollect who else was present at that time
I did not see
They crossed in a ferry
flat I think.
It was himself and some
hired hands - I do not know who -
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(17)
he said he moved a negro man he
from him he had two other negros
they were known or not I do not
know, their names I do not know.
She was rather dark colour about eighteen
months after he
on me to do a piece of work in
and
family - as usual doing the domestic
work about the house.
I dont know
wheather said
or not.
By same - were the two negros named
in your answer to the last question owned
by
and
he returned to Ky.
Were they women
men or what?
Were they black, mullatto
copper colored or what was their color
as near as you can tell.
What work
was it that you done for
time you have alluded to & did you
board with Mr
you were engaged in said work
if 2d
was
boarding in the family at that time, or
was Miss Rachael Bell living with
said
if any others living with him at the time
name them
Answer - I do not know. They were in
his possession after he removed to
there was a woman and a small Girl - the
woman was a dark mulatto the Girl was rather
lighter
I was
Mr.
three days I think.
there was no other
person boarding in the family at that
Miss Rachael Bell was not boarding with
boarding with said
By same - Had you not frequent
dealings with
did they not terminate in an unfriendly
manner?
Answer-
I had dealings with
we had no particular difficulty we had
By same - Did you not have some
dispute or altercation with said
in relation to the price of a House Boat
or the manner of payment for the same
did you not state & think
treated you badly in regard to the
matter & did not his deportment in
relation to that affair excite
unkind feelings for him.
Answer-
We had a dispute about the price
of the boat and how it should be paid
I thought
bad feelings of course.
reexamined by Plaintiffs Counsel
Question by Plaintiffs Counsel
State if you are friendly
with Mr
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time and have you at present any
unkind feelings towards said
and have you any difficulties with
said
Answer-
I am friendly with
at the present time - our old difficulty are
all settled
I do not like said
I have no difficulty with
time.
Further this Deponent saith not.
Wm Maxwell of lawfull age being produced
sworn and examined on the part of
the plaintiff deposeth and saith
Question by Plaintiffs Council
State if you know
of color plaintiff in this case if so
when and how long and under what
circumstances also state all you
know about the matter if you know
any thing.
Answer-
I know
who lived with
or not she is the plaintiff in this case I
tell Said
between one and two years in
that time I never was much about their
house have been passing and
several times and seen said
I suposed
her to be a servant but do not know have seen
her at work in the kitchen and nursing
child.
I know nothing about how she
came there
Question by same
State what you
was when living with
and appearance.
Answer
I supose she was from 12 to 14
years of age at that time she was darker
than a mulatto and not as dark as some
negroes.
Question by same
Did you ever see said
other place than
Answer
I do not know that I did I might
have seen her crossing the river.
Question by Dfts Atty - How did you
know that the negro girl that lived with
Answer I heard the family call
her
her
She would weigh from 100 to 120 lbs
I think.
By same - Are you a member of what is called the abolition party in the
Answer
I do not know that I am
a member but I am decidedly opposed
to slavery.
By same - Have you ever voted
for an abolition candidate for Governor
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(21)
of
when and their names
Answer
I
for Martain VanBuren in
The above Question and answer objected
to by plaintiffs council as being irrelevant
and illegal and otherwise informal
Question by Dfts Atty: Have you not
consulted or talked with the Atty for the
Plaintiffs in this suit as to the best course to
adopt in the taking these depositions, or
what certain individuals would depose to upon the subject and have you not
informed the Atty for Plaintiff what
questions to put to certain persons
him upon the subject.
Answer -
I talked some with him yesterday
but did not consult with in regard to
the best course to be taken in taking these
depositions I told him Mrs.
be a good witness in this case.
I told plaintiffs attorney to ask
witness in this suit if
eat dinner with him the other day and
if they were not now friendly.
I have not
advised him to ask any other questions.
By same - Have you &
not had some difficulty & have you
no unfriendly or unkind feelings for him?
Answer
Yes he has held me at spite for two
years we did not speak I do not like his
ways but would do him no injury
(22)
Further this deponent saith not.
produced sworn and examined on the
part of the plaintiff deposeth and saith
Question by plaintiffs council
State if you know a colored
woman of the name
where did she live who did she live
with state the time and under
what circumstances.
Answer
I was not much acquainted
I
between twelve & 16 years of age the
other I think was between twenty & thirty
years old.
They lived at
I have forgotten the name of, the youngest
one name was
I did not learn the name from
about the time when they were in
I
since he be first seen there
river
saw her working about the house
She
was a dark colour but not Black
Question by Dfts Atty - Where do you reside?
Are you not a member of what is called
the Abolition party in
ever voted for an abolition candidate
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for Governor in
of the
here as a witness or what induced
you to come.
How far do you
live from this place (
Answer
I reside in
from
I am an abolitionist
as I understand
I voted for what they
call free soilers for a number of years. I voted
for
he was elected president of the
I also voted for
a free soil candidate for president in
I was not summoned to come
that they were taking deposition in regard
to this Negro woman
I wished, if I could be of any benefit
to the Girl by telling the truth and being
forthcoming my son told me that Esq
Mc Lefurt wished me to come.
The last above question and answer excepted to by plaintiffs
Council as illegal and irrelevant
and otherwise informal.
Further this deponent saith not.
Opened & filed
I George W. Richards a Justice of the Peace in and
for the township of
and
or within named James Hendrickson
were by me first duly sworn to testify the truth
the whole truth and nothing but the truth and
that the foregoing depositions by them respectively
subscribed were reduced to writing by me
(except the first answer of
who wrote the same himself) and were
taken at the time and place specified in the
herewith set my hand this
in the year 1851
Justice fees
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I, R. W. Clarke, Clerk of the Court of Common Pleas of said
county, certify that
the foregoing
was, at the time of the taking and acknowledging thereof, an acting
commissioned and qualified as such; that the same is in due form of
law, and the signature of said Justice thereto is genuine.
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Deposition Opened &
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Depositions of witnesses produced
sworn and examined at the
office of J C
in the city of
cause pending in the
County
of color is plff in her suit
for freedom and
the part of the plff, the notice
to take the same being
waived by Samuel T Glover
for the deft who also consents
that the taking the said
depositions may be adjourned
till tomorrow morning the
November
o'clock A.
M.
produced, sworn and examined on the part of the
plaintiff, deposeth and saith:
he is a resident of the town of
with the name of
eighteen hundred and forty, said
to
with him, two negroes, one a girl about &
between twelve and fourteen years of age with the
name -
color; the other was a darker color about between
twenty and twenty five years of age, so near as
he can judge - her name was
The negro girl
this same negro girl in the
the year eighteen hundred forty three or four, in Bracker
county in the town of
well acquainted with the negro girl when she was
living in the
Said
the town of
Deponent stated, the girl
he knows the girl is the same who he deponent
knewst in the
Mr
girl
back to the
state positively, but, it was about the time
as he before stated.
Crossexamination by S. T.
Question: how long has it has been, since you saw
the girl here present, previous to your arrival
in
answer: about seven or eight years ago.
question: Where you seen her last?
answer: in
question: when you seen her in
this occasion, how long was you with her
and seen her?
answer: it was about one year.
question: what was about a year?
answer: that I saw her in
the last time.
question: what was you doing in
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Answer: I was living on Mr.
opposite
Question: You did not live in
Answer: no, my family resided in
that time.
question: How many days during that year, did
you work for said
answer: I dont know how many, but good many.
question: can you give the number of days?
answer: if I should guess, about 60 days
or more
question: was sort of business was you employed
in during this work in
answer: most every kind of laboring, making
plank fences, and
question: how do you
here present?
answer: I recognize her by her looks, colour
figure, just as I would any other person
where I was acquainted with.
question: Can you give any other reason for
recognizing her?
answer: no other.
question: do you remember any marks?
answer: none
question: had you much conversation
with her?
answer: o yes, as she was passing in the
house, as any other servants.
question: when was the first time you ever
saw her?
answer: the first time I ever saw her, was
when Mr.
question: which was the darker of the two?
answer
question: you observed any difference between the appearance
of the girl here present and the appearance
she had when you saw her in
time?
answer: I don't see very much difference in her appearance
now, more than she is now a little more fleshy.
question: she was as tall as she is now?
answer: she was about as tall as she is now.
question: was her frame as large then as it
is now?
answer: her frame was about as large then as
it is now>
question: had you much conversation with the
girl here present while you say she was in
answer: not very much more, than of talking
while passing about in the house of Mr.
question: from the time you saw her last
in
in
in her appearance?
answer: I saw no change in her
appearance more than she had
some and more heavy.
question: when you saw her last in
in
answer: she was then about as tall, as she
is now, and her frame about as large, and she
is now a little more heavier and fleshier.
question: on what business did you come
to
answer: I come here on the purpose to
identify this girl
question: under what circumstances did you
come?
answer: I was send here for that purpose
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objected to in time by plaintiffs counsel here
present.
question: who send you?
answer: no one particular person; it was
a kind of public concern.
Objected to this question and answer by the plaintiffs counsel.
question: who were those persons to make up
this public concern and how was the thing
managed?
Answer: the persons was the citizens of the town
of
County
Question: What had they to do with it?
answer: I dont know Sir.
Question: Had they any name or
who send you?
answer: I know some of them, went by
the name of abolitionists.
Question: Were them not knowing as the anti slavery
society those persons?
answer: some of them was knowing as anti
slavery men; whether they was formed in a
say
Question:
Are you a member of an antislavery society?
Answer: No Sir:
Question:
What arrangements was made for your coming
here? Please to state the particulars.
Answer: I cant state any particulars, all
I know, is, that money was furnished me, to pay my
expenses here.
Question: Who furnished the money?
answer: a man of name of Joseph Parrish
furnished me the money; I dont know, how
Parrish got the money.
Question:
1) How much money?
2)How did Parrish know, you were to come
to
3) Was there any conversation between you
as to your testimony?
4) Were you to have any thing part your
except your expenses?
od 1. Answers: I received thirty eight Dollars
for two of us.
od 2. Answer: He told me, he
come, and pay my expenses, and he would
furnish me the money to pay my expenses.
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od 3. Answer: No Sir, none.
od 4. Mr. Parrish told me, that he would pay me
as much money, as I could earn at home
in the
Question:
You were to receive pay for your time
when you get back?
Answer: I was.
Question:
Suppose that
her liberty in this suit, are you to be
paid for your time?
Answer: Yes Sir.
Question: Are you an abolitionist, my friend?
Answer: No Sir. I never was.
Question: Who you voted for, for the last
President?
Answer: I voted for General Cass.
Question: Who you voted for the time before?
Answer: I always voted the Democratic
Ticket
Question: Who did you vote for the last time when
Van Buren was a candidate.
Answer: I voted for Cass.
Question: Did you ever voted for Van Buren
Answer: I did, when he first was elected President
Question: Have you been on terms of
Answer: Mr.
friendly so far as I know, and always was,
since our acquaintance.
Question: You feel any interest in this suit?
answer: None at all particularly.
Adjourned by consent to two o'clock afternoon
November 13 at 2 o'clock
same witness recalled.
Question by plaintiff:
your expenses here, be more or less,
whether
her freedom or not?
Answer: It will make no more or no less.
Question: is the woman
in this suit, the same person, who lived
with
deponent have spoken in this testimony?
Answer: yes, she is the same woman.
Question by defendant: how you know that this
is plaintiff in the suit?
Answer: I was told that this
plaintiff in the suit.
Question: Who told you?
Answer: Mr.
And further deponent says not.
I,
within and for the
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hereby certify that
deponent, whose place of residence is in the town of
to testify the whole truth of his knowledge touching the
matter in controversy in the cause aforesaid; that deponent
was examined, and his examination reduced to writing
and subscribed by said deponent, in my presence, on
the
hundred and fifty one
o'clock in the afternoon at the office of
being produced, sworn and examined on the part
of the plaintiff, deposeth and saith:
Question by plaintiff: where you reside?
answer: I live in the town of Nevill, Clairmont
County, State if
question: how long have you lived there?
answer: about ten months.
question: did you ever live in any other County in the
if so state how long and when?
answer: I did live in
fifteen years.
question: state what time you lived in
answer: I did live in
years
question: did you know
state when you first become acquainted with him?
answer: Yes, I know
acquainted with him since the year
hundred and
question: where did you become acquainted with
him, at what place?
answer: in
question: do you know whereabout Mr.
resided before he came to the
answer: he resided in Louisburg, Louis County
question:
know that
answer: yes,
question:
answer: Yes I was.
question: do you know that
a family to the
answer: Yes he did.
question: do you know
negro
when they landed in
answer: Yes, there was two coloured persons
a woman and a girl in
question: do you know the names of the
coloured persons spoken of?
answer: the womans name was
girls name was
question: what was about the age of the girl
to judge from her appearance?
answer: I suppose, something over twelve
years of age.
question: do you know the colour of the girl
answer: I would call her a dark mulatto.
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Question: how long did the girl
in the
answer: she remained in the family as long as
Mr.
two years.
question: were you in the employment of Mr.
answer: I did live on the farm, and tended
the farm on which Mr.
the time he, Mr.
question: were you often at the house of Mr.
answer: I was there most every day, while Mr. J
Bowd lived in
question: was the girl
of Mr. J Bowd at the time, you deponent, lived
on the farm?
answer: Yes, she was.
question: were you well acquainted with the girl
answer: Yes, I was, I seen her every day.
question: do you know if Mr.
back to the
answer: He moved to
Bracken County.
question: did he take the girl
answer: I saw her in the family after he lived
in
question: when did you see the girl
answer: the last time I saw her was about
eighteen months after Mr.
to
I can recollect in the year eighteen hundred
forty three or eighteen hundred forty four.
question: would you know the girl
you was to see her this time?
answer: I think I would.
question: have you seen the girl
arrival in
answer: I have.
question: is the woman here present, the one who
lived with
whom you have been speaking, who is named
answer: I think she is the same one.
question: have you any doubt about it been the
same woman?
answer: I have not.
question: have you any interest in the event of this suit?
answer: I have
Question: Did you know
moved to the
answer: I was not particularly acquainted with
him, I seen him passing back and forward to
his fathers.
question: Had you ever been in his house?
answer: I had not.
question: Had you ever seen his residence?
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Answer: No Sir. I mean I never seen his residence
question: how do you know he have a residence
in Louis County
answer: I know by good information, that he
was a merchant in that town for some years.
question: from whom did you get your good
information?
answer: from his relatives living in the
except hearsay?
answer: no, only what I heard him say and others.
question: what did you hear him say?
answer: I heard him say, he moved from Louis
question: how far is it from here to where you
live now?
answer: about eight hundred miles.
question: have you any other business in this
country
answer: I have not.
question: was you brought here by any process?
answer: I was not.
question: what induced you to come here, to give
testimony in the case?
answer: partly it was to see this City and partly
give testimony on this case.
question: are you paid for coming?
answer: I expect pay, I have not received
anything.
Question: from whom do you expect pay?
answer: not of anybody particular, I look to
my brother for my pay.
question: is your brother the same man who gives
his deposition in this cause?
answer: yes, he is.
question: how much pay you expect to get?
answer: I have to get my passage back and forward
and one dollar a day for my time.
question: is no other contract but that with your
brother to receive the money?
answer: No Sir.
question: do you know whether your brother was acting for
himself or as the agent for some other party
in imploring you to come here?
answer: No Sir I dont know.
question: has not your brother told you, who he
was acting for in imploying you to come here?
answer: he has.
question: Who is it?
answer: he said, he was imployed by the peoples
in
question: Did he tell you, he was employed by
the abolitionists in
society or by any other society,? or association?
answer: he told him, that he was employed
by the Felicians (Phelistiaes)
question: how is the word Felicians spelled?
answer: it is spelt as it is in the Bible.
question: can you tell, whether these Phelistiaes
are an organized antislavery society?
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Answer: I cant tell, I live nine miles from
that place.
Question: what was Marys size
saw her in
answer: she was always a heavy,
for her and fleshy girl.
question: what was her size as compared with
the girl
answer: she was much smaller.
question: have you seen this girl now present
at any other place than this office since you
come to this City?
answer: I have not, except at the door of this
office when she first got in.
question: have you ever conversed with her,
since you came here?
answer: I never spoke to her except as I said, a good
morning as I came yesterday.
question: when was the last time you saw the girl
before you saw her here.
answer: I saw her about eighteen months after
eighteen hundred forty three or four; she was
I think about sixteen years of age.
question:
whom you have referred.
answer:
Reexamined by plaintiffs counsel.
Question:
for coming here by the result of this suit of
Answer: It will not according to contract.
Question: Are you to be paid any more than your
expenses and what you earn by your labor
at home, at one Dollar per day?
Answer: I am not.
question: do you not expect to get a part of the
money you receive, from plaintiffs counsel.
answer: my brother told me, he would get a
part of the money here in
question: did
living in
answer: yes she
question: did you recognize the girl here present
as the one, named
speaking, when you saw her first in
this week?
Answer: I did recognize her.
Question by defendant:
What business do you follow at home?
answer: I keep a public ferry, cross the
I
and for the
that
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Nevill,
truth of his knowledge touching the matter in
controversy in the cause aforesaid; that deponent
was examined, and his examination reduced to writing
and subscribed by said deponent, in my presence
on the
eighteen hundred and fifty one
of eight and
at the office of
and
Given and certified, this
November 1851
These depositions of
and
were taken by consent of
for plff.
No objection is so be taken to
authentication but all objections
are saved to the matter
of said depositions.