Dorinda, a free woman of Colour vs. John Simonds, Jr.
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[missing figure]
John Simonds JrJohn Simonds Jr

St. Louis Circuit CourtCircuit Court

Avington Phelps being sworn saith
that he is the owner of the above plaintiff now suing
for freedom: that HenryHenry S. Brown is a material witness
for the defendant in above suit without whom he can
not safely go to trial: that said BrownBrown went some time
since to Texas in the Spanish territory whence he
is expected to return to his residence in Pike CountyPike County
in this State in September next & has in fact
lately written home to that effect; so that this de
ponent fully believes he shall be able to procure
the testimony of said BrownBrown in said suit by the
next term of this Court Deponent further says
that said BrownBrown has been in Texas ever since
said suit was commenced, so that he has hith
erto been unable to obtain his deposition.

Avington Phelps

Sworn to & subscribed
This 2d August 1826
in open Court

Arch GambleArchibald Gamble Clerk