vs
PierrePierre Chouteau ChouteauPierre Chouteau jr
In St. Louis Circuit CourtCircuit Court
John BJohn B Sarpy SarpyJohn B Sarpy agent for said
Defendant
being duly
sworn says, that he is
informed and believes
it true
that this is an action
brought for freedom from Slavery, on the ground
of
her being born in the late Northwestern Territory
at PrairiePrairie du
rocher in the present state of IllinoisIllinois-
this affiant
further states, that he is informed
and
believes it true, that a Copy (authorized
according to
law) of the Register of births and baptisms
in the
village of prairie du rocher is material
testimony
for said Defendant in this cause, inasmuch
as this affiant is
informed and believes true, that
the age of said plaintiff, and the
time she was
baptized
can be proved by said Register, and
this affiant does not know of any
other testimony
by which the same facts can be proved, without
which this affiant verily believes, said defendant
cannot safely go to
trial; This affiant further
states, that he is
informed and believes it
true, that in order to obtain said
testimony
said Defendant before the present term of this
Court,
obtained a to State of IllinoisIllinois
and caused due notice to be served on the
plaintiffs attorney that
depositions for said defendant
would be taken at said village of
PrairiePrairie
du
rocher
at the house of HenryHenry ConnorConnor Esq in said
village sometime
during the week preceding the
present term of this Court, and that the
papers
were sent in time by mail to ColPeterPeter Menard MenardPeter Menard
of KaskaskiaKaskaskia to have said deposition
taken.
not know, he is informed no deposition has been received
by the Clerk of this Court in this cause; this affiant
further states he does not know of any witness within the
reach of the process of this Court who can prove the
time and place of said plaintiffs birth, and that by
the next term of this count, the verily said testimony can be had
John B SarpyJohn B Sarpy
Sworn to in open courtDec 3rd 1828
A GambleArchibald Gamble Clerk


