The above named RalphRalph on his oathsays that
since the trial of this case on this morning he
has discovered &been informed that a
Mr. JohnJohn Hart HartJohn Hart is a material witness for
this plaintiff in this cause that said
JohnJohn Hart HartJohn Hart knows the fact that this plaintiff
while he was held as the slave
of one John GordonJohn Gordon deceased was
hired by said John GordonJohn Gordon to labor in
the thenterritory of IllinoisIllinois for several
years & from about the year 1812until
after said Territorybecame a state this
affiant is fully convinced that he can prove
the above facts by said JohnJohn Hart HartJohn Hart as he
is informed & believes that said Hart says
he knows said facts & this affiant now
recalled that he knew said JohnJohn Hart HartJohn Hart
in IllinoisIllinois some fifteen years past or more
But this affiantdid not know that said
Hart was a material witness for him
nor did he know that said Hart would testify to the above facts
untill this morning this affiant says
he knows of nowitnesses by whom
he could have proved the someparts
he appeals to prove by said Hart this affiant
says he washired to do labor in the StateIllinois
ofIllinois IllinoisIllinois by said John GordonJohn Gordon in 1811 or
1812 that he was at work there the
time of the earthquake in N Madridbut
thosewhoknew this affiant to work
there are mostlymoved away or died