Julia v. Samuel M. Kinney
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Depositions of witnesses proudced sworn & examined at
the court house in Pittsfield in the county of PikePike & StateIllinois ofIllinois
IllinoisIllinois before me E Rattau an acting Justice of the
peace in & for the county & State aforesaid in a certain cause now
depending in the circuit court in & for the county of St LouisSt Louis
and StateMissouri ofMissouri MissouriMissouri between JuliaJulia a woman of color and
Plaintiff and SamuelSamuel J M KinneyM Kinney Defendant on the part
of the defendant.

Joseph J Bennet of lawful age being produced sworn
and examined on the part of the defendant deposeth & saith
that Lucunda CarringtonCarrington served into Pike CountyPike County IllinoisIllinois
sometime in the full of 1829& brought with her a woman of
color [ caled ]JuliaJulia and a small negro give the daughter of said JuliaJulia
the weather was cold & stormy & the ice was in the [ Missippi ] river so as to make it dangerous crossing it That
she Mrs CarringtonCarrington applied to this deponent and obtained
leave to stay in one of his houses until she coulg get on
to MissouriMissouri That about the time Mrs CarringtonCarrington stopped
in Pike CountyPike County aforesaid her horses strayed off that she this
deponent was acquainted with Mrs CarringtonCarrington
during the the said negros remained in said PikePike County
CountyPike County & that she always manifested great anxiety to
have them taken out of the state of IllinoisIllinois and that
she did send them on to MissouriMissouri as soon as her horses were
found and the MississippiMississippi could be crossed with
any kind of safety.

That he is acquainted with the general character of NancyNancy Bright
BrightNancy Bright & could not from her general character believe her
under oath That the said Nancy BrightNancy Bright was the respected
wife of Numrod Philips and lived with him as such till
his death when it was ascertained that her proper name
was Nancy MorrisNancy Morris & that she was not the wife of said
Philips she married a Mr Bright

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and further this deponent saith not