Julia v. Samuel M. Kinney
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State of IllinoisIllinois
AdamsAdams county

The deposition of witness produced sworn
& exmanined at the office of A
Williams Esq & in the town of in the
said county of AdamsAdams in the state of IllinoisIllinois
before me a justice of the
peace within & for said conty in a certain
cause now depending in the circut court
for the county of St LouisSt Louis state of MissouriMissouri
between JuliaJulia a woman of colour
plaintiff & SamuelSamuel J M KinneyM Kinney , Defendant
on the part of the said defendant

HenryHenry Baitman of lawful age being
deposeth & saithproduced sworn & ex
amined on the part of the said defend-
ant deposeth & saith, in answer to Inter
rogatories

Interrogatory
1st And you acguainted with the parties
in the of this suit named &
so at what time did you become acguaninted

Answer - I am not acquainted with defendant
Mrs Carringtion came into PikePike county IllinoisIllinois
near to Philips ferry in the neighbourhood
in which I then lived & brought with her
a woman of color named JuliaJulia , who
I suppose to be the Plaintiff to this suit
on or about the 15th day of November 1825, She the said JuliaJulia continued
there with Mrs CarringtonCarrington about
two weeks during which time I was acqu
ainted with her. At the end
of which time she was taken by JosephJoseph
Carring since deceased (the son of Mrs Carringtion)
to MissouriMissouri & there hired out to labour, since that time I have not been ac-
quaninted with her or seen her more than
once.

Interrogatory
2nd When & where did your see her afterwards

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Answer to
2nd. Interrogatory About the time of Christmas Holidays of
the year 1829. I saw her at Mrs Carring
tonsaforesaid.

Question 3rd. At what time did she return to MissouriMissouri
again, & who went with her.

Answer She returned the monday after Christ
mas & Joseph CarringtonJoseph Carrington aforesaid
went with her

Question 4th. Did her little Daughter go with
her to MissouriMissouri at that time

Answer No The child went with her when
She first was taken to MissouriMissouri &
had not been brought back to
IllinoisIllinois

Question 5th. Do you know why JuliaJulia was not
taken to MissouriMissouri immediately
after Mrs CarringtonCarrington brought her
to the neighbourhood of Philips
ferry

Answer - About the time she came there her
(Mrs Carrington's) horses ran away &
were gone about a week during
which time JosephJoseph Carring (her only son
able to do business) & myself were
hunting for them - It was also
understood that The [ Missippi ]
River could not be safely crossed
at that time on account of ice
in it.