Julia v. Samuel M. Kinney
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JuliaJulia a woman of color
vsSamuelSamuel M KinneyM Kinney

Suit for freedom in StCircuit Court LouisCircuit Court
Circuit CourtCircuit Court MissouriMissouri

GustavusGustavus A Bird AGustavus A Bird BirdGustavus A Bird on behalf of Said Plaintiff
says he as one of the for the Plaintiff
of her as to her right to freedom & the witnesses
by whom she could prove that right & was informed
that the most material for her were Philips & AndrewAndrew Philips & the family
of said living in IllinoisIllinois- the affiant causes a notice
to be served on the defendant that on the 23rd day
of March last at the dwelling house of
Philips in Pike CountyPike County & StateIllinois ofIllinois IllinoisIllinois near a
place called Philips Ferry on the IllinoisIllinois river between
the hours of 8 O Clock A.M & 6 Oclock PM
of that day plaintiff wants take the depositions
of witnesses to be read in evidence in said cause
This affiant says Said notice was served on defendant
at St LouisSt Louis on the 14th day of March last &
that the distance from St LouisSt Louis to the residence
of said Philips is nextone hundred &
twenty miles - This affiant says that on the 29
day of March & pursuant to said notice he attended
at the place mentioned in said notice for the
purpose of taking said depositions that on
arriving there he found that said Philips
was dead - but this affiant proceeded to take
depositions at the late residence ofsaid Philips
on the day & between the hours specified in
said notice - that he took the depositions of
daughter of said
which depositions are here on file
& which depositions state facts which this affiant
show that said Plaintiff is entitled to her

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and to which depositions on file the affiant refers
to show that they are material to the
This affiant says he had never heard of the death of
said Philips until after said notice
was given & until this arrived near his late residence & he beleives the plaintiff had never
heard of the death of said Philips [ untill ]
she was informed of his death by this affiant
This affiant further says that after taking Said
Depositions he left the Depositions with the
Justice before whom they were taken for the
purpose of having the official character of
the Justice attested by the certificate of the clerk
of the County Commissions Court of Pike County
& StateIllinois of IllinoisIllinois under the seal of Said Court & gave Said Justice the many
which he said was to defray the
and said Justice agreed that he could
cause said depositions to be authenticated &
put in the Post Office Pike CountyPike County
IllinoisIllinois directed to the Clerk of the St LouisCircuit Court
Circuit CourtCircuit Court by the 26th of March last
This affiant says that in the day Said Depositions
were filed he took them out of the Post Office
at St LouisSt Louis - that they came without
being endorsed under the seal of the Justice
& without being authenticated & without any
certificate under the seal of the County Commissions
Court. This affiant says that at the Court
of the Plaintiff he has taken unusual care
to prepare this cause for trial at this term
& he beleives it is no fault of Plaintiff as her
counsel that said depositions are not authenticated
This affiant beleives the depositions of said
can be procured properly
authenticated by the Term of this court