vs
BerryBerry Meachum MeachumBerry Meachum
Charles D Drake being
swornon his oath says that
on the trial of the above case
he acted as atorney for the defendant.- That
previous to the time of trial he did not know
or suspect in the slightest degree that a person
of color was to be introduced as a witness and
that when LewisLewis a man of color was brought
up as a witness he was wholly by surprize.
This affiant further says that not supposing
that any person of color was to be brought
forward to testify, he was unable to produce
in court on he trial a bill of sale from
JamesJames Newton a white man to the defen-
dant BerryBerry Meachum MeachumBerry Meachum
of the said plaintiff JudyJudy , which said bill
of sale this affiant had heard of but never saw until after the trial and which con-
tains a of warranty of title of said slave & pur-
ports to be for the consideration of five hundred dollars
dated since the pretended residence of the plaintiff
in IndianaIndiana & probably some time in the year
1833. This affiant therefore saith that this suit is substan-
tially therefore between Judy & James Newton the
maker of said Bill of sale with warranty to BerryBerry Meachum
MeachumBerry Meachum as aforesaid & further that this affiant
was employed to act for defendant in their case
by said Newton through his agent.
ChadD. DrakeD Drake
Sworn to in open court
April 9. 1836
John RulandJohn Ruland Clk
ByDpty J.D. Johnsten


