Lewis, a man of color vs. James Newton and Jacob Cooper
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Louis a Man of color
JamesJames Newton

Said Louis says on his oath
that he has a good & just cause for obtaining
his freedom in said suit he refers to the affidavit
of Gustavus A BirdGustavus A Bird heretofore made in this
cause to shew the and he has made to procure
his evidence in said cause This affiant says
that Peggy Morton Living at the yellow Bank
in the State of KentuckyKentucky is a Material
Witness for him & by her he can prove that
Benjamin DuncanBenjamin Duncan Some Nine or twelve
years ago was the Master & owner of this
affiant & claimed him as his slave that said
DuncanDuncan then to prevent your affiant & other
slaves from being on an Execution
sent your petitioner & them into the state of IndianaIndiana
& there caused him to be hired out to Labor
for sixweeks with one Isaac__WrightWright
who lives near Fray in IndianaIndiana Those facts
were known to Many persons but this affiant
does not now know where to find any person
by whom he can prove said facts except
said Peggy Morton aforesaid & EdmondEdmund
Jennings living at Fay IndianaIndiana & said WrightWright
Yet he believes that if he could procure some
further agent to go to Davis County
KentuckyKentucky to Fay IndianaIndiana he could obtain
sufficient evidence to obtain his freedom

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your petitioner states that since the commencement of
his suit he has been all the while in there under
the contract of the Defendant or hired out
by the sheriff that this affiant has not had
the benefit of his labor â that he had
hoped that some friend would have furnished
him with money sufficient to procure his
depositions to be taken in KentuckyKentucky and
IndianaIndiana & to employ same faithful agent
to do it for him but it has as yet been
utterly beyond his power to do either or
scareely to procure himself comfortable â
clothing & he further says that JosephJoseph
has so much confidence
in the justice of his cause & the integrity of
your affiant that he hasengaged
that if this affiant can procure a continuance
of his cause they he will furnish the funds
necessary for the taking his depositions in
said cause in KentuckyKentucky & IndianaIndiana & to
employ some suitable person to attend to
the taking of them and this affiant believes
he can procure the testimony of said
Peggy Morton Issac_ Wright & Edmund
Jennings by the next Term of this court
This affidavit is not made for us action
or delay but that Justice may be done

Sworn to & Subscribed in open court
this 29th March 1835

John RulandJohn Ruland Clerk
LewisLewis X Newton
his Mark