Samuel, a man of color vs. John Howdershell
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Depositions of witnesses produced, sworn and examined at
the offices of LeviI. CarrCarr Esq, in the , D
to be read in and in a suit pending in the
St Louis Circuit CourtCircuit Court , for St Louis County in the
State of MissouriMissouri, wherein SamuelSamuel (a free man
of color) is plaintiff and JohnJohn Howdershell [ John HowdershellHowdershell ]
is defendant on the part of the Plaintiff
Whereas [ HerrymanHerryman ] of lawful age being duly
sworn on behalf of the plaintiff depeseth and
saith that he is acquainted with the plaintiff in
this case he is the same now present he was raised
by my father â his family, he remained in my father's
possession until he was twelve or fourteen years old
Some time in the year 1831 or two my father made
my brother a bill of sale to the plaintiff. My father
and in the year 1833 in July or June, between the
year 1831 and 1833 the plaintiff was in the possession
of AndrewAndrew [ HerrymanHerryman ], I know the paper
hereto marked "A" is a copy from the
records of the book of Chouteau County MissouriMissouri, to this the
defendant objected. He my father owned five slaves EphraimDinah
and Pete they belonged to my father in the year 1833
my owned but three when he Ephraim
Dinah & Pete, I know that AndrewAndrew [ HarrymanHarryman ]
took the plaintiff to IllinoisIllinois twice, the firsttime
he kept the pltf five or six months in IllinoisIllinois

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the next time he kept plff in IllinoisIllinois between
one & two years, AndrewAndrew [ HerrymanHerryman ] never
brought plff back but my father brought
him back the first time he was taken to IllinoisIllinois
he was brought back & AndrewAndrew [ HerrymanHerryman ]
directing my father knew of the [ plffs ] being
carried to IllinoisIllinois by my brother the second
time plff was carried to IllinoisIllinois was in 1831 or
1832. the plaintiff is the only negro that said
[ HarrymanHarryman ]ever took to IllinoisIllinois of this name with past

I have heard AndrewAndrew [ HerrymanHerryman ]say there
he had plaintiff in IllinoisIllinois, that I heard said
A HarrymanHarryman say he had sold plff to [ Howdershall ]
and[ HerrymanHerryman ]neverowned any negro named
Sam except the plff, Sam was born in 1820
to the above relation to the
A [ HarrymanHarryman ] the deft objected,

Cross Examined, I came here as a witness
in this case at the request of the plaintiff and his Counselors There
were nopromises made that I should recover
anything for being a witness. I am friends with
AndrewAndrew [ HarrymanHarryman ] but he is not with me
I am neitherdrunk nor sober this morning
I have taken only one shot of liquor to my
knowledge. I cannot tell how much I have
drunk this morning, I do not measure it
I cannot recollect whether I havedrunkliquor
more than once or not this morning, I am
not in the habit of getting drunk only occasionally
as I saw proper, the bill of sale
to AndrewAndrew [ HarrymanHarryman ] from myfather was made
in 1831 or 1832 to my best recollection, I do
not know of A [ Herryman ]having a mortgage
on the plff, if I were to answer in the
he never had any such mortgage