Samuel, a man of color vs. John Howdershell
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Depositions of a [ witnesse ] produced, sworn
and examined at my office in the County of WashingtonCounty of Washington
and State of IllinoisIllinois, before me the undersigned JohnJohn Williams
WilliamsJohn Williams a Justice of the Peace, in a certain cause
now pending in the St Louis County Circuit CourtCircuit Court
State of MissouriMissouri between, Sam. of Color plaintiff
and JohnJohn Howdershell [ John HowdershellHowdeshell ] defendant on the part of the

Milo[ HarrymanHarryman ], of lawful age, being sworn
and examined on the part of the defendant deposeth
and saith; My Father, CharlesCharles [ HarrymanHarryman ], put
a negro boy named Sam, into the hands of AndrewAndrew of
[ HarrymanHarryman ] about the year 1830, or 1831 as a security
to him if he the aid AndrewAndrew J [ HarrymanHarryman ] should
have to pay any debt for my father for which he
was security; I never knew, or heard of his having any
such debt to pay and I have often heard the administrator, who is my Mother, say he ever had any
such debt to pay- I never saw the negro in IllinoisIllinois
I always supposed the negro boy to belong to the estate
of my Father, I lived with my Father at the time of
his death and Iheard my father say a very short time
previous to his death that AndrewAndrew need not think
that he (my father) could let him have the negro boy
Sam, that he was pretty well through his debts, and that
AndrewAndrew had not any of them to pay I have not seen
the negro Sam, since March 1835 he was then in MissouriMissouri
I do not know that he is the same negro that
has suedJohnJohn Howdershell [ John HowdershellHowdeshell ] for his freedom- I do not
know [ Howdeshell ] I consider the negro to be the property
of my father's estate