Samuel, a man of color vs. John Howdershell
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Depositions of witnesses, produced, sworn,
and examined at my office in the County of WashingtonCounty of Washington
and State of IllinoisIllinois, before me the
undersigned, John 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 defendant.

JamesJames Harryman [ James HarrymanHarryman ] of lawful age, being sworn
and examined on the part of the defendant deposeth
and saith: There was a negro boy belonging to the
estate of my father CharlesCharles [ HarrymanHarryman ], named
Sam, about the age of thirteen or fourteen
years
of age that was in [ washington ] County IllinoisIllinois in
the winter of 1835 that was at that time in the
possession of myself and AndrewAndrew J. [ HarrymanHarryman ]
that the said negro boy was before that time delivered
to AndrewAndrew J. [ HarrymanHarryman ], by my father as a
security to indemnifyhim in case he should
be compelled to pay any debts of my father
for which he was security. I do not know whether
AndrewAndrew J. [ HarrymanHarryman ] had a bill of sale on said
negro boy or not and that to my certain knowledge
AndrewAndrew J. [ HarrymanHarryman ] never had any debt to
pay for my father for which he was security.
The reason why I know it is, that my Mother was
administratrix of the estate of my Father, and that
I was duly appointed by her, by power of attorney
to settle up the said estate, that I did settle up the
estate and AndrewAndrew J. [ HarrymanHarryman ] had no debt to
pay for my Father and after the estate was settled
I got the said negro boy
from AndrewAndrew J. [ HarrymanHarryman ] which was in February
of 1836, and took the said negro boy to St LouisSt Louis, with
the intention of taking him down the River to sell
him- that AndrewAndrew J. [ HarrymanHarryman ] was at that time

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in Washington CountyWashington County IllinoisIllinois on a visit, and he
went with me to St LouisSt Louis at the time I started with
said negro boy and that after we got to St LouisSt Louis I concluded
not to sell said negro boy, and left himwith
AndrewAndrew J. [ HarrymanHarryman ] to be hired out to labor by him
I never have seen said negro boy since that time, and
I do not know that the man of color named Sam who
has sued John [ Houdeshell ] for his freedom is the same
negro that I left with AndrewAndrew J. [ HarrymanHarryman ], I do not
know [ Houdeshell ]

JamesJames Harryman [ James HarrymanHarryman ]