Alsey vs. William Randolph
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Depositions of witness produced whom and examined at the
office of John Elder in the County of EdwardsCounty of Edwards StateIllinois of IllinoisIllinois
before me John Elder an acting justice of the peace in
and for the County of EdwardsCounty of Edwards and State of IllinoisIllinois in
a cause now pending in the St. Louis Circuit CourtCircuit Court StateMissouri
of MissouriMissouri where in Alsey in plaintiff and WilliamWilliam
S RandolphS Randolph defendant on the part of the defendant
Racheal Donald being of lawful age produced
sworn and examined on the part of the defendant
deposith and saith- That she is the wife of
RobertRobert was till his death that when
we lived in KentuckyKentucky County we had a negro girl
named Alsey borrowed of my father
of County under was preparing
to move to IllinoisIllinois and I of my authority
sent the girl Alsey to my father he being poor
not having any female servant but her- We moved to IllinoisIllinois and under returned to KentuckyKentucky
and brought the said girl Alsey to the where
we kept her sometime. When are
took an of her by same means and I forbid
him to touch or remove her as she did not belong to
by any grant purchase or otherwise
that ever came to my knowledge to guard took her
off (to KentuckyKentucky as I heard) my father sent to the salaries
for the by an uncle but he was prevented
from taking her by guard claim and he want
away my father had a law sent about the negro in
KentuckyKentucky as I heard and guard her as I have seen her
several times in my fathers family frequently
since and further the deponant not

Donald