Irene Emerson vs. Dred Scott (of color)
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Dred ScottDred Scott )
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Irene EmersonIrene Emerson )

Dred ScottDred Scott , the plaintiff in this Cause in Support of his motion for a new trial[ [,] ]States upon oath. That he was Surprised in the testimony of the witness , by whom he expected to move that he, this affiant, was hired as a Salon by Said RussellRussell from the defendant, previous to the Commencement of this Suit, & that Said RussellRussell Paid to Said defendant money for the hire of this affiant as a X Slave, and that he did not know previous to, or as [illegible] the trial of Said Cause that he could ^proveXSaid facts, or Could prove that he was claimed as a Slave or held in Slavery by Said defendant, by any other person than Said RussellRussell , and therefore relied solely upon the testimony of Said RussellRussell to prove Such facts as now necessary to maintain Said Suit of which Said defendant, is the person holding this affiant in Slavery. XThis affiant in support of this affidavit makes an exhibit of a certain letter addressed to Said RussellRussell by J.R. Lackland one of the Counsel of this affiant & the answer of Said RussellRussell to the Said letter âfrom which it will appear, that previous to Said trial Said RussellRussell informed Said Lackland that he Said RussellRussell hired this affiant in March 1846.

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from the defendant & that he Said RussellRussell Paid the Said hire of this affiant to Said defendant.

This affiant further states that relying solely upon the testimony of Said RussellRussell to prove these facts & knowing no other person by whom he could prove the same facts, or other facts tending to the Same [ends], he went into trial. When to his Surprise Said RussellRussell testifyed in effect that he did not hire this affiant from XSaid defendant, nor did he pay Said hire to Said defendant, for that his Knowledge of such facts was solely derived from the information of his Wife. This affiant thus taken by surprise in the testimony of Said RussellRussell [,] was unable to establish Said facts to the Satisfaction of the Jury, for which reason, he supposes, a verdict was rendered against him.

This affiant states that previous to said trial he had no knowledge that the Wife of Said RussellRussell had any knowledge that this affiant was held in Slavery by Said defendant but that if a new trial is granted to him he expects to prove by the testimony of the Wife of Said RussellRussell that Said defendant, previous to the Commencement of Said Suit hired this affiant to the Wife of Said RussellRussell ,

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acting as the agent of her Said husband, and that her acts in this ocassion were ratifyed & approved by her Said husband & that Said defendant Claimed this affiant as her Slave.

This affiant avers that previous to Said trial he had no knowledge that the Wife of Said RussellRussell , or any other person ^ than Said RussellRussell had any knowledge that this affiant was held in Slavery by Said defendant.

This affiant avers that the facts [illegible] in his petition to sue for his freedom are true. That he was & is a free man & was at the time of the Commencement of this Suit held in Slavery by Said defendant [.] That the verdict against this affiant is unjust & oppressive tending to the [...]tion of rights to which he is entitled by the laws of the land. And that upon a new Xtrial he will be able to establish his right to freedom & to prove that he was & is unjustly & unlawfully held in Slavery by Said defendant.

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