David McFoy, a person of color v. William Brown
View original image: Page  071
[missing figure]
David McFoyDavid McFoy
vs.
William BrownWilliam Brown

In the St Louis CircuitCircuit Court
CourtCircuit Court Nov. Term 1851.
St Louis County, to wit:

Now at this day comes the plaintiff
and moves the court to suppress the
depositions so called claimed to have been
taken in this cause by defendant for the
reasons:

1. That there was no notice, as required by law
of the time and place of taking the so called
depostitions served upon plaintiff or his
attorney.

2.That, Plaintiff had no sufficient notice
of the taking said so called depositions.

3. Because the certificate of the officer before
whom the so called depostitions purport to
have been taken is not in conformity to law

4 Because the so called depositions were
not reduced to writing & taken as requir
ed by law in the presence of the offi
cer taking there proper officer and
taken in accordance with the law.

5 Because the witnesses were not sworn or
affirmed in accordance with the law

LaDue & Shrere
attys for plff

View original image: Page  072
[missing figure]