Patsy Curd vs. William H. Barksdale
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PatsyPatsy Curd CurdPatsy Curd Plaintiff
vs
WilliamWilliam HH Barksdale BarksdaleH Barksdale Defendant

In the Circuit CourtCircuit Court
of St Louis County
November Term 1850

The defendant by his attorney causes &
moves the court to supress the depositions filed
by the plaintiff in this cause for the following
reasons

1st The commission under which said depositions were
taken was not & is not directed to any judge
justice of the peace or other Judicial officer of the
government in which the deponents resided nor to
the officers of any government

2nd There is no evidence in said depositions that the
witness were sworn to testify the whole truth as
required by the law of missouri

3d there is no evidence accompanying said depositions
that the examation of deponents was reduced
to writing in the presence of the officer who
took and certified the depositions

4 there is no evidence that the depositions were
subscribed & sworn to as required in sec 16 of the
law of missouri depositions

5th Said depositions are in other respects irregular
informal & illigal

Wells & Buckner
attys for Defendant