Samuel, an infant, by and through his next friend, Marcy T. Andrews v. Barnard Lynch
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SamuelSamuel of Color Plff
vs
Barnard M LynchBarnard M Lynch
Deft

In Circuit CourtCircuit Court
of
St. Louis County

Samuel T Glover on his oath says he was
retained as counsel by deft in this case before
the commencement of the present regular
term of this Court, and was told by his client
at the time either that an arrangement
had been made, or could be made with Mr.
RichmondRichmond the atty for the plaintiff by which
the determination of this case and the case of
EdwardEdward vs. same deft then & now pending in
this Court might depend upon the determination
of the case of MaryMary vs.CalvertCalvert which last
named case was also pending in this Court
and is still pending.

Afterwards Mr. RichmondRichmond atty for the plffs in
said three above mentioned causes having as
he informed affiant sent specially to OhioOhio
for witnesses whose evidence by him deemed
[ deemed ] pertinent to the causes of all said
plaintiffs met this affiant by an amicable
appointment to take the depositions of
said witnesses this affiant and Mr. RichmondRichmond
agreeing to take the said depositions
by consent.

On the occasion last named a conversation
was held between the affiant and Mr. RichmondRichmond
in regard to the said depositions and
the said cases, and this affiant understood
Mr. RichmondRichmond distinctly to say that as the determination

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of the cases of SamuelSamuel & EdwardEdward
would depend upon the determination
of the case of MaryMary vsCalvertCalvert he would
only take the depositions of the witnesses
in Marys case, and to refer to affiant
for his assent to the same, and this affiant
did say to Mr. RichmondRichmond that in
that case it would duly be necessary to
take the testimony of the witnesses in
Marys case, and said depositions were
accordingly taken by consent in Marys
case and were not taken in either of
the cases of SamuelSamuel or EdwardEdward , and he
believes said witnesses returned to OhioOhio,
This affiant does not charge Mr. RichmondRichmond
with any intention to deceive him or lull
him into security, but the effect of the above
conversation on his mind was to place him
entirely at ease in regard to the said cases of
SamuelSamuel and EdwardEdward , and affiant gave himself
no care as to pleading in or preparing
the same for trial, nor did the
plaintiffs make any preparation of said
cases or either of them nor did he suppose any
step would be taken
in them till Marys
case was decided.

Samuel T Glover

Sworn to & Subscribed 8th Jany 1852

M. S. CerreM S Cerre Clk.