Depositions of witnesses produced, sworn
and examined pursuant to the annexed
notice, at the office of the Jailor of St.
Louis County, in St. Louis County, State ofMissouri
MissouriMissouri, before me, SamuelSamuel A. Bennett
a Notary Public within and for said county
to be read in evidence in a certain cause
now pending in the Circuit CourtCircuit Court of St.
Louis County, in said state, wherein GeorgeGeorge Johnson
JohnsonGeorge Johnson is plaintiff and ReubenReuben
BartlettBartlett is defendant on behalf of the
Job V. Kimber, of lawful age, being produ
ced, sworn and examined on behalf of
the plaintiff, deposeth and saith:-
"I reside in Pekin, IllinoisIllinois.
I have lived in BrownsvilleBrownsville PennsylvaniaPennsylvania. That
was my home until three weeks since.
Ques: Do you know George JohnsonGeorge Johnson
the plaintiff in this suit?
Ans: I do know him.
Ques: How long have you known him?
Ans: I can't just state the number of
years I have known him. He worked
for me as fireman on a steamboat
some six years ago. I knew him before that.
I am an engineer. Plaintiff has been
on boats with me since that time.
Ques: Where did you get acquainted
Ans: I think
Ques: Did he hire himself to you
Ans: He did.
Ques: Who paid him his wages?
Ans: The Clerk of the Boat
Ques: Were his wages paid to
Ques: Do you recollect what boat
it was & where she ran to?
Ans: The boat that he was on six
years ago was the Colorado, which
ran between St. LouisSt Louis & PittsburghPittsburgh.
Afterwards I knew him on the DanubeDanube
which ran at that time from Cincinnati
Ques: Was plaintiff at that time
a free man or a slave?
Ans: My impression was that
he was a free man because
he acted for himself. That is my only
reason for thinking so. He lived in
the town where I was born & raised
in a free State.
Ques: Was he known as a free man?
Ans: I dont know whether other
people thought he was a free man
or a slave. I thought he was a free man
Further this deponent saith not.
Job V. Kimber.