Ralph, a man of colour v. James Coleman and Duncan Coleman
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Executed this writ on ColemanColeman Duncan DuncanColeman Duncan in the CityCity of St Louis
ofCity of St Louis StCity of St Louis. LouisCity of St LouisMay 26. 1830 by reading to him the Declaration petition summary& orders of the Judge- On JamesJames Duncan
DuncanJames Duncan in the city of St LouisSt LouisJune 4. 1830 by reading to him
the, declaration in petition summons& order of the Judge.

R. SimpsonR Simpson Shff

Service $ 2.00
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No. 35

St Louis Circuit CourtCircuit Court
July Term 1830

RalphRalph a man of
color
vs
ColemanColeman Duncan DuncanColeman Duncan
&James DuncanJames Duncan

suitforfreedom

Action of a assault
& Battery &false
imprisonment
Dam. $ 500.

BirdBird for plif

filed May 26th 1830

A GambleArchibald Gamble Clk

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County of St LouisCounty of St Louis
The state of MissouriMissouri

To the Sheriff of St Louis County
greeting

We command you to summon JamesJames Duncan
DuncanJames Duncan and ColemanColeman Duncan DuncanColeman Duncan that they be
and appear before the Judge of our CircuitCircuit Court
CourtCircuit Court at the next term there of to be held
at the City of St LouisCity of St Louis within and for the
County of St LouisCounty of St Louis on the fourth Monday
of July next then and there to answer
unto RalphRalph a man of color of a plea of
trespassassault&battery& false imprisonment
to the damage of said plaintiff of five hundred
dollars. And have you then there this writ

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Witness of Archibald GambleArchibald Gamble
of our said Court
26th day of may

Archibald GambleArchibald Gamble Clerk

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To the Honorable WilliamWilliam C.CarrCarr Judge of the CircuitCircuit Court
CourtsCircuit Court for the third Judicial CircuitsCircuit Court of the state of
MissouriMissouri

1. The petition of RalphRalph a man of
Colour represents that he is justly entitled to his freedom
but that he is held in slavery now in St LouisSt Louisin said
Circuit by JamesJames Duncan Duncan & Colman DuncanJames Duncan
your petitioner further says that he has resided
in the state of IllinoisIllinois & the Territory of MichiganMichigan
for between two& three years lastpast here he
was taken by James DuncanJames Duncan &where he has
labored for him at his request &with the full knowledge &consentof said ColemanColeman your petititioner
says thats he said James DuncanJames Duncan in the state of
IllinoisIllinois for his freedom that said JamesJames wentinto
Courts where your petitioner had sued for his freedom
&represents that your petitioner belonged
to Coleman DuncanColeman Duncan where upon said suit
wasdismissed&before your petitioner could
sue said ColemanColeman for his freedom&serveprocess
upon him said ColemanColeman had escaped or concealed
himselfso that process could not be secured upon
him & in the mean time said James DuncanJames Duncan
kidnapped your petitioner & brought him to St LouisSt Louis
your petitioner further says that he believesit is
the intention of said James & Coleman to take

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your petitioner to some place where the facts of his
freedom is unknown &sell him for a slave
your petitioner prays thats he may be permitted to
sue as a poorperson to establish his freedom that
counselmay be assigned to him & that such order
may be made & such processissued in his behalf
as his personal safety requires & the lawwill warrant

RalphRalph by G A BirdG A Bird
his agent & atty

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GustavusGustavus A Bird A BirdGustavus A Bird states on oath
that he believes the facts stated in the
above petition are substantially true
sworn to before me this 26 may 1830

WillWill C. CarrCarr .
G A BirdG A Bird

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State of MissouriMissouri
St.Louis County

It is here by ordered that RalphRalph the
above named petitioner be permitted to sue as a
poor person to establish his freedom &GustavusGustavus A Bird AGustavus A Bird BirdGustavus A Bird
is assigned as his counsel to commence&present his
suit for freedom; it is ordered that said RalphRalph shall have reasonable liberty to attend his counsel& the Courts when occasion may require &
that said RalphRalph shall not be removed out of
the jurisdiction of the Circuit Courts of St LouisCircuit Court
County nor be subjected to any severity because of
his application for freedom Given under my hand
this 26 day of May AD 1830

WillWill . C. CarrCarr

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State of MissouriMissouri
St LouisSt Louis county

GustavusGustavus A Bird AGustavus A Bird BirdGustavus A Bird on oath says that
RalphRalph a man of color who has been
this day permitted to sue for his freedom is now in the
possession of JamesJames Duncan Duncan & Coleman DuncanJames Duncan who
are residents of the state of KentuckyKentucky- this affiant has
given cause to suspect&believe& does suspect&believe
that it is the intention of said James &Coleman
to remove said RalphRalph out of the state of MissouriMissouri
& that the order which has been made that said RalphRalph
shall not be removedout of the jurisdiction of the
Circuit is in danger of being
violated unless said James & Coleman shall be
restrained by the order of the Judge of said Courts

G A BirdG A Bird

Sworn to before me this 26 may 1830.

WillWill . C. CarrCarr

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At chambers 26 may 1830.

State of MissouriMissouri
County of St LouisCounty of St Louis sct.

In consequence of the foregoing
affidavit it is hereby ordered that the
before named JamesJames Duncan Duncan & Coleman DuncanJames Duncan
enter into a recognizance with security

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in the sum of five hundred with Con
dition that the petitioner RalphRalph shall
not be removed out of the jurisdiction of
the circuit Court of St louis County
But in case said James & Coleman shall
refuse to enter into such recognizance
then it is further orderd that the
sheriff of St Louis
County take possession
of said RalphRalph &hirehim out taking
land in the sum of five hundred
dollars with security &conditions
as the law directs.

WillWill C. CarrCarr

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State of MissouriMissouri
St Louis County Ss

on this 28th day of may 1830came
before me RalphRalph a man of Colour & being sworn
says he has lived at points in MichiganMichigan
Territory & in the state of IllinoisIllinois for more than 2
years lastpast that he was sent there by
Coleman DuncanColeman Duncan who now claims this affiant as
his slave that this affiant sued James DuncanJames Duncan
who said I belonged to him) for his freedom that
said JamesJames about the fourth of this month got me to dismiss said suit
& then took me to StSt Louis. LouisSt Louis MissouriMissouri& said
if I would not come he would put me in irons&
take me to KentuckyKentucky.Coleman DuncanColeman Duncan now claims
me as his slave I have offered him $ 100 for
my freedom & my mate for $ 200 morewhich he
refuses to take I am in fear that JamesJames &ColemanColeman Duncan
DuncanColeman Duncan have conspired together to take me by
force from this place & sell me as a slave or
will cause me to be thus taken & sold I am
well convinced that I have been brought here in
pursuance of an agreementbetween said ColemanColeman
&James DuncanJames Duncan & I want such measures taken
as willsecure my personal safety.

RalphRalph his mark

Sworn & subscribed to before
me May 28th 1830.

G. A.BirdJustice of the Peacein & for
St. Louis County MissouriMissouri
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On behalf of the
witness named RalphRalph
I ask that JamesJames &
Coleman DuncanColeman Duncan
may be compelled
to give security to
keep the peace &
Especally in relation to
said Ralph

G A BirdG A Bird

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Ralph vs.
JamesJames Duncan Duncan &
Coleman DuncanJames Duncan

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County Of St. LouisSt Louis, Sct.
State of MissouriMissouri,

To Any Judge Or Justice Of The Peace Of the state of KentuckyKentucky
--Greeting.

We, reposing special trust and confidence in your integrity and circumspection, do require and command you, that you
cause to come before you such person, or persons, as shall be named to you by RalphRalph a colored man-Coleman DuncanColeman Duncan or JamesJames Duncan
DuncanJames Duncan their attorney or agent, and him, her or them examine upon his, her or their corporal oath, (to be by you administered,) touch-
ing> their knowledge of any thing that may relate to a certain matter of controversy, now pending in our Circuit CourtCircuit Court ,
for the county of St. LouisSt Louis, wherein RalphRalph a colored man is plaintiff and Coleman DuncanColeman Duncan and
James DuncanJames Duncan are defendants, on the part of the said defendant, and having reduced the said
depositions so taken by you as aforesaid, into writing, you are required to send the same, together with this commission,
enclosed under your seal, to our said Circuit CourtCircuit Court , with all convenient speed.

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Witness, Archibald GambleArchibald Gamble , Clerk of our said Circuit CourtCircuit Court , at
the City of St. LouisCity of St Louis, this eighteenth day of June In the year of our Lord one thousand eight hundred and thirty

Archibald GambleArchibald Gamble

Clerk, C.C.
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RalphRalph a Man of color
vs
Coleman DuncanColeman Duncan and
James DuncanJames Duncan

In vacation June 18th 1830
clerks office of the St Louis Circuit CourtCircuit Court

On application of the attorney for the defendants it is Ruled
that a Dedimius issue to any Judge or Justice of the Peace of this
state of KentuckyKentucky to take the depositions of witnesses to be read
on the trial of the above cause on the part of the defendants

ArchibaldArchibald gamble clerk

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RalphRalph
vs
Coleman DuncanColeman Duncan

HiramHiram Woodruff WoodruffHiram Woodruff
John DuncanJohn Duncan
BrisonBrison Pursley PursleyBrison Pursley

for defendant
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RalphRalph a man of Color
vs
Coleman DuncanColeman Duncan
and James DuncanJames Duncan

To the above named plaintiff and to Gustavus. A. Bird Esqr attorney for
said plaintiff.

Take notice, that in pursuance of a writ of
dedimus issued by the Clerk of the Circuit Court of the County ofCounty of St Louis
St. LouisCounty of St Louis, we shall attend at the dwelling house of John Laffoon
in HopkinsHopkins County CountyHopkins County in the State ofKentucky KentuckyKentucky on the twenty sixth, twenty seventh and twenty Eight days of July next, between the
hours of six in the forenoon and six in the afternoon of the
said days respectively, then and there to take deposition of
witnesses to be read in Evidence on the trial of the above Cause

June 23rd 1830.

Coleman DuncanColeman Duncan
and James DuncanJames Duncan
by E. BatesEdward Bates their Atto.

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I acknowledge to have
received a copy of the
within this 26th day of June 1830at St. LouisSt Louis

G. A. Bird atty
for Ralph

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Ralph a man of Color
vs
Coleman DuncanColeman Duncan
and James DuncanJames Duncan

Notice to take depositions
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Coleman DuncanColeman Duncan &
James DuncanJames Duncan
vs
RalphRalph , a man of Color

and the said Coleman & James by E. BatesEdward Bates
their attorney, come & defend the force & injury
wherefore & say that they are not guilty of the wrongs
trespasses above laid to their charge, in manner
& form as the said RalphRalph has above in declaring
Complained against them &ofthis
they put themselves upon the County.

E. BatesEdward Bates

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and for as further plea in this behalf
the said Coleman & James say that the said
RalphRalph ought not to have or maintain his action aforesaid ...
them, because they say that at the time of the committing
of the said supposed trespasses, the said RalphRalph
was, & still is a slave, without this that the said
RalphRalph was, at the said time, a free person, as
in by his declaration
of this they put themselves upon the court

filed July 28th 1830

A. GambleArchibald Gamble Clk

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No 35

July Term 1830

ColemanColeman &JamesJames Duncan
DuncanJames Duncan
vs.
RalphRalph , a man of Color

plea 1. N.G..
2. pltff a slave.

filed July 28th 1830

A GambleArchibald Gamble Clk

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the deposition of witnessRalphRalph a taken at the Dwelling
House of John Laffoon in the County ofCounty of Hopkins HopkinsCounty of Hopkins
KentuckyKentucky, state on the 26th, 27th and 28th day of July 1830Between the hours of six in the forenoon and
six in the afternoon of said day Respectively
Agreeably to the notice here unto annexed to be
Read as evidence a On the part of the Defendant in
A suit now pending in the Circuit CourtCircuit Court
in the County of St. LouisCounty of St Louis State of MissouriMissouri
wherein RalphRalph a Coloured man is plaintiff and
ColemanColeman Duncan DuncanColeman Duncan and JamesJames Duncan DuncanJames Duncan are
defendants -

July 26th 1830such agreeable to noticed and adjourned
until 27th.

27th July 1830 agreeable to adjournment
the deposition of Hiram WoodruffHiram Woodruff taken in the
above case this deponent being of lawful
age and first duly sworn deposith and sayeth
Question by deft

did or did you not start to orleansaboard of a
boat Belonging to John DuncanJohn Duncan and
BrisonBrison Pursley PursleyBrison Pursley in Company with JesseJesse Duncan
DuncanJesse Duncan and a Coloured man named RalphRalph
the property of Coleman DuncanColeman Duncan

Answer. I did Question by same
did or did not the boat get slow before you
got very far

Answer it did

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Question by same

did or did not you and JesseJesse Duncan DuncanJesse Duncan quit
the boat and goon to Fever River together

Answer I did

Question by same
did or did not Jesse DuncanJesse Duncan take the
above named Coloured man RalphRalph with him
to Fever River

Answer he did

Question by Same
did or did you not hear Jesse DuncanJesse Duncan Say
that he had hired the above named Coloured
man RalphRalph of Coleman DuncanColeman Duncan in the state
Of KentuckyKentucky. Hiram WoodruffHiram Woodruff
Answer I did

And further this deponent SayethSayeth

The deposition of John DuncanJohn Duncan taken at the
same time and in the same case this
deponent Being of lawfull age and first
duly sworn deposith and sayth

Question by deft

was or was you not present in the spring of
1828 in KentuckyKentucky in Company with Coleman DuncanColeman Duncan
and Jesse DuncanJesse Duncan and heard Coleman DuncanColeman Duncan
hire unto Jesse DuncanJesse Duncan the above named

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Coloured man RalphRalph for twelvemonths page 3rd
Answer I did

Question By Same was or was you not in
Company with the said JesseJesse and ColemanColeman Duncan
DuncanColeman Duncan in the year 1829 in KentuckyKentucky and
heard Coleman DuncanColeman Duncan and JesseJesse Duncan DuncanJesse Duncan
Settle up for the hire of the Coloured man RalphRalph
years Work - Answer I did

Question by same did or ded you not hear
Coleman DuncanColeman Duncan demand of JesseJesse Duncan DuncanJesse Duncan
to Deliver him his negro man RalphRalph
Answer I did

Question by same have you or have you not
lived with saidColeman DuncanColeman Duncan since the time
of settlement for the hire of said negro RalphRalph
Answer I have ; Question by same do or do
you not know that Jesse DuncanJesse Duncan never
returned said negro RalphRalph to Coleman DuncanColeman Duncan
Agreeable to Contract - Answer he never
did - Question by same was or was
not JesseJesse Duncan DuncanJesse Duncan Bound to Deliver to ColemanColeman Duncan
DuncanColeman Duncan the Coloured man RalphRalph when Called for
Answer as I understood -

John DuncanJohn Duncan
and further this Deponent SayethSayeth not

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the deposition of BrisonBrison Pursley PursleyBrison Pursley taken in the same
Case and at the same time and place this deponent
Being of lawfull age and first Duly sworn deposith
and SayethSayeth - Question By deft

did or did not JesseJesse Duncan DuncanJesse Duncan Stash down the
river in your Boat which was Bound for OrleansOrleans in 1828 with a
Coloured man with him named RalphRalph said to be the property
of Coleman DuncanColeman Duncan . Answer yes he did
Question By Same did or did not your Boat
get slow before you got very far

Answer it did - Question By Same
did or did not the saidJesseJesse Duncan DuncanJesse Duncan leave the
Boat and take the Coloured man RalphRalph with
him - Answer he did / Question by same
did you not or did you Ever hear me give
the said JesseJesse Duncan DuncanJesse Duncan leave to take the said
Coloured man RalphRalph out of the State ofKentucky KentuckyKentucky
Answer I never did
BrisonBrison Pursley PursleyBrison Pursley
and further this deponent SayethSayeth not

Adjourned untill the 28th July 1830

J. Laffoon Pp.

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July 28th 1830 a agreeable to adjournment
the Deposition of IsaacIsaac Metcalf MetcalfIsaac Metcalf taken on
the same Case this deponent being of lawful
age and first Duly Sworn Deposith and sayth

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Questions By Defendant

page 5th

did or did you not hear JesseJesse Duncan DuncanJesse Duncan state in
your presence of me Coleman DuncanColeman Duncan within the
state of KentuckyKentucky that he the deceased JesseJesse Duncan DuncanJesse Duncan
did hire of me a coloured man named RalphRalph
in the state of KentuckyKentucky to go with him aboard
of a Boat which was Bound to orleans Belonging
to Brison PursleyBrison Pursley and John DuncanJohn Duncan

Answer Said, Question by same, did or
did not said Jesse DuncanJesse Duncan tell you that he
hired this coloured man named RalphRalph of me
Coleman DuncanColeman Duncan in the State ofKentucky KentuckyKentucky and was to return him
at the Expiration of one year / Answer he did
Question By same. did or did not said JesseJesse Duncan
DuncanJesse Duncan also tell you that he had in the
state of KentuckyKentucky billed up with me for the
Hire of the above named coloured man
named RalphRalph for the one year served and
was Bound to return him to me
Answer I did three or four times hear him Repeat
the same words, Question By same did or
did not JesseJesse Duncan DuncanJesse Duncan tell you that I ColemanColeman Duncan
DuncanColeman Duncan did not at any time Give him any
leave or accordingly to take the above named coloured
man RalphRalph out of the state of KentuckyKentucky
Answer, he did of different times Isaac MetcalfIsaac Metcalf
and further this deponant sayeth not

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page 6110

The deposition of Edward Ridly taken in the same
case this deponant being of lawful age and first
Duly Sworn deposith and sayeth

Question By Defendant. did or did you not hear
JesseJesse Duncan DuncanJesse Duncan state at the house of Isaac MetcalfIsaac Metcalf
state that he hired the above named coloured man
RalphRalph of me Coleman DuncanColeman Duncan in the State ofKentucky
KentuckyKentucky for the term of One year

Answer I did, Question By same, did or did
you not also hear JesseJesse Duncan DuncanJesse Duncan say that he
had settled up with me in the State ofKentucky KentuckyKentucky for
the one year services of the above named negro
RalphRalph , Answer I did, Question by same
did or did you not hear Jesse DuncanJesse Duncan state in the year 1829 that
He was Bound by contract to Return the said coloured
man RalphRalph to one at the expiration of one
year and was to as soon as he was able to attend
to his business Answer said, Question by same
was or was not this shortly Before the death of the
said Jesse DuncanJesse Duncan , Answer. it was

Question By same do or do you not believe
that the Said Jesse DuncanJesse Duncan was then in his right mind
Answer. I think he was. Question by
same did or did you not hear Jesse DuncanJesse Duncan
state some time Before that when in his proper
He atlth that I never gave him any leave or author-
ity

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To Take the above named by coloured man
RalphRalph out of the State of KentuckyKentucky, Answer. Idid

EdwardEdward his Ridly
Mark

and further this deponent SayethSayeth not
the foregoing Depositions of HiramHiram Woodruff WoodruffHiram Woodruff
John DuncanJohn Duncan BrisonBrison Pursley PursleyBrison Pursley IsaacIsaac Metcalf MetcalfIsaac Metcalf
and Edward Ridly was this day and the foregoing
days taken and subscribed and sworn to By
the Said Deponents Before the under - assigned
a freedom of the peace for Hopkins CountyHopkins County
KentuckyKentucky at the house and place and for the purposes
Stated in the captionsgivenunder my
Hand this 28th July 1830

JohnJohn B BJohn B .LaffoonJ.P.H.C.

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KentuckyKentucky
HopkinsHopkins County. CountyHopkins County Ss

ss.

I SamuelSamuel WoodsonWoodson clerk of the Court for the County
aforesaid do hereby certify that JohnJohn B BJohn B . Laffoonacquired
before whom the foregoing depositions of HiramHiram Woodruff WoodruffHiram Woodruff
and others appear to have been taken and whose
name is subscribed to the foregoing certificate is
and was at the time of subscribing the same
an acting Justice of the peace in & for said
County as to that fullfaith and orderith are
due and ought to be given to all his acts
whom acting in his official character as well
in court of Justice as thereof

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In testimony whereof I have
her unto subscribed my name
the 11th day of August 1830 &
in the 39th year of the common wealth

Sam. WoodsonWoodson

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I Joseph F Morehane a Justice of the Peace within and for the
County of White and State of IllinoisIllinois do here by certify that LowryLowry Hay
HayLowry Hay the above name deponant was by me duly sworn to testify the
whole truth of his knowledge touching the matter in Controversy between
the parties aforesaid, that his examination was reduced to writing and
by him subscribed in my presence on the day between the hours and at
the place in that behalf first aforesaid.

J S F Morehane J. P.

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State ofIllinois IllinoisIllinois
White CountyWhite County

ss.

I James Ratcliff Clerk of the CircuitCircuit Court
CourtCircuit Court in and for said County of White do certify that
Joseph F.Morchane Esq. who made the above certificate
and before whom the foregoing depostition was taken
now is and was at the date of certifying an acting
Justice of the Peace within and for said County
confirmed and qualified

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In testimony where of I have here unto set
my hand and affixed the seal of said Court
at Carmi this 24th day of March 1831

Ja, Ratcliff

Cost bill
Justice costs - 1.25
Witness fee - 50
Constable serving
& Milage -- 31 1/4
Clerk fee- 50
postage - 37 1/2 Received payment $ 3/4
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The Deposition of Lowry HayLowry Hay taken before me a Justice of the peace within
and for the County of White and State of IllinoisIllinois on the 23rd day of March in the year of our Lord eighteen Hundred and thirty one between the
hours of eight o'clock in the forenoon & six o'clock in the afternoon of
said day at the office of the clerk of the Circuit CourtCircuit Court of White CountyWhite County &
State of IllinoisIllinois at the Town of Carmipursuant to the annexedDedimus
and notice to be read in evidence in a certain action pending in the
Circuit CourtCircuit Court of Saint LouisSt Louis County & State of MissouriMissouri wherein
RalphRalph a man of Colour is Plaintiff & James Duncan & Coleman Duncan
are defendants.

Lowry HayLowry Hay of lawful age being produced sworn & examined
on the part of the plaintiff, deposith and sayeth as follows. -

Question is the body of the note annexed to this Deposition and marked

A in your hand writing ?

Answer Yes, I belive it is.

Que- Did you sue said Coleman DuncanColeman Duncan sign & deliver said note
to said RalphRalph , if so when was said note made and where ?

Ans- The note was written at the SalineSaline are the 2nd day of December 1829. but I do not recollect to have
seen it signed and delivered

Question How long did said RalphRalph live in IllinoisIllinois before the execution
o said note?

Answer I believe about one month- perhaps a day or two over or
under that time.-

Question Was said RalphRalph when you know him reputed to be a slave or
a free man & of a slave whose was he reputed to be ?

Answer He was reputed to be a Slave, and to belong to a Mr.DuncanDuncan .

Question How long did Coleman DuncanColeman Duncan hire RalphRalph to labour
as the salt works in IllinoisIllinois near Shawneetown?

Answer I do not know of Coleman DuncanColeman Duncan hiring the labour of
RalphRalph , but am strongly under the impression that RalphRalph
hired out his own time.

Question What is the age, colour, size & Description of said negro man
RalphRalph as near as you can State?

Answer I have but an indistinct recollection of the man, but believe him to be about Forty years of age & of middle statute, I can't recollect of any other particulars by which to discribe
him.

Lowry Hay

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Ralph a man of color
vsColeman DuncanColeman Duncan &
James DuncanJames Duncan

Deposition

filed March 31st
opened April 11th 1831

A GambleArchibald Gamble clk

Lowry HayLowry Hay for pltff

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County Of St. LouisSt Louis, Sct.
The State Of MissouriMissouri,

To The Sheriff Of S. LouisS Louis County-Greeting.

You are hereby commanded to summon Charles BobbCharles Bobb . George BobbGeorge Bobb , ThomasThomas Cruson
CrusonThomas Cruson , John Steels & JudeJude Warner WarnerJude Warner
that setting aside all manner of excuse and delay, he be and appear in proper person before the
Judge of our Circuit CourtCircuit Court , on the Seventh day of Aprilnext, at the City ofCity of St Louis
St. LouisCity of St Louis, then and there to testify and the truth to say in a certain matter of controversy now
pending in our said Court, wherein RalphRalph a man of Color is plaintiff
and Coleman DuncanColeman Duncan & James DuncanJames Duncan are defendants on the
part of the plaintiff; and have you then there this writ,

[missing figure]
Witness, Archibald GambleArchibald Gamble , Clerk of our said CircuitCircuit Court
CourtCircuit Court , at the City of St.LouisCity of St Louis, this Fourteenth day of March in the year of our Lord one thousand eight hundred and thirty one

Archibald GambleArchibald Gamble

Clerk C.C.
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[missing figure]

Served on Jude WarnerJude Warner on the 15th day of March 1831 on John Steel on the 28 of same month on GeorgeGeorge and Charles BobbCharles Bobb
April 5th 1831by Reading the same to them
Thomas CrusonThomas Cruson not found John K WalkerJohn K Walker Sheriff

service 200 #x0024; 2,12 1/2
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[missing figure]

March Term 1831

RalphRalph
vs
ColemanColeman & James DuncanJames Duncan

Charles BobbCharles Bobb 4

George BobbGeorge Bobb 5

ThomasThomas Cruson CrusonThomas Cruson

John Steel

Jude WarnerJude Warner 15

7th April-
for pltff

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County Of St. LouisSt Louis, Sct.
The State Of MissouriMissouri,

To The Sheriff Of S.LouisS Louis County--Greeting.

You are hereby commanded to summon Joseph. V. Garnier
that setting aside all manner of excuse and delay, he be and appear in proper person before the Judge
of our Circuit CourtCircuit Court , on the Seventh day of Aprilnext, at the City of St. LouisCity of St Louis,
then and ther to testify and the truth to say in a certain matter of controversy now pending in our
said Court, wherein RalphRalph a man of Color is plaintiff and ColemanColeman Duncan
DuncanColeman Duncan & James DuncanJames Duncan is defendant on the part of the plaintiff;
and have you then there this writ,

[missing figure]
Witness, Archibald GambleArchibald Gamble , Clerk of our said CircuitCircuit Court
CourtCircuit Court , at the City of St.LouisCity of St Louis, this Ninth day of March in the year of our Lord one thousand eight hundred and thirty one

Archibald GambleArchibald Gamble

Clerk C.C.
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Executed this writ on Joseph V GarnierJoseph V Garnier on
the 21st day of March 1831 by reading it
to him in the city of St LouisSt Louis

J.K. WalkerK Walker Sheriff

by J. BrothertonJames Brotherton D P Shff

Service 50 cts
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[missing figure]

March Term 1831

RalphRalph
vs
ColemanColeman & James DuncanJames Duncan

Joseph V. GarnierJoseph V Garnier 21

for pltff
7th April

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[missing figure]

County Of St. LouisSt Louis, Sct.
The State Of MissouriMissouri,

To The Sheriff Of S.LouisS Louis County--Greeting.

You are hereby commanded to summon James DuncanJames Duncan , Joseph V. GarnierJoseph V Garnier
that setting aside all manner of excuse and delay, they be and appear in proper person before the Judge
of our Circuit CourtCircuit Court , on the 14th day of Aprilinstant, at the City of St. LouisCity of St Louis,
then and there to testify and the truth to say in a certain matter of controversy now pending in our
said Court, wherein RalphRalph is plaintiff and
Coleman DuncanColeman Duncan is defendant on the part of the plaintiff;
and have you then there this writ,

Witness,Archibald GambleArchibald Gamble , Clerk of our said CircuitCircuit Court
CourtCircuit Court , at the City of St.LouisCity of St Louis, this 8th day of April in the year of our Lord one thousand eight hundred and thirty one

A.GambleArchibald Gamble

Clerk C.C.
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[missing figure]

Executed this writ on James DuncanJames Duncan
and J.VJ V Garnier .GarnierJ V Garnier April 9th by
reading the same to them in the CountyCounty of St Louis
of St LouisCounty of St Louis

John K. WalkerJohn K Walker Sheriff

by S Blood D Sheriff

Service $1.00
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[missing figure]

March Term

RalphRalph
vs
ColemanColeman

James DuncanJames Duncan 9

Joseph V. GarnierJoseph V Garnier 9

14th April

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[missing figure]

County Of St. LouisSt Louis, Sct.
The State Of MissouriMissouri,

To The Sheriff Of S.LouisS Louis CountyâGreeting.

You are hereby commanded to summon Charles BobbCharles Bobb . Geroge Bobb,
Thomas CrusonThomas Cruson , John Steel JudeJude Warner WarnerJude Warner
that setting aside all manner of excuse and delay, he be and appear in proper person before the
Judge of our Circuit CourtCircuit Court , on the 14th day of Aprilinstant, at the City ofCity of St Louis
St. LouisCity of St Louis, then and ther to testify and the truth to say in a certain matter of controversy now
pending in our said Court, wherein RalphRalph is plaintiff
and ColemanColeman & James DuncanJames Duncan are defendants on the
part of the plaintiff; and have you then there this writ,

[missing figure]
Witness,Archibald GambleArchibald Gamble , Clerk of our said CircuitCircuit Court
CourtCircuit Court , at the City of St.LouisCity of St Louis, this 9th day of April in the year of our Lord one thousand eight hundred and 31

A GambleArchibald Gamble

Clerk C.C.
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[missing figure]

Executed this writ on John Steel April 11th
on Charles BobbCharles Bobb 12th april 1831 by Reading
it to them Jude WarnerJude Warner George BobbGeorge Bobb
& Thomas CrusonThomas Cruson not summoned for
want of time

John K WalkerJohn K Walker Sheriff

service $1.00
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[missing figure]

March Term '31

RalphRalph
vs
Coleman & James DuncanJames Duncan

Charles BobbCharles Bobb

George BobbGeorge Bobb

ThomasThomas Cruson CrusonThomas Cruson

John Steel 11

Jude WarnerJude Warner

14th April-

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[missing figure]

County Of St. LouisSt Louis, Sct.
The State Of MissouriMissouri,

To The Sheriff Of St. Louis County--Greeting.

You are hereby commanded to summon Robert DuncanRobert Duncan & JosephJoseph Garnier GarnierJoseph Garnier
that setting aside all manner of excuse and delay, they be and appear in proper person before the Judge
of our Circuit CourtCircuit Court , on the 14th day of April 1831, at the City of St. LouisCity of St Louis,
then and there to testify and the truth to say in a certain matter of controversy now pending in our
said Court, wherein RalphRalph a man of color is plaintiff and ColemanColeman Duncan
DuncanColeman Duncan & James DuncanJames Duncan is defendant on the part of the plaintiff;
and have you then there this writ,

[missing figure]
Witness,Archibald GambleArchibald Gamble , Clerk of our said CircuitCircuit Court
CourtCircuit Court , at the City of St.LouisCity of St Louis, this 14th day of April in the year of our Lord one thousand eight hundred and thirty one

A GambleArchibald Gamble

Clerk C.C.
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[missing figure]

Executed this writ on Robert DuncanRobert Duncan
and Joseph VJoseph V Garnier .GarnierJoseph V Garnier Esq.april 14th 1831
by Reading
the same to them in the
County of St LouisCounty of St Louis

John K WalkerJohn K Walker Sheriff

by S.Blood Dept Sheriff

Service $1.00
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[missing figure]

March 1831

RalphRalph a man of color
vs
Coleman DuncanColeman Duncan
James DuncanJames Duncan

Summons for RobertRobert Duncan

DuncanRobert Duncan & JosephJoseph Garnier
GarnierJoseph Garnier

14th April
pltff

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[missing figure]

County Of St. LouisSt Louis, Sct.
The State Of MissouriMissouri,

To The Sheriff Of S LouisS Louis CountyâGreeting.

You are hereby commanded to summon Dr. John Cornelius
RobertRobert Simpson SimpsonRobert Simpson HenryHenry vonPhul & CharlesCharles Wahrendorff WahrendorffCharles Wahrendorff
that setting aside all manner of excuse and delay, he be and appear in proper person before the
Judge of our Circuit CourtCircuit Court , forthwith at the City ofCity of St Louis
St. LouisCity of St Louis, then and there to testify and the truth to say in a certain matter of controversy now
pending in our said Court, wherein RalphRalph a man of color is plaintiff
and Coleman DuncanColeman Duncan & James DuncanJames Duncan defendant on the
part of the pltff; and have you then there this writ,

[missing figure]
Witness,Archibald GambleArchibald Gamble , Clerk of our said CircuitCircuit Court
CourtCircuit Court , at the City of St.LouisCity of St Louis, this 15th day of April in the year of our Lord one thousand eight hundred and thirty one

A GambleArchibald Gamble

Clerk C.C.
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[missing figure]

Executed this writ on John Cornelius
& Robert SimpsonRobert Simpson 15th April on Chas
Wahrendorff16th april 1831 by Reading
it to them HenryHenry Von Phul not found

John K WalkerJohn K Walker Sheriff

J. BrothertonJames Brotherton D P S Services $ 1 50
12 1/2
$ 1.62 1/2
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[missing figure]

March 1831

RalphRalph
vs
ColemanColeman & JamesJames Duncan
DuncanJames Duncan

for
Dr.John Cornelius

forthwith for
pltff

RR Simpson . SimpsonR Simpson 15

HenryHenry VonPhul &
16 CharlesCharles Wahrendorff WahrendorffCharles Wahrendorff pltff

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[missing figure]

County Of St. LouisSt Louis, Sct.
The State Of MissouriMissouri,

To The Sheriff Of S LouisS Louis County--Greeting.

You are hereby commanded to summon Mrs.Sally DuncanSally Duncan
that setting aside all manner of excuse and delay, she be and appear in proper person before the Judge
of our Circuit CourtCircuit Court , forthwith, at the City of St. LouisCity of St Louis,
then and there to testify and the truth to say in a certain matter of controversy now pending in our
said Court, wherein RalphRalph is plaintiff and
ColemanColeman & James DuncanJames Duncan defendant on the part of the Defendants;
and have you then there this writ,

[missing figure]
Witness,Archibald GambleArchibald Gamble , Clerk of our said CircuitCircuit Court
CourtCircuit Court , at the City of St.LouisCity of St Louis, this 18th day ofApril in the year of our Lord one thousand eight hundred and thirty one

A GambleArchibald Gamble

Clerk C.C.
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[missing figure]

March 1831

RalphRalph
vs
ColemanColeman & JamesJames Duncan
DuncanJames Duncan

for
Mrs.SallySally Duncans 18

forthwith for
Deft

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[missing figure]

Executed this writ by Reading it to
her on the 18th day of april 1831

John K WalkerJohn K Walker Sheriff

J.Brotherton Dp Sheriff

Service 50 cts
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[missing figure]

County Of St. LouisSt Louis, Sct.
The State Of MissouriMissouri,

To The Sheriff Of S LouisS Louis County--Greeting.

You are hereby commanded to summon Theodore LTheodore L McGill .McGillTheodore L McGill
that setting aside all manner of excuse and delay, he be and appear in proper person before the Judge
of our Circuit CourtCircuit Court , forthwith, at the City of St. LouisCity of St Louis,
then and there to testify and the truth to say in a certain matter of controversy now pending in our
said Court, wherein RalphRalph a man of color is plaintiff and ColemanColeman Duncan
DuncanColeman Duncan & James DuncanJames Duncan are defendants on the part of the plaintiff;
and have you then there this writ,

[missing figure]
Witness,Archibald GambleArchibald Gamble , Clerk of our said CircuitCircuit Court
CourtCircuit Court , at the City of St.LouisCity of St Louis, this 18th day of April in the year of our Lord one thousand eight hundred and thirty one

Arch GambleArchibald Gamble

Clerk C.C.
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[missing figure]

Executed this writ on Theo LTheo L McGill .McGillTheo L McGill
april 18th 1831 by Reading the same
to him in the County of St. LouisCounty of St Louis

John K WalkerJohn K Walker Sheriff

S. Blood Dept Sheriff

Service 50
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[missing figure]

March Term '31

RalphRalph
vs
C & J Duncan

TheodoreTheodore L McGill LTheodore L McGill .McGillTheodore L McGill

forthwith
pltff
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[missing figure]

State of MissouriMissouri
St Louis County ss.

Circuit CourtCircuit Court Third Judicial
Circuit Declaration.

And said plaintiff also complains
of said Coleman DuncanColeman Duncan for that
heretofore to wit on the second day of December 1829 at the County of GallatinCounty of Gallatin in the State ofIllinois
IllinoisIllinoistowith at St LouisSt Louis in the State of MissouriMissouri
the said ColemanColeman withforce & arms an assault
did make upon the said plaintiff & him
the said plaintiff did then & there beat
wound & ill treat & him the said plaintiff did then & there falsely imprison & did keep him
said plaintiff in false imprisonment there for a
longspan of time to wit from the time case
aforesaid untill the time of the commencement of this suit And the said plaintiff avers
that before & at the time of the committing
the said several grievances he was & still is
a free person & the said Defendant held & detained & still helds & detains him in
Slavery By means of which premises the said
plaintiff has been prevented from attending to his
ordinary business & availing himself of the
benefit of his labor by which business & Labor the
plaintiff could have& should have wages a
large sum of money to wit the sum of
five hundred dollars had not the Defendant
presented him by the means aforesaid wherefore
the said plaintiff says he is greatly injured & hath
sustained Damages to five hundred Dollars
therefore he sues

G A BirdG A Bird Attorney for
pltff

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[missing figure]

RalphRalph man of color
vs
Coleman DuncanColeman Duncan

AmendedNarr

Filed April 23rd 1831

A GambleArchibald Gamble
Clk

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[missing figure]

County Of St. LouisSt Louis, Sct.
The State Of MissouriMissouri,

To The Sheriff Of Saint LouisSt Louis County--Greeting.

You are hereby commanded to summon Mrs.Sally DuncanSally Duncan
that setting aside all manner of excuse and delay, she be and appear in proper person before the Judge
of our Circuit CourtCircuit Court , on the second day of Augustnext, at the City of St. LouisCity of St Louis,
then and there to testify and the truth to say in a certain matter of controversy now pending in our
said Court, wherein RalphRalph is plaintiff and ColemanColeman Duncan
DuncanColeman Duncan is defendant on the part of the defendant;
and have you then there this writ,

[missing figure]
Witness,Archibald GambleArchibald Gamble , Clerk of our said CircuitCircuit Court
CourtCircuit Court , at the City of St.LouisCity of St Louis, this twenty fifth day ofjune in the year of our Lord one thousand eight hundred and thirty one

Archibald GambleArchibald Gamble

Clerk C.C.
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[missing figure]

Executed this writ on Mrs.Sally DuncanSally Duncan in St LouisSt Louis
county on the 1st day of July 1831 by Reading
it to her

John K WalkerJohn K Walker Sheriff

by JJames Brotherton .BrothertonJames Brotherton Dept Sheriff

Service 50 cts
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[missing figure]

July Term 1831

RalphRalph
vs
Coleman DuncanColeman Duncan

for defendant

Mrs.Sally DuncanSally Duncan

2nd August

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[missing figure]

County Of St. LouisSt Louis, Sct.
The State Of MissouriMissouri,

To The Sheriff Of Saint LouisSt Louis CountyâGreeting.

You are hereby commanded to summon Theodore L McGillTheodore L McGill - RobertRobert Simpson SimpsonRobert Simpson
HenryHenry Von Phul- Charles WahrendorffCharles Wahrendorff Charles BobbCharles Bobb - George BobbGeorge Bobb - ThomasThomas Cruson
CrusonThomas Cruson - & John Steel
that setting aside all manner of excuse and delay, they be and appear in proper person before the
Judge of our Circuit CourtCircuit Court , on the second day of Augustnext, at the City ofCity of St Louis
St. LouisCity of St Louis, then and ther to testify and the truth to say in a certain matter of controversy now
pending in our said Court, wherein RalphRalph is plaintiff
and Coleman DuncanColeman Duncan is defendant on the
part of the plaintiff; and have you then there this writ,

[missing figure]
Witness,Archibald GambleArchibald Gamble , Clerk of our said CircuitCircuit Court
CourtCircuit Court , at the City of St.LouisCity of St Louis, this twenth fifth day of June in the year of our Lord one thousand eight hundred and thirty one

Archibald GambleArchibald Gamble

Clerk C.C.
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[missing figure]

Executed this writ on HenryHenry Von Phul & R. SimpsonR Simpson
6th July on John Steel 14th JulyTheo L Magill 16th July on Charles BobbCharles Bobb & George BobbGeorge Bobb 18th July 1831
in the St Louis County by reading it to them
CharlesCharles Wahrendorff WahrendorffCharles Wahrendorff sick unable to attend
Thomas CrusonThomas Cruson not found

John K WalkerJohn K Walker Shff

by J. BrothertonJames Brotherton Dept Shff

Service $3.00
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[missing figure]

July Term 1831

RalphRalph
vs
Coleman DuncanColeman Duncan

for plaintiff

Theodore L Magill 16

Robert SimpsonRobert Simpson 6 july

HenryHenry Von Phul 6

Charles WahrendorffCharles Wahrendorff

Charles BobbCharles Bobb 18

George BobbGeorge Bobb 18

ThomasThomas Cruson CrusonThomas Cruson

John Steel 11 14

on 2nd august

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[missing figure]

County Of St. LouisSt Louis, Sct.
The State Of MissouriMissouri,

To The Sheriff Of Saint LouisSt Louis CountyâGreeting.

You are hereby commanded to summon Jude WarnerJude Warner - JamesJames Duncan DuncanDuncan Robert
Joseph V.Garnier & RobertDuncan Robert DuncanJames Duncan
that setting aside all manner of excuse and delay, he be and appear in proper person before the
Judge of our Circuit CourtCircuit Court , on the second day of Augustnext, at the City ofCity of St Louis
St. LouisCity of St Louis, then and there to testify and the truth to say in a certain matter of controversy now
pending in our said Court, wherein RalphRalph is plaintiff
and Coleman DuncanColeman Duncan is defendant on the
part of the plaintiff; and have you then there this writ,

[missing figure]
Witness,Archibald GambleArchibald Gamble , Clerk of our said CircuitCircuit Court
CourtCircuit Court , at the City of St.LouisCity of St Louis, this twenty fifth day of June in the year of our Lord one thousand eight hundred and thirty one

Archibald GambleArchibald Gamble

Clerk C.C.
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[missing figure]

Executed this writ on Robert DuncanRobert Duncan 2nd July on Joseph VJoseph V Garnier GarnierJoseph V Garnier 6th July 1831 in
the county of St LouisSt Louis by reading it to
them Jude WarnerJude Warner & James DuncanJames Duncan not
found in my county

John K WalkerJohn K Walker Sheriff

Service $1 00
25
$ 1.25
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[missing figure]

July Term 1831

RalphRalph
vs
Coleman DuncanColeman Duncan

for plaintiff

Jude Warmer

James DuncanJames Duncan

Joseph VJoseph V Garnier GarnierJoseph V Garnier 6

Henry Duncan

2 july

on 2nd August

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[missing figure]

County Of St. LouisSt Louis, Sct.
State of MissouriMissouri,

To Any Judge Or Justice Of The Peace Of the State of KentuckyKentucky
--Greeting

We, reposing special trust and confidence in your integrity and circumspection, do require and command you, that you
cause to come before you such person, or persons, as shall be named to you by RalphRalph a man of color or Coleman DuncanColeman Duncan
their attorney or agent, and him, her or them examine upon his, her or their corporal oath, (to be by you administred,) touching
their knowledge of any thing that may relate to a certain of controversy, now pending in our circuit Court,
for the county of St. LouisSt Louis, wherein RalphRalph a man matter of color is plaintiff and Coleman DuncanColeman Duncan
is defendant, on the part of the said plaintiff, and having reduced the said
depositions so taken by you as aforesaid, into writing, you are required to send the same, together with this commission,
enclosed under your seal, to our said circuit court, with all convenient speed.

[missing figure]
Witness, Archibald GambleArchibald Gamble , Clerk of our said Circuit CourtCircuit Court , at
the City of St. LouisCity of St Louis, this Twenty Eighth day of May in the year of our Lord one thousand eight hundred and thirty one

Archibald GambleArchibald Gamble

Clerk, C.C.
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[missing figure]
RalphRalph a man of color
vs
Coleman DuncanColeman Duncan

In vacation 28th May 1831
Clerks office of the st. Louis Circuit CourtCircuit Court

On the application of the attorney for the plaintiff it is Ruled
that a Dedimus issue to any Judge or Justice of the peace of the StateKentucky
of KentuckyKentucky to take the depositions of witnesses to be read in evidence
on the trial of this cause on the part of the plaintiff

A true copy of the Rule

Archibald GambleArchibald Gamble clerk

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[missing figure]
Copy of native
RalphRalph a man of color
vs
Coleman DuncanColeman Duncan

In the St LouisSt Louis Circuit court &
State of MissouriMissouri

To the above named defendant
& Edward BatesEdward Bates Esqure his attorney
he take notice that on the 27th 28th 29th & 30th days of June instant at the court house in the town of
MadisonvilleMadisonville in Hopkins CountyHopkins County and State of KentuckyKentucky
between the hours of eight O clock in the forenoon &
6 O clock in the afternoon of each of said days
I shall prove to take the Depositions of witnesses
to be read in evidence on the trial of the above
cause June 1st 1831

Yours & G A BirdG A Bird attorney for
Plaintiff

This commission must be
annexed to the Depositions
& sent back withthem
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[missing figure]

Depositions of witnesses produced sworn & examined on
the / here insert the day /or days / on which the Depositions
shall be taken / in the year of our Lord eighteen hundred & thirty one between the hours of eight O clock in the
forenoon & six O clock in the afternoon of said day
/ar of each of said days as the case may be at the Court
house on the town of MadisonvilleMadisonville Hopkins CountyHopkins County
and State of KentuckyKentucky before me / A.B.a
Justice of the peace within & for the County aforesaid
in a certain cause now depending in the Circuit
Court of the County of St LouisCounty of St Louis in the state of MissouriMissouri
between RalphRalph a man of color Plaintiff & ColemanColeman Duncan
DuncanColeman Duncan Defendant
on the part of the Plaintiff
E.B.of lawful age being produced Sworn & examined on
the part of the plaintiff Deposith & saith / here insert the
statement of the witnesses)

(note) each deposition must be subscribed by the witness and
the office must annex at the fact therof the following
certificate.

Sworn & Subscribed to before me this day of June 1831
at the place & between the hours in that behalf first
aforesaid

A. B. J. Peace

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[missing figure]

At the end of all the Depositions should be a certificate
in the following form

I A.B a Justice of the peace within & for the County of HopkinsCounty of Hopkins & State of KentuckyKentucky do hereby certify that the above
named Deponents /N.O.P. / whereby
me severally sworn to testify the whole
truth of their knowledge touching
the matter in controversy aforesaid
that they were examined & their examination reduced
to writing & by these respectively subscribed in my / presence
on the day between the hours & at the place on that behalf
first aforesaid

A.B.J.P.

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[missing figure]

The clerk of the Court where the Justice's commission is
recorded must certify under the seal of the court
to the official character of the Justice who takes
the deposition. The Depositions must be sealed up & Directed to the Clerk of the Circuit CourtCircuit Court at StSt Louis.
LouisSt Louis MissouriMissouri and the names of the parties to the
suit must be endorsed thus

RalphRalph a man of color
vs
Coleman DuncanColeman Duncan

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[missing figure]

Depositions of witnesses produced sworn & examined
on the 28th day of June 1831 between the hours of
8 Oclock in the forenoon and 6 O clock in the afternoon
at the Court house in the town of MadisonvilleMadisonville
HopkinsHopkins county & State of KentuckyKentucky before me
E.W.R.Woolfolk a justice of the peace within and
for the county aforesaid in a certain cause now
depending in the Circuit Court of the County of St. LouisCounty of St Louis in the state of MissouriMissouri between RalphRalph a
man of color plaintiff and Coleman DuncanColeman Duncan Defendant
on the part of the plaintiff. John DuncanJohn Duncan
of lawful age being produced sworn and examined
on the part of the plff. deposes & says

Question by Plaintiff. Do you or do you not
know that RalphRalph /a man of color / who belonged
to Coleman DuncanColeman Duncan was sent to labor at the
mines in the state of IllinoisIllinois in the year 1827
1828 or 1829

ans I think in the year 1827 my brother of JesseJesse
took RalphRalph from Hopkins CountyHopkins County and said
he was going to the mines
in IllinoisIllinois or MichiganMichigan Territory

Quest by same. Was RalphRalph or not at the
time he was taken off by your brother the
property of Coleman DuncanColeman Duncan

Ans. yes,

Quest by same Have you or not heard
Coleman DuncanColeman Duncan say then RalphRalph was his

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[missing figure]

or at labor at the mines in IllinoisIllinois in the
year 18271828 or 1829

ans. I do not recollect whether I never heard
him say so or not

Quest. by same. Was or was not the said
RalphRalph taken off by your brother JesseJesse with
the knowledge and consent of ColemanColeman Duncan
DuncanColeman Duncan

ans. I expect he was

Quest. by same. Have you or not heard
or understood that the said RalphRalph was at work in or at the mines in IllinoisIllinois
in 1827, 1828 or 1829

ans yes I understood he was at the Fever
River lead mines

Quest by same From whom did you get that information

ans I understood so from Mr. Woodruff and
my brother JesseJesse

Quest. by same. Do you or not know
that RalphRalph was hired at or near the SalineSaline
in the state of IllinoisIllinois in 1826 or 1827

ans. I do not

Quest by same Did you or not hear Coleman DuncanColeman Duncan say that he was hired
to labor three in one or the other of three
years

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[missing figure]

Ans I do not recollect that I everdid I
might or might not have heard him say so
Question by DefDid you or did you not hear ColemanColeman Duncan
DuncanColeman Duncan say that his brotherJesseJesse had taken RalphRalph
to the lead mines in IllinoisIllinois with his knowledge &
consent; Ans. I do not recollect that I ever heard
him say anything particular about it

Quest by plaintiff Did or did not ColemanColeman Duncan
DuncanColeman Duncan object to your Brother JesseJesse taking
RalphRalph to the mines

Ans I neverheard of his objecting nor
did I know that he know that he was going to take
him to the mines

Question by Def was or was not RalphRalph hired to
JesseJesse when he took him off

Ans I understood so I saw him pay the hire
Ques by pltff For how long a time was
he hired

Ans For one year I understood.

Ques by same In what year was he hired
Ans I think it was in 1827 as well
as I recollect

Quest by same Did you or not hear
JesseJesse Duncan DuncanJesse Duncan tell Coleman DuncanColeman Duncan that
he had hired RalphRalph at the mines in
IllinoisIllinois

Ans I dont recollect that I everheard him
tell him any thing about it

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[missing figure]

and further this deponent sayeth not

John DuncanJohn Duncan

sworn to and subscribed before me this 28th day of June 1831 at the place and between the hours
in that behalf first aforesaid

EEdward W R Woolfolk .WEdward W R Woolfolk .REdward W R Woolfolk .WoolfolkEdward W R Woolfolk J.P.H.C.

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[missing figure]

also the deposition of HiramHiram Woodruff WoodruffHiram Woodruff taken at
the same time and place to be read as evidence
in the same cause on the part of the plaintiff this deponent being of lawful
age and first duly sworn deposes& says
Quest by plaintiff was you or not acquainted
with RalphRalph a man of color claimed by ColemanColeman Duncan
DuncanColeman Duncan

AnsYes I was a little acquanted with him
Quest by same Do you or not know that
said RalphRalph was hired to labor at the lead
mines in the state of IllinoisIllinois in the year
1828 or 1829

Ans. I saw him at work there in 1827 or 1828
I cant recollect which

Ques by same How longdid said RalphRalph
work at the mines

Ans I went with him to the mines in

IllinoisIllinois and stayed there about 3 months and when I came away I left him
there at work

Ques by same who took RalphRalph to the
mines

AnsJesseJesse Duncan DuncanJesse Duncan

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[missing figure]

Quest by same-was RalphRalph or not taken there
by and with ColemanColeman Duncan's knowledge
and consent

Ans I suppose that he knew that he was going,
but whether he knew where he was going I
cannot tell

Quest by same was you or not told in KentuckyKentucky
by ColemanColeman &JesseJesse Duncan DuncanJesse Duncan about the time
that RalphRalph was taken away that theirintentionwas
to take him to the lead mines near GalenaGalena

Ans I never heard Coleman DuncanColeman Duncan say
any thing about it, JesseJesse told me that he
was going to the lead mines and RalphRalph
was along with him

Ques by same Did or did not ColemanColeman and
JesseJesse Duncan DuncanJesse Duncan live at or near the same place
at the time RalphRalph was taken to the
mines

Ans They are

Ques by same Do you or not know of your own
knowledge that Coleman DuncanColeman Duncan knew of or consented
to JesseJesse Duncan DuncanJesse Duncan taking RalphRalph to IllinoisIllinois or the
MichiganMichigan Territory Ans I do not.

Ques by same Do you or not know positively that
those mines at which you saw RalphRalph at work were
in IllinoisIllinois I cannot tell whether they were or not

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[missing figure]

Quest by pltff How for from Gallena was
it to where the said RalphRalph was at work

Ans It was called ten miles.

Quest by same was or was not the
place where RalphRalph was hired to work
on the IllinoisIllinoisside of the MississippiMississippi

Ansyes

Question By Deft Do you or not know that RalphRalph
was hired or not at the minesAns I do not that he was
hired And further this deponent saith not

HiramHiram Woodruff WoodruffHiram Woodruff

Sworn to and subscribed before me this 28th day of June 1831 at the place and between the
hours in that behalf first aforesaid

EEdward W R Woolfolk WEdward W R Woolfolk REdward W R Woolfolk WoolfolkEdward W R Woolfolk JPHC

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[missing figure]

Also the deposition of AllenAllen O'BryanBryan at
the same time and place on the part of the defendent
by leave of plaintiff all objections on his part
being received to the taking of the same to be read as evidence
in the same cause this deponent being of
lawful age and first duly sworn deposesand says
Question by the defendent was or was not John
Steel present when a settlement was made between
JohnJohn Gordon GordonJohn Gordon and OwingsOwings the manager of the
saline works in IllinoisIllinoisAnd It is my impression
he was there before the settlement was enclosed
but I will not be positive; Question by same
can you or can you not state in what year this
was

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[missing figure]

Ans. It was in the month of september or october in the year 1819 And further this deponent

AllenAllen O'BryanBryan

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[missing figure]

saith not

IEEdward W R Woolfolk WEdward W R Woolfolk REdward W R Woolfolk WoolfolkEdward W R Woolfolk a Justice of the Peace
within and for the county of HopkinsHopkins and state
of KentuckyKentucky as hereby certify that the above
named deposition of JohnJohn Duncan DuncanJohn Duncan , HiramHiram Woodruff
WoodruffHiram Woodruff and AllenAllen O'Bryan were by me
severally sworn to testify the whole truth of
their knowledge touching the matter in controversy
aforesaid, that they were examined
and this examination reduced to writing
and by then respectively subscribed in
my presence on the day between the hours
and at the place in the behalf first aforesaid

EEdward W R Woolfolk WEdward W R Woolfolk REdward W R Woolfolk WoolfolkEdward W R Woolfolk JPHC

constablesfee $ 1.00
Justicesfee $ 1.00
witness 3.00
plaintiffs costs $5.00
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[missing figure]

KentuckyKentucky
HopkinsHopkins County CountyHopkins County

I SamuelSamuel WoodsonWoodson clerk of the court for the County
aforesaid do certify that E WEdward W R Woolfolk REdward W R Woolfolk WoolfolkEdward W R Woolfolk esq. whose name is
subscribed to the above aforesaid certificate is now & was at the
time of subscribing the same acting Justice of the Peace in & for said
HopkinsHopkins County CountyHopkins County & that due faith & credit is & ought to be given
to all his acts as such

[missing figure]
In Testimony whereof I have hereunto subscribed
my name & affixed the seal of said County
the 28th day of June 1831 and in the 40th year
of the Commonwealth

Sam WoodsonWoodson

Clerk fee 50
50
$ 1.00 Att S. Woodson Clk
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[missing figure]

RalphRalph a man of color
vs
Coleman DuncanColeman Duncan
Deposition

Opened & filed
July 9th 1831

A gamble Clk

for pff
Jn Duncan
HiramHiram Woodruff WoodruffHiram Woodruff
AllenAllen O'BryanBryan
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[missing figure]

State ofIllinois IllinoisIllinois
SangamonSangamon County CountySangamon County

I CharlesCharles R Matheny RCharles R Matheny MathenyCharles R Matheny clk of the county
court of said county do hereby certify that WilliamWilliam CarpenterCarpenter
whose name appears to the foregoing certificate is an
acting Justice of the Peace duly sworn and authorized
in and for said county and that full faith and
credit is due to all his official acts as such

[missing figure]

Given under my hand and seal of
office at spring field in said county
this 22 day of July AD 1831
CharlesCharles R Matheny RCharles R Matheny MathenyCharles R Matheny clk

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[missing figure]

Fee Bill
Subpoena 18 3/4
Serving Do 12
Deposition 1.43 3/4
Clerk Certificate 25
Adam SmithAdam Smith attendance 50
$ 2.50

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[missing figure]

RalphRalph vs
Coleman DuncanColeman Duncan

(a man of colour Deposition)

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[missing figure]

RalphRalph
vs
Coleman DuncanColeman Duncan

Depos. of- for pff
Adam SmithAdam Smith
opened&filed
July 28th 1831

A GambleArchibald Gamble Clk

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[missing figure]

Archibald GambleArchibald Gamble esq
St LouisSt Louis
MissouriMissouri

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[missing figure]

The Deposition of Adam SmithAdam Smith taken before Wm. Carpenter
A Justice of the Peace within and for the county of
Sangamon and state of IllinoisIllinois on the 22nd day of July in the year of our Lord Eighteen hundred and thirty one
at the office of Wm. Carpenter in the Town of SpringfieldSpringfield
and county aforesaid Between the hour of eight oclock
in the forenoon and six oclock in the afternoon of said
day to be read in evidence in a certain action pending
in the Circuit CourtCircuit Court of St Louis County and state of
MissouriMissouri in which RalphRalph (a man of Color) is plaintiff and
Coleman DuncanColeman Duncan is Defendant, on the part of the plaintiff
Adam SmithAdam Smith of lawful age being produced sworn and
examined on the part of the Plaintiff Deposith and saith
as follows (to writ)

Ques 1st Did you know the plaintiff RalphRalph when he was the
slave of John GordonJohn Gordon of KentuckyKentucky.

Answer I did

Quest 2nd Do you or not know that said Gordan
while he claimed said RalphRalph as his slave
hired said RalphRalph to labour at the SalineSaline in
the state of IllinoisIllinois near Shawneetown previous
to the 3rd of December in the year 1818 Please
to state all the circumstance
within your knowledge
on this subject

Answer From information, RalphRalph was fired in IllinoisIllinois in
the years of 1818 or 1819 and was hired there
frore several years afterwards

Qust. 3rd Did on did not said Defendant ColemanColeman Duncan
DuncanColeman Duncan , in the years 1826 and 1827 claim aid
RalphRalph as his slave

Answer Coleman DuncanColeman Duncan was at my house in SangamonSangamon County
CountySangamon County IllinoisIllinois in the year of 1826 on 1827

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[missing figure]
that said DuncanDuncan then stated to me at that time
that he had purchased said RalphRalph from John
Gordan

Qust 4th. Do you know or have you heard saidColemanColeman Duncan
DuncanColeman Duncan admit that said RalphRalph was hired by him
on by his permission to labour at the SalineSaline in IllinoisIllinois
at any time, during the years 1826 on 1827. State if
you know or have heard said Coleman DuncanColeman Duncan
say on this subject

Answer I never heard said Coleman DuncanColeman Duncan say any
thing on the subject

Adam SmithAdam Smith

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[missing figure]

I Wm. Carpenter a Justice of the Peace within and for
the County of Sangamon and state of IllinoisIllinois do hereby
certify that the above named Deponent Adam SmithAdam Smith
was by me duly sworn to testify the whole truth of his
knowledge touching the matter in controversy between the
parties aforesaid, that his examination was reduced to
writing and by him subcribed in my presence on the
22nd day of July between the hour of eight oclock
A.M. and six oclock PM at my office in the
town of springfield. Witness my hand and seal
this 22nd day of July 1831

W. Carpenter J P (Ill.)

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[missing figure]

County Of St. LouisSt Louis, Sct.
State of MissouriMissouri,

To any Judge or Justice of the Peace of the State of IllinoisIllinois
---Greeting.

We, reposing special trust and confidence in your integrity and circumspection, do require and command
you that you cause to come before you such person or persons as shall be named to you by RalphRalph
(a man of color) or Coleman DuncanColeman Duncan their attorney
or agent, and him or them examine upon his, her or their corporeal oath (to be you administered) touching their knowledge of any thing that may relate to a certain matter of controversy, now pending in
our Circuit CourtCircuit Court , for the county of St. LouisSt Louis, wherein RalphRalph (a man of color)
is plaintiff and Coleman DuncanColeman Duncan is defendant on the part of the said
plaintiff and having reduced the said depositions so taken by you as aforesaid into writing, you are required to send the same, together with this commission, enclosed under your seal, to our said CircuitCircuit Court
CourtCircuit Court , with all convenient speed.

[missing figure]
Witness, Archibald GambleArchibald Gamble , Clerk of our said Circuit CourtCircuit Court ,
at the city of St. LouisSt Louis, this eleventh day of July in the year of our Lord, one thousand eight hundred and thirty-one

Archibald GambleArchibald Gamble

Clerk, C.C.
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[missing figure]
RalphRalph (a man of color)
vs
Coleman DuncanColeman Duncan

In Vacation July 11th 1831
Clerk office of the St Louis Circuit CourtCircuit Court

On the application of the attorney for the Plaintiff it is Ruled
that a Dedimusissue to any Judge or Justice of the Peace of the state of
IllinoisIllinois to take the depositions of witnesses to be read in evidence on the
trial of the above cause on the part of the plaintiff

a true copy of the Rule

Archibald gamble Clerk

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[missing figure]

The Deft has this day been notifud that plaintiff
will take Depositions in this cause at the
office of WilliamWilliam CarpenterCarpenter in the tower of
spring fieldSangamon county & state of IllinoisIllinois
an the 21st 22nd & 23rd days of July instant between
the hours of 8 o clock AM & 6 o clock pm
of said days.

GG A Bird AG A Bird BirdG A Bird Atty for pltff

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[missing figure]
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[missing figure]

State ofIllinois IllinoisIllinois
WhiteWhite County CountyWhite County

The Deposition of taken before me
JohnJohn Craw CrawJohn Craw Justice
of the peace for the
County of White and State ofIllinois IllinoisIllinois
at the office of the Clerk of the CircuitCircuit Court
CourtCircuit Court for said County, at the Town
on the 23rd day of July 1831, Between
thehours of Eight O Clock in the forenoon, and six O clock in the afternoon
of said day, to be read in evidence in
a Certain matter of Controversy now
pending in the Circuit CourtCircuit Court of St. LouisSt Louis
and state of MissouriMissouri, where in RalphRalph
a man of color is plaintiff and ColemanColeman Duncan
DuncanColeman Duncan is Defendant, on the part of
the plaintiffs,

LowryLowry Hay HayLowry Hay of Lawful age being
produced, sworn and examined on the
part of the plaintiff Deposith and sayeth
as follows

Have you any Recollection of a note
purporting to be a note from ColemanColeman Duncan
DuncanColeman Duncan to RalphRalph for Twenty Dollars
dated in 1827and attached to a Deposition
of yoursheretofore taken in this Cause

Answer

When the Deposition in this Cause was
heretofore taken there was a note attached
which was in my hand writing

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[missing figure]

Question 2nd. Did said RalphRalph and one Joa
Negro man said to belong to oneDuncanDuncan
work for you in IllinoisIllinoisin1827 on or
the date of said note

Ans.

Negros by the name of RalphRalph and Jo Did
work for me in 1827 and I understood them
to belong to ColemanColeman Duncan DuncanColeman Duncan

Ques 3rd.

Did these men when working for your in
1827pass for slaves or free men If for slaves
Did they work for you with or without the
consent of the person that claimed to be their
master

Ans.

I Considered them slaves, but whether
they came with or without their masters
consent I know not

Ques. 4th.

wasColeman DuncanColeman Duncan or a man by the name
of DuncanDuncan at the SalineSaline in IllinoisIllinois in 1827 when
said RalphRalph and Jo was their Labouring as
aforesaid, Claiming their wages and observing
them as thereby of master over then,

Ans.

Coleman DuncanColeman Duncan was at the SalineSaline about
the timeRalphRalph and Joleft there, But when
then their wages was paid to him or them & I do not
recollect

Ques 5th

Did your know said RalphRalph when he belonged
to John Gordan of KentuckyKentucky

Ans.

I did not

LowryLowry Hay HayLowry Hay

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[missing figure]

State of IllinoisIllinois
White CountyWhite County
Ss

I JohnJohn Craw CrawJohn Craw a Justice of the
White CountyWhite Countyof the Peace within and for said county
of the and state of IllinoisIllinois Do

Certify that the above named LowryLowry Hay HayLowry Hay was
by me Duly sworn and testified to
To the matters and things touching the matters
in controversyas aforesaid in my presence
the 23rd Day of July 1831between the hours
of eight o clock AM and six o clock P.M.
at the Clerk office of the Circuit CourtCircuit Court
of White CountyWhite Countygiven under myhand
and seal this 23rd Day of July 1831

JohnJohn Craw CrawJohn Craw JsPc

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[missing figure]

State ofIllinois IllinoisIllinois
White CountyWhite County

I James Ratcliff Clerk of the CircuitCircuit Court
CourtCircuit Court in and for White CountyWhite County aforesaid do
Certify that John CrawJohn Craw Esq. before whom the
foregoing deposition was taken and by him certified
now is and was at the date of Certifying an
acting Justice of the peace within and for
said County commissioned and qualified

[missing figure]

In testimony where of I have here
unto set my hand and affixed the
seal of said Court at Carmi this
23rd day of July 1831

JamesRatcliffClk

Costs for taken deposition
Justice Costs - 1.00
witness fee - .50
Certificate & seal-.50
$ 2.00
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[missing figure]
Double 25

Clerk of the CircuitCircuit Court
CourtCircuit Court of St Louis
County MissouriMissouri
St LouisSt Louis

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[missing figure]

Carmi Ill
August 11th

RalphRalph , a man of color,
vs
Coleman DuncanColeman Duncan

Deposition

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[missing figure]

LowryLowry Hay HayLowry Hay
for pltff

Filed & opened
9th August 1831

ArchibaldArchibald gamble
Clerk



St Louis St LouisSt Louis St LouisSt Louis
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[missing figure]

County Of St. LouisSt Louis, Sct.
The State Of MissouriMissouri,

To The Sheriff Of St Louis County-Greeting.

You are hereby commanded to summon Joseph VJoseph V Garnier GarnierJoseph V Garnier & JeremiahJeremiah Millington
MillingtonJeremiah Millington that setting aside all manner of excuse and delay, he be and appear in proper person before the
Judge of our Circuit CourtCircuit Court , on the eighth day of Augustinstant, at the City ofCity of St Louis
St. LouisCity of St Louis, then and there to testify and the truth to say in a certain matter of controversy now
pending in our said Court, wherein RalphRalph a man of color is plaintiff
and Coleman DuncanColeman Duncan is defendant on the
part of the Defendants; and hare you then there this writ,

[missing figure]
Witness,Archibald GambleArchibald Gamble , Clerk of our said CircuitCircuit Court
CourtCircuit Court , at the City of St.LouisCity of St Louis, this sixth day of August in the year of our Lord one thousand eight hundred and thirty one

A GambleArchibald Gamble

Clerk C.C.
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[missing figure]

July 1831

RalphRalph
vs
Coleman DuncanColeman Duncan

for plff

J.VJ V Garnier .GarnierJ V Garnier

JeremiahJeremiah Millington MillingtonJeremiah Millington

8th August
Plaintiff

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[missing figure]

Executed this writ on the J.VJ V Garnier .GarnierJ V Garnier and
JeremiahJeremiah Millington MillingtonJeremiah Millington on the 8th August 1831 in the city of St.LouisSt Louis

John K WalkerJohn K Walker Sheriff

Jas. Brotherton Dept

Service $ 1.00
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[missing figure]
RalphRalph
vs
Coleman DuncanColeman Duncan

Suit for freedom
in the St. Louis CircuitCircuit Court
CourtCircuit Court

The above named RalphRalph the plaintiff
and G. A. Bird Esq. his attorney will take
notice that in virtue of a Dedimusissued
from the office of the said Circuit CourtCircuit Court ,
depositions of witnesses will be taken, on
the fifteenth day of Novembernext
at the courthouse in the county of HopkinsHopkins
State ofKentucky KentuckyKentucky, between the hours of
eight O clock in the morning six O clock
in the afternoon of that day (and to be
continued from day to day between the
same hours, if need be) to be read in
evidence on the trial of the above,
named cause, or the part of the
defendant.

Coleman DuncanColeman Duncan
by his atty

E. BatesEdward Bates

October 19. 1831.

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[missing figure]

Executed the within notice by reading it to Gustavus
A. Bird in the city of St. LouisSt Louis on the 20 day of October 1831

John KJohn K Walker WalkerJohn K Walker Shriff
by JJames Brotherton BrothertonJames Brotherton Dept Shrf

Service .50 cts
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[missing figure]

County Of St. LouisSt Louis, Sct.
State of MissouriMissouri,

To any Judge or Justice of the Peace of the State of KentuckyKentucky
---Greeting.

We, reposing special trust and confidence in your integrity and circumspection, do require and command
you that you cause to come before you such person or persons as shall be named to you by ColemanColeman Duncan
DuncanColeman Duncan or RalphRalph (a man of color) their attorney
or agent, and him or them examine upon his, her or their corporeal oath (to be by you administered)
touching their knowledge of any thing that may relate to a certain matter of controversy, now pending in
our Circuit CourtCircuit Court , for the county of St. LouisSt Louis, wherein RalphRalph
is plaintiff and Coleman DuncanColeman Duncan is defendant on the part of the said
defendant and having reduced the said depositions so taken by you a aforesaid into writing,
you are required to end the same, together with this commission, enclosed under your seal, to our said CircuitCircuit Court
CourtCircuit Court , with all convenient speed.

[missing figure]
Witness, Archibald GambleArchibald Gamble , Clerk of our said Circuit CourtCircuit Court ,
at the City of St. LouisCity of St Louis, this Nineteenth day of October in the year of our Lord, one thouand eight hundred and thirty-one

Archibald GambleArchibald Gamble

Clerk, C.C.
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[missing figure]
RalphRalph
vs
Coleman DuncanColeman Duncan

In vacation 19th October 1831
Clerk Office of the St. Louis Circuit CourtCircuit Court

On the application of the attorney for the plaintiff it is Ruled
that a dedimusissue to any Judge or Justice of the peace of the StateKentucky
ofKentucky KentuckyKentucky to take the depositions of witnesses to be read in evidence
on the trial of this cause on the part of the defendant

a true copy of the Rule

Archibald GambleArchibald Gamble Clerk

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[missing figure]
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[missing figure]

RalphRalph
vs
Coleman DuncanColeman Duncan

Filed & opened 25th November 1831

Archibald GambleArchibald Gamble Clerk

Depositions
for defendant

Ambrose G GordonAmbrose G Gordon

Wm. Gordon

NathanNathan Hibbs

Lawson RobertsonLawson Robertson

Joseph RobertsonJoseph Robertson

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[missing figure]

Woodson Clerk of the Court
for the County aforesaid (the
same being a Court of record so
constituted by law) have herein
to subscribed my name and
affixed the seal of said County
at Office this fifteenth day of November one thousand eight hundred thirty one

Sam WoodsonWoodson

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[missing figure]

Deposition of witness produced Sworn and examined
at the Court House in the County ofCounty of Hopkins HopkinsCounty of Hopkins and
State of KentuckyKentucky before me SamuelSamuel MortonMorton a Justince
of the peace in and for the County and state aforesaid
in a certain cause now depending in the Circuit Court
of the County of St. LouisCounty of St Louis State of MissouriMissouri between
RalphRalph (a man of Color) is Plaintiff and ColemanColeman Duncan DuncanColeman Duncan
is Defendant,

Ambrose G GordonAmbrose G Gordon of lawful age being produced
and sworn and examined on the part of the Defendant
and sayeth

Question by Defendant do your know the plaintiff
and how long have you known him
Answer. I know him well he was once the property
of my father I have known him from my
infancy near twenty eight years.

question by same where did he reside and
with whom during the years 1816. 1817,
& 1818.

Answer. He resided the principal part of his time
at my Fathers in HopkinsHopkins county KentuckyKentucky &
some parts at the SalineSalinelick now the State ofIllinois
IllinoisIllinois

question same do you know of your father
Taking him to Ill to hire him
Answer: I do not believe he ever did at any time
and further this Deponant SayethSayeth not

AmbroseAmbrose G Gordon G GordonAmbrose G Gordon

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[missing figure]

KentuckyKentucky
HopkinsHopkins County CountyHopkins County

I SamuelSamuel MortonMorton an acting Justice
of the peace in and for the county aforesaid
do hereby certify that Ambrose G. Gordon the deponent
was by me sworn to testify the whole
truth of his knowledge touching the matter in
controversy in the cause aforesaid that deponent
was examined and his examination reduced to
writing and subscribed by said deponent in my
presence on the fifteenth day of November in the year eighteen hundred and thirty one between the
hours of eight in the forenoon and six in the afternoon
at the court house in the County ofCounty of Hopkins HopkinsCounty of Hopkins in
State of KentuckyKentucky,
Given and certified the 15th day of November 1831

Sam MortonMorton J. P.

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[missing figure]

also the deposition of William GordonWilliam Gordon to here
at the same time and place in the caption
mentioned being of lawfull age
sworn and examined on the part of the
deft. deposeth and sayeth

question by Deft

how long have you known
the plaintiff RalphRalph and where did he
live

Answer I know him from the time that
he was born and that he lived in KentuckyKentuckyuntil
shortly after DuncanDuncan purchased him

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[missing figure]

he belong to my Father ever
until the division and then he fell to
my brotherJohn

Ques by same
did you on not live near your
brother John in the years 1815
16 17 18 & 19 & did he or not
hire RalphRalph at the SalineSaline in those
years to your knowledge

ans.
I lived in five miles a
John in those years I never
knew of his being hired by
John GordonJohn Gordon at the SalineSaline

Question by same if John GordonJohn Gordon
had hired RalphRalph at the
SalineSaline do you or not believe you
would have known it
ans. I believe if John had
hired him there I should have
known it I heard John GordonJohn Gordon
say in his lifetime the
negro hired his own time
& went to the saline of his
own accord
& further this deponent sayeth
not

Will Gordon

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[missing figure]

Hopkins county & State of KentuckyKentucky

I SamuelSamuel MortonMorton a Justice of the peace in
and for the county and state aforesaid, do
hereby certify that William GordonWilliam Gordon the deponent
was by me sworn to testify the whole truth of
his Knowledge touching the matter in controversy
in the cause aforesaid that deponent
was examined and his examination reduced
to writing and subscribed by said deponent
in my presence on the 15th day of November in the year eighteen hundred and thirty one
between the hours of eight in the forenoon
and six of the afternoon at the court house
in the county of HopkinsHopkins state of KentuckyKentucky
given and certified the 15th. day of November 1831

SamMortonMorton

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[missing figure]

also the Deposition NathanNathan Hibbs
taken at the time & place aforesaid
to be read as evidence in the
suit aforesaid the Deponant living
of lawful age & first duly sworn
& examined on the part of deft
deposeth & sayeth

Question by deft did or did not
John Steel now of St. LouisSt Louis live near
you in HopkinsHopkins County CountyHopkins CountyKy & how
long did he live near you

ans. he lived about one mile from
me when he left Hop kins KentuckyKentucky
I was acquainted with him for
years

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[missing figure]

Question by same
what was his general moral
character in the neighborhood
where he lived

Ans he was a man general bad
character in the neighborhood
as I believe

Question by same from his General
character in the neighbourhood
would place confidence in him
on Oath

Ansrfrom his general character I could place no confidence
in him in any respect

Question by same who did he
marry

Ansr he married MajorSamuelSamuel
DowneyDowney daughter my neighbour
by same when did leave KentuckyKentucky

Ans 6 or 7 years ago
Question by same did SteeleSteele take
his family with him when he
left KentuckyKentucky and where have
resided since he left here

Ansr he did not he left them here
at her fathers & they have lived
there even since

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[missing figure]
Question by same is or not SteeleSteele
wife a woman of good character
in the neighbourhood

Ansr she is as much so as any I believe
& further this deponant sayeth
not

NathanNathan Hibbs

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[missing figure]

Kentucky
Hopkins CountyHopkins County

.

I SamuelSamuel MortonMorton an acting Justice of the
peace in and for the county and state aforesaid
do hereby certify that NathanNathan Hibbs the deponent was
by me sworn to testify the whole truth of his knowledge
touching the matter in controversy in the cause aforesaid
that deponent was examined and his examination
reduced to writing and subscribed by said deponent
in my presence on the 15th day of November in the year eighteen hundred and thirty one between the hours
of eight in the forenoon and ix in the afternoon at
the court houe in the county and state aforesaid

Given and Certified the 15th day of November 1831

SamMortonMorton

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[missing figure]

also the Deposition of Lawson RobertsonLawson Robertson taken at
the same time and place in the caption mention-
ed being of lawful age sworn and examined on
the part of the Defendant deposeth and sayeth
Question by dlft how long have you
been acquainted with JohnJohn Steele SteeleJohn Steele formerly
of HopkinsHopkins County CountyHopkins County KentuckyKentucky now

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[missing figure]

of St. LouisSt Louis

Ansr Since the fall 1819 or 20 when
he first came to he county
Question by same did he or
not live with you same time and
what was his general Moral
character in the neighbourhood
Ansr he did not live with me but
he worked at the carpenters
trade with me in the town of
madisonville a his moral cha
racter was not good in he neighbourhood

Question by same is or not
JohnJohn Steele SteeleJohn Steele entitled to Credit on
Oath in a Court of Justice from
your knowledge of his
general character in the neighbourhood
whilest he lived in
KentuckyKentucky

Ansr I would not believe upon
Oath nor do I believe he is en
titled to credit in a Court of Justice
& further this deponent sayeth
not

L. Robertson

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[missing figure]

HopkinsHopkins County CountyHopkins County
State of KentuckyKentucky

I SamuelSamuel MortonMorton a Justice of the peace
in and for the county & State aforesaid,
do hereby certify that Lawson RobertsonLawson Robertson

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[missing figure]
the deponent was by me sworn to testify the whole
truth of his knowledge touching the matter in controversy
in the cause aforesaid that deponent
was examined and his examination reduced
to writing and subscribed by said deponent
in my presence on the Fifteenth day of November in the year eighteen hundred and thirty one between the hours of Eight in the forenoon
and six in the afternoon at the Court
houe in the county of HopkinsHopkins state of KentuckyKentucky

Given and certified the 15th day of November 1831

SamMortonMorton

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[missing figure]

also the Deposition of JosephJoseph Robertson
RobertsonJoseph Robertson taken at the time & place
in the caption mentioned for
the purpose aforesaid being of
lawful age & first duly sworndeposeth
& sayeth

Question by deft how long did
you know John SteeleJohn Steele now of St. LouisSt Louis
formerly of Hopkins CountyHopkins CountyKy
& what was his general moral
Character in the neighbourhood
Ansr I knew all the time he lived
in Hopkins CountyHopkins County his moral
character was not good
by same from your knowledge
of SteeleSteele & his general character

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[missing figure]

in the neighbourhood was he entitled
to credit on Oath in a Court
of Justice

Ansr I would not have confidence
myself in SteeleSteele upon Oath
Question by same did or not SteeleSteele
pass counterfeit money whilst
you knew him
Ansr he passes a dollar of
counterfeit money & further
this deponent sayeth not

Joseph RobertsonJoseph Robertson

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[missing figure]

Kentucky State
Hopkins CountyHopkins County
Sct.

I SamuelSamuel MortonMorton a justice of the peace in
and for the county and state aforesaid
do hereby certify that Joseph RobertsonJoseph Robertson
the deponent was by me sworn to testify
the whole truth of his knowledge touching the
matter in controversy in the cause aforesaid
that deponent was examined and examination
reduced to writing and subscribed by said
deponent in my presence on the fifteenth day of November eighteen Hundred and thirty one between the hours of eight in
the fore noon and six in the afternoon at
the court house in Hopkins CountyHopkins County & State
aforesaid

Given and certified the 15th day of November 1831

SamMortonMorton

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[missing figure]

I SamuelSamuel MortonMorton Justice of the peace
within & for the County ofCounty of Hopkins HopkinsCounty of Hopkins & state of
KentuckyKentucky do certify that pursuance of
theannexedcommission and notice came
before me at the courthouse in the CountyCounty of Hopkins
ofCounty of Hopkins HopkinsCounty of Hopkins& state of KentuckyKentucky aforesaid AmbroseAmbrose G Gordon GAmbrose G Gordon GordonAmbrose G Gordon , William GordonWilliam Gordon , NathanNathan Hibbs, Lawson
Roberton & Joseph Roberton who were there by
me sworn and examined & suchexamination
reduced to writing and subscribed by
them respectively in my presence and
their said depositions are now herewith
returned

Given at the courthouse in
the County ofCounty of Hopkins HopkinsCounty of Hopkins state of KentuckyKentucky
aforesaid this 15th day of November 1831

SamMortonMorton .

Justice fee paid $1.00
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[missing figure]

KentuckyKentucky
HopkinsHopkins County CountyHopkins County
Sct.

It is hereby certified that SamuelSamuel MortonMorton
on this fifteenth day of November One thousand eight hundred and thirty one is
a Justice of the Peace within and for the county
of HopkinsHopkins & state of KentuckyKentucky duly commissioned
and acting as such and that full faith and
credit are due to his acts as such

In Testimony whereof I SamuelSamuel

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[missing figure]
RalphRalph man of color
vs
Coleman DuncanColeman Duncan

In the St Louis CircuitCircuit Court
CourtCircuit Court MissouriMissouri.

To said Defendant or EdwardEdward Bates BatesEdward Bates Esq
his attorney of record

I am please to take notice
that on the 14th day of November instant at the
office of JosephJoseph V Garnier VJoseph V Garnier GarnierJoseph V Garnier in the city of StSt Louis
LouisSt Louis between the hours of 8 o clock AM&
5O ClockPM of that day of
shall proved to take the Deposition of
witnesses in this cause

Yours GAGA Bird BirdGA Bird atty for
pltff

nov 10th 1831

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[missing figure]

nov 10read
that I am going to WashingtonWashingtonattend

EEdward Bates BatesEdward Bates

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[missing figure]

RalphRalph
vs
Coleman DuncanColeman Duncan

nature of Depositions

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[missing figure]

Deposition taken By virtue of a notice on monday
the fourteenth day of November in the year eighteen hundred and thirty one, Between the hours of eight
O Clock inthe forenoon and five O ClockPM of
that day, at the office of JosephJoseph V Garnier V GarnierJoseph V Garnier
in the city of St. LouisSt Louis, and to be read in evidence
in the trial now pending in the circuit court
of the County of St. LouisCounty of St Louis, Between RalphRalph a man
of color, who suesfor his freedom as plaintiff and
Coleman DuncanColeman Duncan defendant, on the part
plaintiff -

John SteeleJohn Steele being of lawful age and duly sworn
on his oath saith that to thebest of his recollection
he saw RalphRalph the plaintiff at the SalineSaline (in the month of October 1818)
Lick in IllinoisIllinois at work for one OwingsOwings who
was at the same time setting with John GordonJohn Gordon
of HopkinsHopkins County CountyHopkins County KentuckyKentucky who was the
reputed owner of RalphRalph and that
he understood from the conversation of said
Ownings & GordonGordon that they were settling
for wages for the past services of said
RalphRalph to the best of his recollection for the
amount of one or two years services
or part of two years but of the particular
length of time or the amount of the settlement
he can not be positive that
this affiant taught school in the neighbourhood
of & boarded with said GordonGordon

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[missing figure]
the winter after he saw said RalphRalph at the
SalineSaline in IllinoisIllinois that in conversation with
said GordonGordon his recollection is that said
Gordan told this affiant that said RalphRalph
had worked at the SalineSaline
of IllinoisIllinois as early as the year 1814 or 1815
that he said GordonGordon had hired said RalphRalph
to work almost every year after the war
up to the time this affiant saw said RalphRalph
as above stated

Questions by Plaintiffs attorney

Question 1st what makes you to believe
John GordonJohn Gordon was the owner of RalphRalph
answer. I am induced to believe JohnJohn Gordon
GordonJohn Gordon was the owner of RalphRalph from
the fact that he exercised all the acts of
ownership common for masters to do in
that country & the common reputation
of the Country was that he was the master
of said RalphRalph .

Question 2nd Do you know that the plaintiff
ever after the times above referred to came in
to the possession of the defendant & did
you ever know him to exercise any acts
of owner ship over RalphRalph the plaintiff
answer I understood from the Defendant
that RalphRalph the Plaintiff belonged to him
by some transfer or other the particulars
of which I do not recollect also from the common
talk in the county but have no other knowledge
nor did I ever in RalphRalph in the possession of

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[missing figure]

the defendant.

Question 3rd did you ever have any conversation
with the defendant relative to the plaintiff
having been hired to work in IllinoisIllinois & if so
state what it was.

answer some time in 1828 I think in June
& so in the winter following I had some
conversation with the Defendant in
which he made some statement about
his hands working at GalenaGalena of IllinoisIllinois
but I can not state any thing in particular
more than that RalphRalph was
among them but how they got there
I can not say with certainty but think
that he said one of his brothers
had taken them to GalenaGalena

Question 4 Did you understand from
the Defendant whether RalphRalph
was taken to GalenaGalena with or without
his consent.

answer there was nothing said about
consent. I was in a kind of friendly
conversation about his & my own success
generally & I saw nothing that indicated
his as he spoke of it as a matter
in the course of his affairs & my inference
was that he had sent RalphRalph and one
other the name of which I do not recollect

John SteeleJohn Steele

Swornto & subscribedbefore meon
atdayandyear

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[missing figure]

at the place and within the hour first
abovementioned before

JJ V Garnier VJ V Garnier GarnierJ V Garnier J.P.

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[missing figure]

RalphRalph
vs
Coleman DuncanColeman Duncan

Depos of
John SteeleJohn Steele for pltff

opened & filed
Nov 30th 1831

A GambleArchibald Gamble clk

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[missing figure]

County Of St. LouisSt Louis, Sct.
State Of MissouriMissouri,

To the sheriff of St. Louis County---Greeting:

You are hereby commanded, to summon JudeJude Warner WarnerJude Warner JamesJames Duncan DuncanDuncan Robert RobertDuncan Robert
Duncan-Sally DuncanJames Duncan JeremiahJeremiah Millington MillingtonJeremiah Millington
that setting aside all manner of excuse and delay, they be and appear in proper person before the Judge
of our Circuit CourtCircuit Court , on the second day of decemberinstant at the City of St. LouisCity of St Louis, then
and there to testify and the truth to say, in a certain matter of controversy now pending in our said Court,
wherein RalphRalph is plaintiff and
ColemanColeman and JamesJames Duncan DuncanJames Duncan are defendants, on the part of the
plaintiff and have you then and there this writ.

[missing figure]
Witness, Archibald GambleArchibald Gamble , Clerk of our said Circuit CourtCircuit Court ,
at the City of St. LouisCity of St Louis, this 11th day of November in the year of our Lord one thousand, eight hundred and thirty-one

Archibald GambleArchibald Gamble

clerk, C.C.
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[missing figure]

November Term 1831

RalphRalph
vs
ColemanColeman & James DuncanJames Duncan

For plaintiff

Jude WarnerJude Warner

JamesJames Duncan DuncanDuncan Robert

RobertDuncan Robert DuncanJames Duncan

Mrs.SallySally Duncan DuncanSally Duncan

JeremiahJeremiah Millington MillingtonJeremiah Millington

on 2nd December

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[missing figure]

Executed this writ on JMillington 14
or Robert DuncanRobert Duncan 19 Nov 1831 on
JamesJames Duncan Duncan & Sally DuncanJames Duncan
2nd Decr 1831 in the county St LouisSt Louis
JudeJude Warner WarnerJude Warner not found

JohnJohn K Walker KJohn K Walker WalkerJohn K Walker Shff
&byJosBrotherton D. Shff

Service 200
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[missing figure]

County Of St. LouisSt Louis, Sct.
State Of MissouriMissouri,

To the sheriff of St. Louis County---Greeting:

You are hereby commanded, to summon JosephJoseph V Garnier V. GarnierJoseph V Garnier GeorgeGeorge Bobb Bobb Charles BobbGeorge Bobb Theodore LTheodore L McGill .
McGillTheodore L McGill RobertRobert Simpson SimpsonRobert Simpson HenryHenry VonPhulThomasThomas Cruson CrusonThomas Cruson JohnJohn Steele
SteeleJohn Steele
that setting aside all manner of excuse and delay, they be and appear in proper person before the Judge
of our Circuit CourtCircuit Court , on the second day of Decembernext at the City of St. LouisCity of St Louis, then
and there to testify and the truth to say, in a certain matter of controversy now pending in our said Court,
wherein RalphRalph is plaintiff and
ColemanColeman and JamesJames Duncan DuncanJames Duncan are defendants, on the part of the
plaintiff and have you then and there this writ.

[missing figure]
Witness, Archibald GambleArchibald Gamble , Clerk of our said Circuit CourtCircuit Court ,
at the City of St. LouisCity of St Louis, this 11th day of November in the year of our Lord one thousand, eight hundred and thirty-one

Archibald GambleArchibald Gamble

clerk, C.C.
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[missing figure]

November Term 1831

RalphRalph
vs
ColemanColeman & James DuncanJames Duncan

For plaintiff

JoVGarnier 15

George BobbGeorge Bobb 24

Charles BobbCharles Bobb 2

TheodoreTheodore L McGill LTheodore L McGill .McGillTheodore L McGill 25

RobertRobert Simpson SimpsonRobert Simpson 16

HenryHenry VonPhul

ThomasThomas Cruson CrusonThomas Cruson

John SteeleJohn Steele 14 Nov

on 2nd December

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[missing figure]

Executed this writ on JohnJohn Steele SteeleJohn Steele 14th on
JosVGarnier15thRobert SimpsonRobert Simpson 16th on
George BobbGeorge Bobb 24th on Theo L.25th of Nov 1831 in the county of St LouisSt Louis on Chas
Bobb 2 December 1831HVon Phul &
Theo Cruson not found in my
county

JohnJohn K Walker KJohn K Walker WalkerJohn K Walker Shrff
byJJames Brotherton BrothertonJames Brotherton Dept Sheriff

Service 300 3.25
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[missing figure]

County Of St. LouisSt Louis, Sct.
State Of MissouriMissouri,

To the sheriff of Saint LouisSt Louis County---Greeting:

You are hereby commanded, to summon John HJohn H Baldwin BaldwinJohn H Baldwin
that setting aside all manner of excuse and delay, they be and appear in proper person before the
Judge of our Circuit CourtCircuit Court , forthwith at the
City of St. LouisCity of St Louis, then and there to testify and the truth to say, in a certain matter of controversy now
pending in our said Court, wherein RalphRalph is
plaintiff and Coleman DuncanColeman Duncan is defendant,
on the part of the plaintiff and have you then and there this writ.

[missing figure]
Witness, Archibald GambleArchibald Gamble , Clerk of our said
Circuit CourtCircuit Court , at the City of St. LouisCity of St Louis, this Second day of December in the year of our Lord one thousand, eight hundred and thirty-one

ArchibaldArchibald gamble

Clerk C.C.
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[missing figure]

Executed on JohnJohn H Baldwin HJohn H Baldwin .BaldwinJohn H Baldwin
on the 2nd Dec 1831

JohnJohn K Walker K. WalkerJohn K Walker
Sheriff

Service 50cts
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[missing figure]

RalphRalph
vs
Coleman DuncanColeman Duncan

JohnJohn H Baldwin HJohn H Baldwin .BaldwinJohn H Baldwin
pltff

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[missing figure]

County Of St. LouisSt Louis, Sct.
State Of MissouriMissouri,

To the sheriff of S LouisS Louis County---Greeting:

You are hereby commanded, to summon JeremiahJeremiah Millington MillingtonJeremiah Millington
DavidDavid Lawrence LawrenceDavid Lawrence
that setting aside all manner of excuse and delay, they be and appear in proper person before the
Judge of our Circuit CourtCircuit Court , on theforthwithday of at the
City of St. LouisCity of St Louis, then and there to testify and the truth to say, in a certain matter of controversy now
pending in our said Court, wherein RalphRalph is
plaintiff, and Coleman DuncanColeman Duncan is defendant,
on the part of the plaintiff and have you then and there this writ.

[missing figure]
Witness, Archibald GambleArchibald Gamble , Clerk of our said
Circuit CourtCircuit Court , at the City of St. LouisCity of St Louis, this Second day of December in the year of our Lord one thousand, eight hundred and thirty-one

A GambleArchibald Gamble

Clerk C.C.
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[missing figure]

Executed this writ on JeremiahJeremiah Millington
MillingtonJeremiah Millington and DavidDavid Lawrence LawrenceDavid Lawrence on the
9th of December 1831 by reading the
same to them in the County of St LouisCounty of St Louis

for

JohnJohn K Walker KJohn K Walker WalkerJohn K Walker sheriff

SBloodDept sheriff

Service $ 1.00
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[missing figure]

RalphRalph
vs
Coleman DuncanColeman Duncan

for JeremiahJeremiah Millington MillingtonJeremiah Millington
DavidDavid Lawrence LawrenceDavid Lawrence
forthwith for
Plf

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[missing figure]

County Of St. LouisSt Louis, Sct.
State Of MissouriMissouri,

To the sheriff of S LouisS Louis County---Greeting:

You are hereby commanded to summon AbnerAbner Martin MartinAbner Martin Jr.
that setting aside all manner of excuse and delay, they be and appear in proper person before the
Judge of our Circuit CourtCircuit Court , on the Second day of Decr at the
City of St. LouisCity of St Louis, then and there to testify and the truth to say, in a certain matter of controversy now
pending in our said Court, wherein RalphRalph is
plaintiff and Coleman DuncanColeman Duncan is defendant,
on the part of the Pltf and have you then and there this writ.

[missing figure]
Witness, Archibald GambleArchibald Gamble , Clerk of our said
Circuit CourtCircuit Court , at the City of St. LouisCity of St Louis, this 1st day of Decr in the year of our Lord one thousand, eight hundred and thirty-one

A GambleArchibald Gamble

Clerk C.C.
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[missing figure]

RalphRalph
vs
DuncanDuncan

for

AbnerAbner Martin MartinAbner Martin Jr.
2nd Dec for

Pltf

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[missing figure]

Served this writ on AbnerAbner Martin MartinAbner Martin
on the 12th Decr 1831 in the city
of St LouisSt Louis

JohnJohn K Walker KJohn K Walker WalkerJohn K Walker Shff

Service 50 cts
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[missing figure]

County of St. LouisCounty of St Louis, Sct.
The State Of MissouriMissouri,

To The Sheriff Of St. Louis County,
Greeting.

We command you to attach JohnJohn Steele SteeleJohn Steele
by his body and him safely keep, so that you have his
body before the Judge of our Circuit CourtCircuit Court , now in session at the City of St. LouisCity of St Louis, within and for
the county of St. LouisSt Louison theforthwithday of 18,
then and there to testify and the truth to say in a certain matter of controversy, now pending in our
said Circuit CourtCircuit Court , between RalphRalph plaintiff, and ColemanColeman Duncan
DuncanColeman Duncan defendant, wherein the said JohnJohn Steele SteeleJohn Steele
has heretofore been summoned, on the part of of the said plaintiff

[missing figure]
Witness, Archibald GambleArchibald Gamble , Clerk of our said Court, at the
City of St LouisCity of St Louis, this 2nd of Dec- 1831.

A GambleArchibald Gamble Clk

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[missing figure]

Executed this writ &have the body of
John SteeleJohn Steele in open court

JohnJohn K Walker KJohn K Walker WalkerJohn K Walker Sheriff
by S.BloodDeptSheriff

Service $ 1.00
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[missing figure]

RalphRalph
vs
C DuncanDuncan
for
JohnJohn Steele SteeleJohn Steele
attachment

Discharged
costs to
suit

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[missing figure]
RalphRalph
vs
Coleman DuncanColeman Duncan

In St. Louis Circuit CourtCircuit Court

Plaintiff comes & moves for
a new suit & files the following reasons -

1 The verdict is contrary to the law

2 It is against the right of evidence

3 It is against Law

4 The court misdirected the jury

5 The plaintiff has discovered new & material
evidence since the trial of whichhewas ignorant
before the trial as until appear by the
affidavits filed

G A BirdG A Bird pltffatty

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[missing figure]

RalphRalph a man of color
vs
Coleman DuncanColeman Duncan

The above named RalphRalph on his oathsays that
since the trial of this case on this morning he
has discovered &been informed that a
Mr. JohnJohn Hart HartJohn Hart is a material witness for
this plaintiff in this cause that said
JohnJohn Hart HartJohn Hart knows the fact that this plaintiff
while he was held as the slave
of one John GordonJohn Gordon deceased was
hired by said John GordonJohn Gordon to labor in
the thenterritory of IllinoisIllinois for several
years & from about the year 1812until
after said Territorybecame a state this
affiant is fully convinced that he can prove
the above facts by said JohnJohn Hart HartJohn Hart as he
is informed & believes that said Hart says
he knows said facts & this affiant now
recalled that he knew said JohnJohn Hart HartJohn Hart
in IllinoisIllinois some fifteen years past or more
But this affiantdid not know that said
Hart was a material witness for him
nor did he know that said Hart would testify to the above facts
untill this morning this affiant says
he knows of nowitnesses by whom
he could have proved the someparts
he appeals to prove by said Hart this affiant
says he washired to do labor in the StateIllinois
ofIllinois IllinoisIllinois by said John GordonJohn Gordon in 1811 or
1812 that he was at work there the
time of the earthquake in N Madridbut
thosewhoknew this affiant to work
there are mostlymoved away or died

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[missing figure]
RalphRalph a man of color
vs
Coleman DuncanColeman Duncan

In the St LouisSt Louis circuit Court

John SteeleJohn Steele an his oath says that last week & a
few days before the trial of said cause he
was informed by Mr.BirdBird the counsel for
the Plaintiff that depositions have been taken
& filed in said cause which went to impeach
the credit of this affiant & said affiantinformed
said BirdBird that he know only two persons
in this neighbourhood who had been acquainted
with this affiant in KentuckyKentucky & that they
would prove that this affiant sustained the
character of a man of veracity- This affiant
says that John HartJohn Hart at the request of
this affiant was summoned as a witness
to rebut the testimony taken on the part
of said Defendant which intended to-
impeach the credit of this affiant &
this affiant says that after Plaintiff an
the trial of said cause had concluded his
testimony in chief & after Defendant had
concluded his testimony said John HartJohn Hart was
sworn in said cause to rebut same
evidence taken & read by the Defendant
& which want to impeach the character
of this affiant & said Hart was asked
no question & gave no evidence apart
in relationto the character of John SteeleJohn Steele
& those where Depositions were read to
impeach this affiant

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[missing figure]

This affiant says that on friday cominglast
& after said cause had been submitted to
the jury this affiant had a conversation
with said Hart in relation to said RalphRalph claim to freedom & said Hart then stated that he knew the fact that said RalphRalph
was hired by his then master John GordonJohn Gordon
to labor in the Territory of IllinoisIllinois many
years that he Hart frequently saw said
RalphRalph laboring in the Territory of IllinoisIllinois
& that he saw him this labouring there he
thinks as early as the year 1812 on 1813 said Hart
further said that he was not aware when
sworn as aforesaid that his knowledge of
the residence of said RalphRalph in IllinoisIllinois was
material to any issue in said case

John SteeleJohn Steele

Sworn to before me this
6th day of Decr 1831

A GambleArchibald Gamble Clerk

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[missing figure]

RalphRalph
vs
Coleman DuncanColeman Duncan

John SteeleJohn Steele
affidavit

filed Dec 6th 1831

A. GambleArchibald Gamble Clk

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[missing figure]

RalphRalph a man of color
vs
Coleman DuncanColeman Duncan

Be it remembered that
on the trial of the cause the following is the
evidence & all of the evidence produced of by
the parties aforesaid. The Depositions & of which
the following are copies were read in Evidence
on the part of the plaintiff âhere insert the
two Depositions of Lowry HayLowry Hay & the to saidHay's Depositions the Deposition
of Adam SmithAdam Smith & the Depositions of
Hiram WoodruffHiram Woodruff plaintiff & John DuncanJohn Duncan / leaving
out the captions & certificates to the Depositions)
The following the witnesses sworn on the part of the
Plaintiff testified as follows- TheodoreTheodore L McGill L McGillTheodore L McGill
testified that his was acquanted with the
hand writing of the Defendant had seen him
write & behind that the signature of ColemanColeman Duncan
DuncanColeman Duncan to the note attached to the Deposition
of LowryLowry Hay HayLowry Hay was in the hand writing of
the Defendant-

Robert SimpsonRobert Simpson testified that same time
about June 1830James DuncanJames Duncan the brother of
the defendant acted as the agent of the
Defendant in causing the Plaintiff to be arrested
as a runaway slave.

JeremiahJeremiah Millington MillingtonJeremiah Millington testified that last fall
he brought a suit before Joseph VJoseph V Garnier GarnierJoseph V Garnier a
Justice of the peace against the Defendant
on a note given to William SmithWilliam Smith of
Galena IllinoisIllinois- that an the trial of said
cause the Defendant set up as a Defense
said suit that said note was given
without consideration & attained by duress
that said ColemanColeman stated that said

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[missing figure]
had been employed by his brother JamesJames to
procure the emancipation of some slaves
which said JamesJames had in IllinoisIllinois near
GalenaGalena & that SmithSmith was about to arrest
him an account of said Services to present
which executed said note to SmithSmith

That on the trial of said cause he caused
said ColemanColeman & James DuncanJames Duncan to be Sworn
as witnesses for the plaintiff & they both
on being asked if they were not
interested in said negroes answered an
oath that they were

Charles BobbCharles Bobb testified that some time
in 1828 he was at the mines near GalenaGalena
in IllinoisIllinois or MichiganMichigan he could
not tell which & he seen the plaintiff
Laboring at the mines there- that said
plaintiff was taken there by JesseJesse Duncan DuncanJesse Duncan & was afterwards
under the management &
control of James DuncanJames Duncan brother of the
Defendant that he know said plaintiff
to be thus laboring there about six months
& when he left said mines he left the plaintiff
at work there.

John Steel testified that either in the fall of
1818 or 1819 he could not recollect which he
was at the saline in the State of IllinoisIllinois near
Shawnee Town where he first saw the Plaintiff
& his then master John GordonJohn Gordon deceased
that said GordonGordon & a Mr.OwingsOwings then had
a settlement for the hire of said Plaintiff
at said saline & he understood from the
conversation between said Gordon & Owings
that said RalphRalph had been Laboring at said
saline a year on a part of two years

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[missing figure]

previous to that time & that this settlement
was for the hire of said RalphRalph during the
time aforesaid he further tesified that
immediately after this settlement he went to
KentuckyKentucky with said JohnJohn Gordon
GordonJohn Gordon & taught a school in the neighbour
hood of said John GordonJohn Gordon & boarded in
the family of said John GordonJohn Gordon that
which he in the family of said Gardan
he heard said GordonGordon say that he had
been in the habit of hiring said RalphRalph to
work at said saline occasionally from 1814
or 1815 to that time he further stated that
he understood it was the practice of said GordonGordon
to said RalphRalph after planting corn & sometimes
after gathering to work at said saline
untill about Christmas when said RalphRalph
was ordered back to KentuckyKentucky on the cross
examination said SteeleSteele in answer to questions
that he could not be certain as to the time when
said settlement took place between said GordonGordon
& said OwingsOwings that he had been sworn as a
witness in this case on a former trial & then
stated substantially what he has now that
he was then of the impression as he now is
that said settlement took place in the
fall of 1818- that he then released to a trial
that took place in GallatinGallatin county IllinoisIllinois before
a Justice of the peace which would show the
precise time a paper was then handed to said
Steel purporting to be articles of argument
between said Steel & the subscribers to the
school he taught in KentuckyKentuckydated21st October 1819- on issuing this paper said Steel said

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[missing figure]
Stated that it was the agreement between him
& the Subscribers to his school on KentuckyKentucky which
he had spoken of & he was now cornered
that the settlement he had spoken of between
John GordonJohn Gordon & the said OwingsOwings for the hire of
said RalphRalph must have taken place in
1819soonaforesaid to the date of said
articles of agreement.

AbnerAbner Martin MartinAbner Martin testified that he was the nephew
of said John GordonJohn Gordon deceased & was brought
up in KentuckyKentucky within about a mile of said
GordonGordon that during the life of said GordonGordon
witness spent & lived a considerable of his
time with said GordonGordon that he was now
about twenty one years old - that since his
earliest recollection said RalphRalph was the
slave of John GordonJohn Gordon & said GordonGordon was
in the habit of hiring said RalphRalph to
labor at the saline in the State of IllinoisIllinois
that he recollects when he was about seven
years old of hearing said GordonGordon say that
said RalphRalph was at work at said SalineSaline in the mar
said MartinMartin said he never saw
said RalphRalph in IllinoisIllinois but only know
he was hired there from the statements
or John Gardon on the cross examination said MartinMartin was
asked if the Plaintiff or any other person
had given him any money to procure his
testimony in this cause the witness answered
no - The above Depositions of Lowry HayLowry Hay were
taken one of them in IllinoisIllinoisMarch 23rd 1831
the in same state 23rd July 1831
the Deposition of Adam SmithAdam Smith was taken in
same state 22nd July 1831 and the Depositions
of John DuncanJohn Duncan & HiramHiram Woodruff WoodruffHiram Woodruff were

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[missing figure]

taken in KentuckyKentucky the 28th day of June 1831
The Depositions of which the following are witnesses
were then read in under me on the part of
the Defendant /here insert the Depositions
of AllenO BryanHiramHiram Woodruff WoodruffHiram Woodruff - John DuncanJohn Duncan & BrisonBrison Pursley
PursleyBrison Pursley - & the Depositions of Ambrose Gordon
William Gordon NathanNathan HibbsLawsonLawson Robertson
RobertsonLawson Robertson & Joseph RobertsonJoseph Robertson omitting the
Captions & certificates-/- the Depositions
on the part of the plaintiff were all taken
in KentuckyKentucky that of AllenO Bryan the
28 June 1831 Those of HiramHiram Woodruff WoodruffHiram Woodruff
John DuncanJohn Duncan & Brison PursleyBrison Pursley an the 26th day of July 1830- and said Deposition of
AmbroseAmbrose G Gordon G GordonAmbrose G Gordon William GordonWilliam Gordon
NathanNathan HibbsLawson RobertsonLawson Robertson
& Joseph RobertsonJoseph Robertson were taken an the 15th day of November 1831-

The following persons were then introduced to
give rebutting the underme & certified as follows

Abner MartinAbner Martin testified that he became
acquainted with said witness John SteeleJohn Steele in
KentuckyKentucky about 11 or 12 years age that
he went to school to said Steel & considered
him a man of good character that said
Steel when he know him & associated with
respectable people & he never heard any
thing alleged against said Steel as a
man of truth he further stated that
he knew NathanNathan HibbsLawson RobertsonLawson Robertson
& Joseph RobertsonJoseph Robertson whose Depositions had

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[missing figure]
been read stated that the character of JosephJoseph Robertson
RobertsonJoseph Robertson forthwith was bad- but he knew nothing
against the character of Lawson RobertsonLawson Robertson
or NathanNathan Hibbs - but believed Mr.Hibbs was a
man of good character
John HartJohn Hart testified that he formerly lived
in Hopkins CountyHopkins County KentuckyKentucky where he became
acquanted with said & John Steel & where
he knew said Lawson & Joseph RobertsonJoseph Robertson
& NathanNathan Hibbs - that he never heard any
thing alleged against said Steel as a man
of truth that he known but little about
the character of Lawson RobertsonLawson Robertson or said
Hibbs- that Joseph RobertsonJoseph Robertson he generally
Saw at horse races & his character was not good but he could not say what his character
for truth was

John HJohn H Baldwin BaldwinJohn H Baldwin testified that he has been
acquanted with said Steel for Several years
that said Steel soon after his acquaintance
with him was employed by him & worked
in his shop that he had never heard any
thing alleged against the character of said
Steel & so far as he knew any thing about
him his character was fair

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[missing figure]

The evidence being closed the Defendants
counsel asked the court to give the Jury
the following instructions â here copy
the instructions â while instructed were
given as asked for the argument to
the say it was insisted by the plaintiff that

The Plaintiff then moved the court to
instruct the jury as follows - that the ordinance
of 1787. prohibiting slavery in the Northwest
Territory continued in force in IllinoisIllinois as
regard the question of slavery until the
3d December 1818. When the state of IllinoisIllinois
was admitted into the union by the restric
tion of congress: which instruction the court
referred to give to which opinion is referring
said instruction the plaintiff excepts

Govern as regards the
the courts charging the Jury another
declared the law to be that as regards the
question of slavery in IllinoisIllinois the constitution
of IllinoisIllinois of not the ordinance of 1789 must
govern from the time that the said-
constitution was passed by the constitution
which formed it the Plantiff moved
for a new trial for the reasons & affidavits
filed of which the following are copies here copy reasons affidavits
the court overruled the motion for a new
trial of to the decision of the court in
refusing to grant the new trial the plaintiff
accepts & tenders this bill of exceptions which is
signed sealed of made part of the Record

WillWill C. CarrCarr

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[missing figure]

RalphRalph a man of color
vs
Coleman DuncanColeman Duncan

Bill of Exceptions

Filed Dec 22nd 1831

A GambleArchibald Gamble Clk

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[missing figure]
RalphRalph a man of color
vs
Coleman DuncanColeman Duncan

Suit for freedom in the Circuit
court of St LouisSt Louis county

RalphRalph the above named & plaintiff being sworn
on his oath says he has a prayed an appeal from
the Judgement of said Court in this cause
to the Supreme CourtSupreme Court and that his application
for said appeal is not made for the
purpose of expatiation or delay but because
this affiantverilybelieves that he is
aggrieved by the Judgement of said CircuitCircuit Court
CourtCircuit Court in this cause upon which this appeal
is prayed

RalphRalph his Mark

Sworn to Dec 22nd 1831

A GambleArchibald Gamble clk

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[missing figure]

RalphRalph
vs
DuncanDuncan

Affidavit for an
appeal

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[missing figure]

State of MissouriMissouri,
County Of St. LouisSt Louis, Sct.

To any Judge or Justice of the Peace of The State of KentuckyKentucky
--Greeting.

We, reposing special trust and confidence in your integrity and circumspection, do require and command you that you cause
to come before you such person or persons a shall be named to you by RalphRalph man of color
or by Coleman DuncanColeman Duncan their attorney or agent, and him or them examine upon
his, her or their corporal oath (to be by you administered) touching their knowledge of any thing that may relate to a certain matter
of controversy, now pending in our Circuit CourtCircuit Court , for the county of St. LouisSt Louis, wherein RalphRalph a man of Colour is
plaintiff and Coleman DuncanColeman Duncan is
defendant on the part of the plaintiff and having so reduced the said depositions so taken by
you as aforesaid into writing, you are required to send the same, together with this commission, enclosed under your seal, to our
said Circuit CourtCircuit Court , with all convenient speed.

[missing figure]
Witness, Archibald GambleArchibald Gamble , Clerk of our said Circuit CourtCircuit Court , at the City of St.
Loui, this first day of July in the year of our Lord, one thousand eight hundred and thirty three

Archibald GambleArchibald Gamble

Clerk, C.C.
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[missing figure]

Directions for taking Depositions pursuant and to notice & this
commission First they must be taken at the time &
place mentioned in the notice. Notice is given that
the plaintiff will take Depositions at the Court house
in MadisonvilleMadisonville KentuckyKentucky on the 28th day of August instant 1833 between the hours of 8 o clock in the forenoon &
6 o clock in the afternoon of that day & that he
will continue to take Depositions from day to day
between the same hour of each day at that place
untill he shall have completed taking said Depositions
the Depositions must be reduced to writing & subscribed
by eachwitness in presence of the Justicewho takes
them & the magistrate must certify at the fact of each
Deposition on what day & between what hours &
at what place each deposition was taken. Each witness
must be sworn or affirmed to testify by the whole truth of his knowledge
touching the matters in controversy between the parties
aforesaid at the fact of all the Depositions the Justice
must certify that the Deponents weresworn or affirmed
beforehim as aforesaid that there Depositions were
reduced to writing & by the Deponents respectively subscribed
in hispresence stating the time & place & cause & on whose
behalf eachwitnesswassworn The instructions for taking
the depositions should be State & by the Justice. The certificate
of the clerk of the Court where the Justices commission
to record under the seal of the Court should be

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[missing figure]
procured certifying that the Justice before whom the Depositions
been taken wasawaiting Justice of the peace &, at the date
of taking the Depositions duly commissioned & qualified as
such and that full faith & credit is due to all his affiants
- The Justice should examine any witnessproduced by
either party and ask any question which he thinks material
to detect from the witnessany material fact through his
knowledge touching the matter in dispute between the
parties taking the depositions are taken & certified & the
official character of the Justice authenticated the Justice
should attach this commission to the Depositions on
in an envelope under his seal & sentthen
forthwith the by maildirected to ''The clerk of the
Circuit CourtCircuit Court of Saint Louis County St. Louis Missouri''
& on the envelope should be endorsed the title of
the suit thus -'' RalphRalph vs Coleman DuncanColeman Duncan .

For the of the Justice the following form of
heading & certifying Depositionswhich is substantiallyrequired
by our statutes is given

Depositions of witnessesproduced & sworn & examined on the
day herein after mentioned at the fact of each deposition
between the hours of eight O clock in the forenoon & six O clock
in the afternoon of each of said days at the Court house
in the town of MadisonvilleMadisonville HopkinsHopkins County CountyHopkins County & State ofKentucky
KentuckyKentuckybeforeme a Justice of the peace then & for
the County aforeaid in a certain cause now depending
in the Circuit CourtCircuit Court for Saint LouisSt Louis County and
State of MissouriMissouri between RalphRalph a man of colour
plaintiff & Coleman DuncanColeman Duncan Defendant on the
part of the plaintiff

[missing figure]

G.F. of lawful age being produced sworn & examined
deposith & saith / here insert the Statement of witness
which Statement must be subscribed by witness
which Justice must certify as follows as sworn to and
``subcribed beforeme this 28th day of November 1833 (or if taken on another
``day name the day) between the hours at the place inthat
``which first aforesaid A B Justice of the Peace,

at the end of all the Deposition taken in the cause a certificate
should in added in the following form.

I A B a Justice of the Peacein this & for the county of HopkinsHopkins & state of
``Kentucky do hereby certify that (N. O. R. Q) the Deponants were by me
``severally sworn (or affirmed) to testify the whole truth of their knowledge
``touching the matters in controversy between the parties aforeaid that
``they were examined & their examination reduced to writing & by
``there respectively subscribed in my presence on the day (fordays)
``between the hours & at the place as herein before stated

A. B. Justice of the Peace

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[missing figure]

State of MissouriMissouri sct;
supreme Court Third Judicial District. May Term 1833

RalphRalph
vs
Coleman DuncanColeman Duncan

Monday 17th June 1833

Appeal from St. Louis Circuit CourtCircuit Court

Now at this day come again the parties aforesaid by their respective
attorneys and the court now here being sufficiently advised of and concerning
the premises consider that the Judgment aforesaid in form aforesaid by the said
Circuit CourtCircuit Court rendered be reversed and for nought held and Esteemed, and it is
ordered by the court, that this cause be remanded to the said Circuit CourtCircuit Court for
further proceedings therein in conformity with the opinion of this court delivered
in this case, and it is further considered by the court that the said RalphRalph the appellant
recover against the said Coleman DuncanColeman Duncan the appellee his costs and charges
by him about the prosecution of his appeal in this case expended and that he
have thereof execution

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[missing figure]
RalphRalph a man of Color
vs
Coleman DuncanColeman Duncan

Appeal from St. Louis Circuit CourtCircuit Court

RalphRalph sued for his freedom in the Circuit CourtCircuit Court of St. Louis County,
and Judgment being given against him in that court he comes here to reverse
that Judgment. On the trial of the cause it was testified by John Steel that
he had heard John GordonJohn Gordon the former master of RalphRalph say in the year 1818
or 19 that he had been in the habit of hiring RalphRalph to work occasionally at
the OhioOhio SalineSaline from the year 1814 or 15 till the time of the conversation
aforesaid. Witnesses were called to impeach Steeles character for veracity,
others were called to support it; and William GordonWilliam Gordon a witness on the part
of the defendant himself by his testimony seemed to support that of SteeleSteele .

William GordonWilliam Gordon was asked by the defendant if he did not live near his
brother John GordonJohn Gordon in the years 1815. 16. 17. 18 & 19 and if he knew that his
brother hiredRalphRalph at the SalineSaline in those years; to which question he
answered that he lived in five miles of John in those years, he never knew
of his (RalphRalph ) being hired by John GordonJohn Gordon at the SalineSaline. The witness to
make the matter more certain was asked, whether if John GordonJohn Gordon had hired
RalphRalph at the SalineSaline he did not believe he should have known it. The answer
was ``I believe if John GordonJohn Gordon had hired him there I should have known it. I''
`heard John GordonJohn Gordon say in his life time, the negro hired his own time and went''
``to the SalineSaline of its (his) own accord'' - The object of the ordinance of 1787 was
to prohibit the introduction of slaves into the Territory of which the present State of IllinoisIllinois contitutes
a part, and the master who permits his slave to go there to hire himself
offends against that law as much as one who take his slave along with
himself to reside there; and if we are at liberty to regard the moral effect of
the act it is much worse to permit the slave to go there to hire himself to
labor, than for the master to take him along with himself to reside there
under his own inspection or to hire him out personally to some person who
will be bound to pay the master the hire; yet even this last act has been
decided to be a violation of the provision of the ordinance - AbnerAbner Martin
MartinAbner Martin one of the plaintiffs witnesses also testified that he was the nephew of
John GordonJohn Gordon (former owner of RalphRalph ) that in 1831 he was 21 year sold and

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[missing figure]
that he recollected when he was about seven years old, he heard John GordonJohn Gordon
say that RalphRalph was at work at the Olis SalineSaline, the witnes stated that he
had spent much time in Gordons family, had no knowledge that RalphRalph
was employed at the SalineSaline except from Gordon's statements- much other
testimony was given to prove a hiring of the plaintiff at the SalineSaline, and
at the Lead mines near GalenaGalena in IllinoisIllinois, some part of which time was
since the defendant became the owner, but his assent was not expressly
proved. This testimony and some other not very material to be noticed
being given, the counsel for the defendant moved the court to give six
instructions the sum and purpose of which is as follows -

1st that the constitution of IllinoisIllinois takes date and was obligatory from the time
it passed unless some other date is provided in the instrument.

2nd that the execution of a note by the defendant to the plaintiff as given in evidence
in this case does not operate a manumission of the plaintiff.

3rd that in order to intitle the plaintiff to recover in this suit it must be proved
that the defendant assented to his residence in IllinoisIllinois - These instructions
were given - The plaintiff prayed the court to instruct the Jury that the
Constitution of IllinoisIllinois took effect on 3rd December 1818 when CongressCongress
assented to the admission of that state into the union and not before that
time - this was refused the plaintiff then prayed a new trial which was refused -

This court is of opinion that the instruction asked by the plaintiff should have
been given, and that the first instruction asked by the defendant should have been
refused - We have no doubt that for the purposes of self government the Consti-
tution of IllinoisIllinois might have been well in force from the time of its adoption,
but for the purpose of the present cause we incline to limit its effect to the time
when congress assented to the admission of the State into the Union - It
cannot be said that the 2nd and 3rd instructions asked by the defendant were
improperly given, But the evidence that the defendant gave his not to the plaintiff
is certainly admisible to prove that the defendant treated with him as with a
freeman. - nor is it necesary to prove that the assent either of GordonGordon the
former claimant or of DuncanDuncan the defendant was expressly given to the Residence
in IllinoisIllinois by virtue of which the plaintiff claims his freedom, this asent may be
inferred from circumstances. - The motion for a new trial was in the opinion of
this court improperly overruled. - Then for the reason that the first instruction
asked by the defendant was in the opinion of this court improperly given, and
that asked by the plaintiff improperly refused, and because the plaintiffs motion
for a new trial was in the opinion of this court improperly overruled (there being
as we think evidence enough to entitle the plaintiff to a verdict) the Judgment
of the Circuit CourtCircuit Court is reversed and the cause remanded for further proceedings
in conformity with this opinion -

M. McGirk

G Tompkins

R WashR Wash

Judges -
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[missing figure]

State of MissouriMissouri Sct;

I, JosephJoseph C BrownBrown Clerk of the Supreme CourtSupreme Court for the third
Judicial District of the State of MissouriMissouri do certify that the above & foregoing
is a true Copy of the Judgment rendered by said court in the case of RalphRalph

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[missing figure]

(a man of color) appellant and Coleman DuncanColeman Duncan appellee at the May Term of said court in the year Eighteen Hundred and thirty three, and of the opinion of
the said court delivered in said cause at the same term therof as the same
now remain in my office

In Testimony where of I have hereunto
set my hand and affixed the seal of the
said Supreme CourtSupreme Court at office in the city
of St LouisSt Louis in the Third Judicial District
of the State of MissouriMissouri this Twenty first Day of June in the year of our Lord One thousand Eight Hundred and thirty three.

JosephJoseph C. BrownBrown Clerk

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[missing figure]
No 35

June Term 1830

RalphRalph
vs
Coleman DuncanColeman Duncan

copy of Judgement & opinion

Filed July 2nd 1833

A GambleArchibald Gamble Clk

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[missing figure]
RalphRalph
vs
Coleman DuncanColeman Duncan

St Louis Circuit CourtCircuit Court
Suit for freedom

The plaintiff RalphRalph this attorney G.A. Bird,
will take notice that the defendant Coleman DuncanColeman Duncan
will come depositions of witness & to be taken to he read on
his part of the trial of said come, at the Court House
in MadisonvilleMadisonville, Hopkins CountyHopkins County KentuckyKentucky,
on the 20th of August next, between 8 o clock in
the morning six in the afternoon of that day,
to be continued from day, to day, at the same
place between the same hours, if need be.

Coleman DuncanColeman Duncan

St. LouisSt LouisJuly 3rd- 1833.

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[missing figure]

RalphRalph vs C.DuncanDuncan

not to take depositions

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[missing figure]

Served this notice on G.A.Bird
by delivering him a copy of it in the city of
St LouisSt Louis on the 5th of July 1833

John K WalkerJohn K Walker Sheriff

By Geo. Dept
Shff

Service 50 cts
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[missing figure]

County Of St. LouisSt Louis, Sct.
State of MissouriMissouri,

To Any Judge Or Justice Of The Peace Of The StateKentucky
of KentuckyKentucky --Greeting.

We, reposing special trust and confidence in your integrity and circumspection, do require and command you, that you cause
to come before you such person or persons, as shall be named to you by Coleman DuncanColeman Duncan or RalphRalph
a man of color their attorney or agent, and him or them examine upon
his, her or their corporal oath (to be by you administred) touching their knowledge of any thing that may relate to a certain matter
of controversy, now pending in our circuit Court, for the county of St. LouisSt Louis, wherein RalphRalph a man
of color is plaintiff and Coleman DuncanColeman Duncan is
defendant, on the part of the said defendant, and having reduced the said depositions so taken by
you as aforesaid, into writing, you are required to send the same, together with this commission, enclosed under your seal, to our
said circuit court, with all convenient speed.

[missing figure]
Witness, Archibald GambleArchibald Gamble , Clerk of our said Circuit CourtCircuit Court , at the City of StCity of St Louis.
LouisCity of St Louis, this fifth day of July in the year of our Lord, one thousand eight hundred and thirty three.

Archibald GambleArchibald Gamble

Clerk, C.C.
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[missing figure]
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[missing figure]

Depositions of witnesses produceed sworn, and examined,
at the court house in MadisonvilleMadisonville in the
County of Hopkin and State of KentuckyKentucky before
me, MeredithMeredith Myers MyersMeredith Myers a Justice of the peace
for the county and State aforeaid in a certain
cause, now depending in the Circuit Court of
the county of St. LouisSt Louis State of MissouriMissouri, between
RalphRalph (a man of colour) is plantiff and
Coleman DuncanColeman Duncan is Defendant, on the part
of the Defendant

William GordonWilliam Gordon of Lawful
age being produced, sworn and examined
on the part of the defendant deposit and sayeth
Question by the Deft Do you or not know that
John GordonJohn Gordon (ever hired a certain negro man
by the name of RalphRalph , where he had in possession,
in the state of IllinoisIllinois Ans I know
nothing of my own knowledge I heard John GordonJohn Gordon
say he never hired him there; John GordonJohn Gordon went
with him there in the year 1819, the negro had
time away before that time and give to the
State ofIllinois IllinoisIllinois - Questionby same State if you
recollect where old AbnerAbner Martin MartinAbner Martin moved to this
country the age of his son AbnerAbner Martin MartinAbner Martin
at that time and your opinion of the opportunity
of said AbnerAbner Martin MartinAbner Martin Jr. of knowing anything
about this man RalphRalph : Ans I think
it was in the year of 1817 or 18 that AbnerAbner Martin

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[missing figure]

MartinAbner Martin Jr.moved from Union County to this county.
I think young AbnerAbner Martin MartinAbner Martin was ten or eleven
years old at that time he was acquainted with
the boy but I think he could have known
but about the boy living at Lick in the
State ofIllinois IllinoisIllinois or about when it was made
a state Question by same Areyouacquainted
with John Steel formerly of this county if so
state his general character and all you know
about him when he first came here and with
where he came: An I am acquainted with
him, his general character with a majority
of the people is bad, he first came to this
country with John GordonJohn Gordon or a few days after the him
John Came from the Lick which was in November
her 1819- and Whether he ever saw John before
that time I know not but I believe he never did
And further this deponent saith not.

Wm. Gordan

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[missing figure]

I MeredithMeredith Myers MyersMeredith Myers a Justice of the peace in and
for the county of HopkinsHopkins & State of KentuckyKentucky
do here by certify, that WilliamWilliam Gordan the
deponent was by me sworn to testify the whole
truth of his knowledge touching the matter in
controversy in the cause aforeaid; that deponent
was examined and his examination reduced to writing,
and subscribed by aid deponent in my presence
on the 20th day of August in the year 1833, between the
hours of 8 o clock A. M. and 6 o clock P. M. at the
courthouse in the County of HopkinsCounty of Hopkins StateKentucky of KentuckyKentucky

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[missing figure]

I could not credit any thing he would say
even on oath, the cost account I had of
him he was editing a paper called the Free
Press in the city of St LouisSt Louis state of MissouriMissouri

question for same were you or not acquainted with the
negro boy RalphRalph the plaintiff in this suit if so
state and whether he was hired by JohnJohn Gordon GordonJohn Gordon or any
other person in the state of IllinoisIllinois in the year
1816 17 or 18 and what your opportunity of knowing
whether he was or not and had the opportunity
that AbnerAbner Martin MartinAbner Martin Jr. had of knowing these
things

Answer I was well acquainted with the
boy RalphRalph he belonged to my Father at
the dates you mention I do not believe my
father ever hired him in the state of IllinoisIllinois
though he permitted him to hire
himself there but at what time I cannot
state, The father of AbnerAbner Martin MartinAbner Martin Jr.moved
to this county from Union county KentuckyKentucky
in 1817 or 18 at that time AbnerAbner Martin MartinAbner Martin Jr.
was not more than eight or nine years of age
and further this deponent saith not

AmbroseAmbrose G Gordon GAmbrose G Gordon .GordonAmbrose G Gordon

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[missing figure]

I MeredithMeredith Myers MyersMeredith Myers a justice of the peace in
and for the county of HopkinsHopkins and state of KentuckyKentucky
do hereby certify that AmbroseAmbrose G Gordon GAmbrose G Gordon .GordonAmbrose G Gordon
the deponent was by me sworn to testify the

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[missing figure]

whole truth of his knowledge touching the
matter in controversy in the case aforesaid that
Defendant was examined and his examinationreduced
to writing and subscribed by said deponent
in my presence on the 20th day of August 1833
between the hours of 8 oclock AM and 6 oclock PM
at the court house in MadisonvilleMadisonville in the
county & state aforesaid

Given & certified the 20th day of August 1833

MeredithMeredith Myers MyersMeredith Myers J of theP

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[missing figure]

Also the Deposition of SamuelSamuel DowneyDowney
taken at the same time and place named in
the caption to be read as evidence in the same
cause, this deponent being of lawful age
and first duly sworn and examined on behalf
of the Defendant deposes and saith,

question for Defendant were you or not acquainted
with a negro man called RalphRalph owned
by JohnJohn Gordon GordonJohn Gordon if so state
whether or not he was hired by said GordonGordon
in the state of IllinoisIllinois during the year 1816 17
or 18. Ans I was a near neighbor to Mr.GordonGordon
(we lived about half mileapart ) I believe he never hired
him there at any time I was with Mr.GordonGordon at
the Lick in IllinoisIllinois with the boy in 1819 he did not hire then
but left him there I believe if he had ever
hired him there I should have known it.

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[missing figure]

given & certified the 20th of August 1833

MeredithMeredith Myers MyersMeredith Myers JP

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[missing figure]

Also the Deposition of George ClarkGeorge Clark taken at the
same time and place mentioned in the caption
to the read as evidence in the same cause this deponent
being of lawful age and being duly sworn
and examined on the part of the Deft deposes and sayeth

Question for Dft

Were you or not acquainted with John Steel if
so state all you know about him whether his
general character be good or bad. Answer
I know Mr Steel he is a man of bad
character and so believed to be by a majority
of all I have heard speak of him he married
the daughter of Mr. DowneyDowney of this county
whom I esteem as a very fine woman he
trifled about him for some time and went off
and left his wife and title children I would
not credit him where oath: He attempted to make
a living here as preaching but could not succeed
there he tried the plan of horse racing and upon
that quit the county. And further this deponent
sayeth not.

GeorgeGeorge Clark ClarkGeorge Clark

I MeredithMeredith Myers MyersMeredith Myers a Justice of the peace

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[missing figure]

in and for the county of HopkinsHopkins and
state of KentuckyKentucky do hereby certify that GeorgeGeorge Clark
ClarkGeorge Clark the deponent was by me from to testify
the whole truth of his knowledge touching
the matter in controversy in the cause aforesaid
that Deponent was examined and his examination
reduced to writing and subscribed by said deponent
in my presence on the 20th day of August 1833
between the hours of 8 Oclock A. M. and 6 Oclock A. M.
at the court house in MadisonvilleMadisonville in the county
& state aforesaid

Given & certified the 20th day of August 1833

MeredithMeredith Myers MyersMeredith Myers J. P.

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[missing figure]

Also the Deposition of Ambrose G. Gordon taken
at the time & place mentioned in the caption to
be read a evidence in the Same Cause this deponant
being of lawful age and first duly
sworn and examined on behalf of the Defendant,
deposes and sayeth,

Question by Defendant were you acquainted
with John Steel formerly of HopkinsHopkins county if so State
all you know about his general character, whether he
has a family or not whether he could be relied
upon when on oath and where he is at this time -
Ans I knew Mr. Steel he married the daughter of
Maj DowneyDowney of this county, by where she had three
children she and her children are at her fathers
in this county.

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[missing figure]

And further this deponent sayeth not
SamlDowney

I MeredithMeredith Myers MyersMeredith Myers a Justice of the Peace in & for
the county of HopkinsHopkins and state of KentuckyKentucky do
hereby certify that SamuelSamuel DowneyDowney the deponent
was by me sworn to testify the whole truth
of his knowledge touching the matter in controversy
in the case aforesaid that Deponent
was examined and his examination in reduced
to writing and subscribed by said deponent
in my presence on the 20th of August 1833
between the hours of 8 o'clcok AM and 6 o'clock
PM. at the courthouse in MadisonvilleMadisonville in
HopkinsHopkins county and state of KentuckyKentucky

Given and certified the 20th of August 1833

MeredithMeredith Myers MyersMeredith Myers JP

Justices fee $ 1.00 Witnesses 2.00
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[missing figure]

I MeredithMeredith Myers MyersMeredith Myers a Justice of the peace in and
for the county HopkinsHopkins and state of KentuckyKentucky do
certify that in pursuance of the within commission
and notice, came before at the court house in MadisonvilleMadisonville
in the county of HopkinsHopkins & state of KentuckyKentuckyWilliamWilliam Gordon

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[missing figure]
GordonAmbroseG.GordonWilliam Gordon GeorgeGeorge Clerk
& SamuelSamuel DowneyDowney who were there by me sworn
and examined and such examination reduced
to writing and subscribed by them respectively
in my presence and their depositions are
here with returned given at the courthouse in
MadisonvilleMadisonville in HopkinsHopkins county and state
of KentuckyKentucky this 20th August 1833

MeredithMeredith Myers MyersMeredith Myers JP

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[missing figure]

KentuckyKentucky
Hopkins CountyHopkins County

It is hereby certified that MeredithMeredith Myers MyersMeredith Myers Esq.
on the twelveeth day of August in the year of our Lord one thousand eight hundred & thirty threewas and now is a Justice of the peace
within and for the County & state aforesaid
duly commissioned and acting as such &that
full faith and credit and due to his
as such in testimony whereof I SamuelSamuel

[missing figure]

WoodsonWoodson clerk of the County CourtCircuit Court
for the County aforesaid the same
being a court of record so constituted
by law have hereunto subscribed my
name & affixed the seal of saidcounty the
28th day of August 1833

SamWoodson

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[missing figure]

County Of St. LouisSt Louis, Sct.
State of MissouriMissouri,

To Any Judge Or Justice Of The Peace Of the state of IllinoisIllinois
--Greeting.

We, reposing special trust and confidence in your integrity and circumspection, do require and command you that you cause
to come before you such person or persons, as shall be named to you by RalphRalph a man of color or by ColemanColeman Duncan
DuncanColeman Duncan their attorney or agent, and him or them examine upon
his, her or their corporal oath (to be by you administered) touching their knowledge of any thing that may relate to a certain matter
of controversy, now pending in our Circuit CourtCircuit Court , for the county of St. LouisSt Louis, wherein RalphRalph a man of color
is plaintiff and Coleman DuncanColeman Duncan is
defendant on the part of the plaintiff, and having reduced the said depositions so taken by
you as aforesaid into writing, you are required to send the same, together with this commission,
enclosed under your seal, to our
said Circuit CourtCircuit Court , with all convenient speed.

[missing figure]
Witness, Archibald GambleArchibald Gamble , Clerk of our said Circuit CourtCircuit Court , at the City of StCity of St Louis.
LouisCity of St Louis, this eleventh day of November in the year of our Lord, one thousand eight hundred and thirty three

Archibald GambleArchibald Gamble

Clerk, C.C. Copy of Notice
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RalphRalph a Man of color
vs
Coleman DuncanColeman Duncan

In the St Louis Circuit CourtCircuit Court
MissouriMissouri suit for freedom &c.

To the above named Defendant EdwardEdward Bates BatesEdward Bates being his
attorney of RecordSirI shall proceed to take Depositions to
be said in evidence in the above cause at the court house
in the town of Equality county of GallatinGallatin & state of IllinoisIllinoison
the twenty third day of Novemberinstant & at the court house
in the town of MadisonvilleMadisonvilleHopkinsHopkins county KentuckyKentucky on the twenty eight day of November instant between the hours of eight
o clock A.M. and six o clock P.M. of each of said days and
I shall continue taking Depositions at each place from day to
say (sundays excepted) between the same hours on each day
until I shall take as many as I deem necessary November 11th 1833

RalphRalph by GG A Bird AG A Bird BirdG A Bird
his attorney

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[missing figure]

Executed this Notice by delivering a true copy of it to a
free white female, member of the family of EdwardEdward Bates BatesEdward Bates , attorney
of Record for Defendant, over the age of fifteen years, at his
place of residence in the city of St LouisSt Louis on the 11th day of November 1833.

JohnJohn K Walker KJohn K Walker WalkerJohn K Walker sheriff
by JJames Brotherton BrothertonJames Brotherton D.P.Sheriff

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RalphRalph a man of color
vs.
Coleman DuncanColeman Duncan

In the
saint louis
Circuit CourtCircuit Court
MissouriMissouri

Deposition of witness produced sworn
and examined at the court house
in the town of MadisonvilleMadisonville in the
county of HopkinsHopkins and state of
KentuckyKentucky before me EEdward W R Woolfolk WEdward W R Woolfolk REdward W R Woolfolk WoolfolkEdward W R Woolfolk
a justice of the peace within & for
said state & county in a certain cause
now depending in the circuit court
of saint louis county & state of missouri
between RalphRalph a man of color
plaintiff & Coleman DuncanColeman Duncan Defendant
on the 28th day of November A.D. 1833
between the hours of 8 o'clock A.M. & 6 o'clock
P.M. of said day on the part
of the plaintiff.

WilliamWilliam Bradley of lawful age being
produced, sworn and examined on the
part of the plaintiff deposith and sayeth
Question 1st on the part of the plaintiff.
Do you know John Steel & his general
character: Answer: several years age when
Mr.Steellived in KentuckyKentucky I had a partialacquaintance

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with him but did not live in the same neighborhood
at present I am not acquainted with his general Character

Question 2nd on the part of the plaintiff
from your knowledge of his general
character as a man of truth would you
have believed him when on oath in a court
of justice.

answer as I have before stated I am not
very well acquainted withMr. Steel's general
character I never heard his credibility on oath disputed
while I knew him in KentuckyKentucky

WW Bradley .BradleyW Bradley

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[missing figure]

IEEdward W R Woolfolk WEdward W R Woolfolk REdward W R Woolfolk WoolfolkEdward W R Woolfolk a justice of the peace do hereby
certify, that WW Bradley .BradleyW Bradley the deponent, was by me
sworn to testify the whole truth of his knowledge
touching the matter in controversy in the cause
aforesaid; that deponent was examined, and
his examination reduced to writing, and subscribed
by said deponent, in my presence on
the 28th day of November, in the year eighteen hundred and thirty three, between the hours of
8 o'clock in the forenoon and 6 o'clock of the
afternoon of said day, at the court house in
the town of MadisonvilleMadisonville in the county of HopkinsHopkins
and state KentuckyKentucky.

given and certified, the twenty eighth day of November 1833.

EEdward W R Woolfolk WEdward W R Woolfolk REdward W R Woolfolk WoolfolkEdward W R Woolfolk JP

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[missing figure]
Ralph a man of Color
vs
Coleman DuncanColeman Duncan

In the St Louis Circuit CourtCircuit Court
MissouriMissouri Suit for freedom &

To the above named Defendant EdwardEdward Bates BatesEdward Bates
Esq.being his attorney of record

Sir I shall proceed to take depositions to be read
in evidence in the above named cause at the Court
house in the town of Equality County ofCounty of Gallatin GallatinCounty of Gallatin
state of IllinoisIllinois an the twenty third day of november
instant & at the Court house in the town MadisonvilleMadisonville
HopkinsHopkins County CountyHopkins County state of KentuckyKentucky in the
twenty eight day of november instant between
the hours of eight Oclock A.M and six oclock
P.M. of each of said days and I shall
continue taking Depositions at each place
from day to day (sundays, excepted) between
the same hours in each day untill I shall
take as many as I deemnecessary

RalphRalph by EEdward Bates .BatesEdward Bates
his atty

November 11th 1833.

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RalphRalph
vs
Coleman DuncanColeman Duncan

notice of taking
Depositions

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[missing figure]

Executed this notice by delivering a true copy of it to a
free white female member of the family of EdwardEdward Bates BatesEdward Bates
attorney of Record for defendant over the age of fifteen years at his place of residence
in the city of St LouisSt Louis on the 11th day of November 1833

JohnJohn K Walker KJohn K Walker WalkerJohn K Walker sheriff
by JJames Brotherton BrothertonJames Brotherton DPSheriff

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[missing figure]

Depositions of witnessesproduced sworn and
examined, at the Court house in the town of
Equality, in the County of GallatinCounty of Gallatin and state of
IllinoisIllinois before meTylerTyler D Hewitt DTyler D Hewitt HewittTyler D Hewitt

a Justice of the peace within & for said state & county
in a certain cause now depending in the CircuitCircuit Court
CourtCircuit Court of Saint LouisSt Louis county and State of MissouriMissouri
between RalphRalph a man of Color plaintiff, and
Coleman DuncanColeman Duncan defendant, on the 23rd day of November AD and 6 o'clock pm of said
day, on the part of the plaintiff.

I a justice of the peace with-
in and for the County of & State of IllinoisIllinois do
hereby certify that state Deponent,
was by me to testify whole truth of his knowledge
touching the matter in Controversy in the cause aforesaid

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[missing figure]
state the deponent was examined, and his exam-
ination reduced to writing and subscribed by
said deponent, in my presence on the 23rd day of November in the year eighteen hundred and thirty three, between the hours of 8 O'clock A.M.
in the forenoon, and six O'clock in the afternoon,
at the Court house in the tour of Equality
in the County of Gallitin & State of IllinoisIllinois
given and certified, the 23rd day of November 1833.

J. P.

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[missing figure]

WilliamWilliam Bourland of lawful age, being produced,
sworn and examined, on the part of the plaintiff,
deposith and sayeth that he is well acquainted
with RalphRalph the plaintiff and also JohnJohn Gordon GordonJohn Gordon
deceased of HopkinsHopkins County CountyHopkins County and state of KentuckyKentucky
That JohnJohn Gordon GordonJohn Gordon owned the plaintiff as early
as the year 1805, that GordonGordon was in the
habit as the deponent understood of hiringRalphRalph to work at the Gallatin
Saline in the then Territory of IllinoisIllinois at various
times from the year 1810 up to 1817. that GordonGordon
frequently, within the same years, came over
to the saline Lick in IllinoisIllinois in GallatinGallatin county
and got salt and money for RalphRalph the plaintiff
work, that this was the general understanding of
all the neighbors as this deponent believes by common
report of the neighborhood WmWilliam Bourland BourlandWilliam Bourland
Question by plaintiff Do you know John
Steel and if so what is his general character ?
Answer I do and have ever thought him
an honest and industrious man and even when

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I asked him for the truth I feel sure I
should get it.

In 2nd From your knowledge of his general
Character would you belive him or oath in
a court of justice.

Answer: I would as soon as any man I know.

WmWilliam Bourland BourlandWilliam Bourland

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[missing figure]

I TylerTyler D Hewitt DTyler D Hewitt HewittTyler D Hewitt a justice of the peace
within and for the County ofCounty of Gallatin GallatinCounty of Gallatin and state of
IllinoisIllinois do hereby certify, that WilliamWilliam Bourland
the deponent, was by me sworn to testify the whole
truth of his knowledge touching the matter in
controversy in the cause aforesaid; that deponent
was examined and his examination reduced to
writing, and subscribed by said deponent, in
my presence on the 23rd day if November in the year eighteen hundred and thirty three between
the hours of 8 o' clock in the forenoon and 6 o'
clock in the afternoon, at the Court hour
in town of Equality in the county of GallatinGallatin
and state of IllinoisIllinois.

given and certified, on the 23rd day of November 1833.

TylerTyler D Hewitt DTyler D Hewitt .HewittTyler D Hewitt
JP

Magistratesservice$ 1.00
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[missing figure]

It is hereby Certified, that TylerTyler D Hewitt DTyler D Hewitt HewittTyler D Hewitt on
the twenty third day of November in the year eighteen hundred and thirty three, was and now is an acting
justice of the peace within and for the CountyCounty of Gallatin
ofCounty of Gallatin GallatinCounty of Gallatin and State ofIllinois IllinoisIllinois duly commissioned
and acting as such, and that full faith and
Cerdit are due to his acts as such.

In testimony whereof I JamesJames Caldwell CaldwellJames Caldwell
Clerk of the County Court of Gallatin County
& state of IllinoisIllinois Have hereunto subscribed
my, name, and affixed the seal of office, this
twenty third day of November eighteen hundred & thirty three

JamesJames Caldwell CaldwellJames Caldwell clkGC

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[missing figure]

RalphRalph
vs
Coleman DuncanColeman Duncan

Depos of
WmWilliam Bourland BourlandWilliam Bourland
for plff

opened & filed
January 11th 1834

A GambleArchibald Gamble Clk

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[missing figure]
RalphRalph a man of color
vs
Coleman DuncanColeman Duncan

Suit for freedom
in the Saint LouisCircuit Court
Circuit CourtCircuit Court in
the State of MissouriMissouri

Depositions of witness produced sworn and examined, at the Court house in the town of MadisonvilleMadisonville,
in the County of HopkinsCounty of Hopkins, and State of Kintucky,
before me E.W.R.Wolfolk a Justice of the peace
within and for said State and County, in a
certain cause, now depending in the Circuit CourtCircuit Court
of Saint LouisSt Louis County and State of MissouriMissouri, between
RalphRalph a man of color Plaintiff, and ColemanColeman Duncan
DuncanColeman Duncan Defendants, on the 28th and 29th days of November A.D. 1833. Between the hours of
8 O'clock A.M. 6 O'clock P.M. of each of said
day on the part of the Plaintiff.

TimothyTimothy Fisk FiskTimothy Fisk of Lawful age, being produced
sworn and examined, on the part of the
plaintiff deposeth and sayeth that he
the parties to this suit, that he knew RalphRalph
the plaintiff whilst he was the slave of JohnJohn Gordon
GordonJohn Gordon , late âdeceasedâ of Hopkins CountyHopkins County and State ofKentucky
KentuckyKentucky that said GordonGordon in his life time,
as this deponent
understood sold or swaped said RalphRalph the
plaintiff to IsaacIsaac Metcalf MetcalfIsaac Metcalf as deponent understood and that since
GordonGordon parted with RalphRalph the plaintiff he
RalphRalph has been taken out of the County ofCounty of Hopkins
HopkinsCounty of Hopkins to some place unknown to this deponent
only by report.

Question 1st, on the past of the Plaintiff
Do you know whether or not RalphRalph the Plaintiff was

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ever hired permitted to labor in the Territory of
IllinoisIllinois previous to the 3rd day of December 1818 and
if so state what you know touching such hiring
or permission?

Answer: I have no knowledge of the matter

Question 2nd on the part of the plaintiff.
Do you know whether or not DuncanDuncan the Defendant
ever hired or consented to RalphRalph the plaintiff
to labor in the state of IllinoisIllinois?

Answer: I do not

Question 3rd on the part of the Plaintiff.
Have you ever been acquainted with John
Steel who married a Daughter Major : SamuelSamuel Downey's
of this County?

Answer I have

Question 4th on the part of the Plaintiff.
How long have you been acquainted with him?

Answer: About twelve or thirteen years

Question 5th on the part of the Plaintiff
How you had an opportunity of becoming
acquainted with his general character as a man of truth and if so state whether or not from
your knowledge of his general Character you
would believe him when on oath in a Court
of justice?

Answer: When John Steel first came in
my neighbourhood he commenced teaching an
english school near my house during which

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[missing figure]

time I became well acquainted with him as
he was often at my house and I never know
any thing against him, but always thought
him to be a man of truth and honesty
and I believe he bore that name in our
settlement and should think his Oath
good in a Court of Justice and should
believe him myself

Question 6th On the part of the Plaintiff
Have you any public vocation or calling
and if so please state what it is.

Answer: I am now and have been
a Baptist preacher for thirty one years

Timothy FiskTimothy Fisk

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[missing figure]

I, E.W.R Woolfolk a Justice of the peace do hereby
certify, that Timothy FiskTimothy Fisk the deponent was
by me sworn do testify the whole truth of
his knowledge touching the matter in controversy
in the cause aforesaid; that the deponent
was examined and his examination reduced
to writing and subscribed by said deponent
in my presence on the 29th day of November in the year eighteen hundred and thirty three
between the hours of eight O'clock in the
forenoon and six O'clock of the afternoon
at the court house in the town of MadisonvilleMadisonville in
the county of HopkinsHopkins in the State of KentuckyKentucky
sworn and certified the 29th day of November 1833.

E.W.R.Woolfolk- J.P.

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[missing figure]

John BJohn B .Laffoon of lawful age, being produce, sworn
and examined, on the part of the Plaintiff deposeth,
and sayeth, that he is acquainted with the
parties to this suit; that when he first knew the
Plaintiff RalphRalph he was owned by JohnJohn Gordon
GordonJohn Gordon deceased who sold RalphRalph the plaintiff
as deponent believes to one Issac Metcalf
who sold him to oneAbner West who sold
him to Coleman DuncanColeman Duncan the Defendant by
whom RalphRalph was taken or sent out of this
County to parts unknown to this deponent only
by report.

Question 1st on the part of the Plaintiff
If you have ever known or heard of RalphRalph
the Plaintiff having been hired or permitted to
labor in the State or Territory of IllinoisIllinois state at
what time and by whom he was so hired or
permitted

Answer: I have frequently heard of the
Plaintiff RalphRalph having been hired to labor at
the Saline Lick in the State of IllinoisIllinois by John
Gordan and I think at as early a time as 1816 or
1817 & from that time at interval up to the time he
was taken out of this county

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[missing figure]

Question 6th on the part of the Plaintiff.
Do you know where said State is now and whither
he has now or ever has had any correspondence
with his family since he left this County or whether
he ever intends to take any care of his family or
not

Answer : I have frequently heard from
his family that they received letters from him
during his absence and received one from
him my self through his family. He is now
in this County and as I was informed is now
preparing to remove with his family to the
Territory of ArkansasArkansas where if am informed
he established a Newspaper Called the
Helena Herold

Question 7th on the part of the Plaintiff
How far did you live from Steel and his family?

Answer About one mile & 3/4

Question 8th on the part of the Plaintiff
WillWill you state if you know what was the
cause of said Steels leaving this County.

Answer: I was imformed by him that
the losses be sustained by the sinking of his
Boats were more than he was able to repose
and therefore left his family with his fatherinlaw

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[missing figure]

Question 2nd, on the part of the Plaintiff
Do you know John Steel who married a
Daughter of Maj. SamuelSamuel DowneyDowney of this County

Answer: I Do.

Question 3rd on the part of the Plaintiff
Are you acquainted with his general Character
as a man of truth?

Answer: I have lived neighbour to him for
several years & know nothing against him as a man of truth

Question 4th On the part of the Plaintiff
From your knowledge of his general Character
as a man of truth whould you believe him or
not when an oath in a court of Justice?

Answer: From what I know of his general
Character i always took him to be a man of
truth and entitled to credit & when on oath
I should believe him in a court of Justice.

Question 5th on the part of Plaintiff
Do you know whether or not he has been absent
from this county for some years?

Answer: He has some 4 or 5 years

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[missing figure]

JamesJames Bishop of careful age, being produced,
sworn and examined, on the part of the
plaintiff and sayeth.

Question 1st by the plaintiff
Do you know John Steel and his general
character as a man of truth and if so
would you believe him on oath in a
court of justice

answer Ihad apartialacquaintance with
one John Steel when he lived in this county
which was seven years ago I neverknew him
sworn in a court of justice but from my
acquaintance with him during the time
of his residence in this county I should
believehe was in titled to credit when on
oath in a court of Justice

JamesJames Bishop

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[missing figure]

IEEdward W R Woolfolk WEdward W R Woolfolk REdward W R Woolfolk WoolfolkEdward W R Woolfolk a justice of the peace do
hereby certify, that JamesJames Bishop the Deponent, was
by me sworn to testify the whole truth of his
knowledge touching the matter in controversy
in the cause aforesaid; that Deponent was
examined, and his examination reduced to
writing, and subscribed by said Deponent

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[missing figure]
in my presence on the 29th day of November, in the year eighteen hundred and thirty three, between the hours of
8 o'clock in the forenoon and 6 o'clock
of the afternoon at the court house in
the town of MadisonvilleMadisonville in the county of
HopkinsHopkins and state of KentuckyKentucky.

given and certified, the 29th day of November 1833.

EwRWoolfolk JP

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[missing figure]

IEEdward W R Woolfolk WEdward W R Woolfolk REdward W R Woolfolk WoolfolkEdward W R Woolfolk a justice of the peace, within
and for the county of HopkinsHopkins the state
of KentuckyKentucky do certify that in pursuance of
the annexedcommission and notice came
before me at the court house in the
county and state last aforesaid WW Bradley BradleyW Bradley
TimothyTimothy Fisk FiskTimothy Fisk JohnJohn B BJohn B LaffoonGeorge Finley and
JamesJames Bishop who were there by me sworn
and examined and such examination
reduced to writing and subscribed by
them respectively in my presence and their
said Depositions are now herewith returned

given at MadisonvilleMadisonville in the county
of HopkinsHopkins and state of KentuckyKentucky
this 29th day of November 1833.

EEdward W R Woolfolk WEdward W R Woolfolk REdward W R Woolfolk WoolfolkEdward W R Woolfolk

justices, fees for taking Depositions
two days $ 200
Rec'd payment of the plaintiff

EWRWoolfolkJP

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[missing figure]

It is hereby certified that EEdward W R Woolfolk WEdward W R Woolfolk REdward W R Woolfolk WoolfolkEdward W R Woolfolk
on the 28th and 29th days of November in the year eighteen hundred and thirty three
was and now is an acting justice of
the peace within and for the county of
HopkinsHopkins and state of KentuckyKentucky duly sworn
and acting as such and that
full faith and credit are due to his
acts as such

In testimony whereof I SamuelSamuel
WoodsonWoodson clerk of the county court
of Hopkins CountyHopkins County and state of KentuckyKentucky
have hereunto subscribed my name
and affixed the seal of office this
twenty ninth day of November eighteen hundred and thirty three.

[missing figure]

Sam WoodsonWoodson clerk
HopkinsHopkins County CountyHopkins County Court

Clerk fee 50 cts
Tax 50
1.00 Rec'd payment of plff

SWoodsonclk

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[missing figure]

RalphRalph
vs
Coleman DuncanColeman Duncan

Depos. of
TimothyTimothy Fisk FiskTimothy Fisk
JohnJohn B BJohn B Laffoon
GFinley
WW Bradley BradleyW Bradley
JBishop
for plaintiff

opened & filed
Dec 23rd 1833

A GambleArchibald Gamble clk

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[missing figure]

Question 4th on the part of the Plaintiff
Do you know whether or not there was
any understanding or institution that any
of your Company of which you have
spoken that went to GalenaGalena and
particularly with RalphRalph or JosephJoseph
a man of color were to go on the
flat Boat to New OrleansOrleans or any
other part of the lower Country

Answer There was no such understanding
that I know of and I believe
that it was the understanding of
all parties that we the above named
five persons were going to GalenaGalena
Lead mines in IllinoisIllinois.

GeorgeFinley

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[missing figure]

I, E.W.R.Woolfolk a Justice of the Peace do
hereby certify that George Finley the Deponent was by
me sworn to testify the whole truth of his knowledge
touching the matter in controversy in the cause aforesaid
that Deponent was examined and his examination
reduced to writing subscribed by said
Deponent in my presence on the 29th day of November in the year eighteen hundred and thirty three between the hours of eight O'clock in the forenoon and six O'clock of the
afternoon at the court house in the town of

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[missing figure]
MadisonvilleMadisonville in the County of HopkinsCounty of Hopkins &
State of KentuckyKentucky.

Given and certified the 29th day of November 1833.

E.W.R.Woolfolk J.P.

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[missing figure]

We started in a flat Boat to go down
the this river until we could get our a
Steam Boat that would take us up the
Missipippi - the flat boat sunk before we
got very far and we all left the Boat &
walked to where we got a passage on a
Steam Boat that took us on to St. LouisSt Louis where we
got on another boat that took us on
to GalenaGalena where are all went to mining -
the negros RalphRalph & Jodeph being under the
care of JesseJesse Duncan DuncanJesse Duncan . About the 18th of July following Eoodruff & myself quit the
GalenaGalenaLead Mines & I left JesseJesse Duncan DuncanJesse Duncan &
Ralph & Joseph at work at the GalenaGalena lead
mines.

Question 1st on the part of the plaintiff. Who claimed RalphRalph the Plaintiff when you started to GalenaGalena. Answer: Coleman DuncanColeman Duncan the defendant

Question 2nd an the part of the plaintiff

Do you know whether Coleman DuncanColeman Duncan
knew that RalphRalph the Plaintiff was going to
GalenaGalena to work in care of JesseJesse

Answer: He did

Question 3rd, on the part of the plaintiff.

Do you know whetherColeman DuncanColeman Duncan made
any objection to Ralph's going to GalenaGalena lead
mines in IllinoisIllinois

Answer: I never heard him make any

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[missing figure]
until he could so repose his fortune as
to enable him again to take charge of
them this I undertood from him
at different times when on visits to see his family

JohnJohn B BJohn B . Laffoon

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[missing figure]

I, E. W. R. Woolfolk a justice of the peace do hereby
Certify that John BJohn B . Laffoon the Deponent was by
me sworn to testify the whole truth of his knowledge
touching the matter in Controversy in the
Cause aforesaid; that the Deponent was examined
and his examination reduced to writing and
subcribed by said Deponent in my presence on
the29th day of November in the year eighteen hundred and thirty three between the hours of 8 o'clock in
the forenoon and 6 o'clock of the afternoon
at the court house in the town of MadisonvilleMadisonville
in the County of HopkinsCounty of Hopkins and StateKentucky of KentuckyKentucky
given and certified the 29th day of November 1833.

EEdward W R Woolfolk W REdward W R Woolfolk WoolfolkEdward W R Woolfolk J P

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[missing figure]

George Finley of lawful age, being produced
sworn and examined on the part of the Plaintiff
deposeth and sayeth in the spring of 1827
myself, HiramHiram Woodruff WoodruffHiram Woodruff ,JesseJesse Duncan DuncanJesse Duncan , RalphRalph
the plaintiff and JosephJoseph a man of color
all started from HopkinsHopkins county State ofKentucky
KentuckyKentucky with the intention of going to
GalenaGalena lead mines in the State of IllinoisIllinois

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[missing figure]

County of St. LouisCounty of St Louis, sct.
The State of MissouriMissouri,

To the Sheriff of St. Louis CountyâGreeting.

You are hereby commanded to summon John Steel, Abner MartinAbner Martin &
John HartJohn Hart
that setting aside all manner of excuse and delay, they be and appear in proper person
before the Judge of our Circuit CourtCircuit Court , on the second day ofJanuarynext at the City of St. LouisCity of St Louis, then and there to testify and
the truth to say in a certain matter of controversy now pending in our said Court,
wherein RalphRalph (a man of color) is plaintiff and
Coleman DuncanColeman Duncan is defendant on the
part of the Plaintiff; and have you then there this writ,

[missing figure]
Witness,Archibald GambleArchibald Gamble , Clerk of our said Circuit CourtCircuit Court , at the
City of St.LouisCity of St Louis, this second day of November in the year of our Lord one thousand eight hundred and thirty three

Archibald GambleArchibald Gamble

Clerk C.C.
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[missing figure]

November Term 1833

RalphRalph
vs
Coleman DuncanColeman Duncan

for plff

John Steel 6

Abner MartinAbner Martin

John HartJohn Hart 12

on 2nd January 1834
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[missing figure]

Executed this writ on John Steel by Reading it
to him 6th on John HartJohn Hart by reading 12th both
in the county of St. LouisSt LouisNov 1833AbnerAbner Martin
MartinAbner Martin not found in my county

John K WalkerJohn K Walker Sheriff

G.stonerDp.

service $ 1.00
12 1/2
$ 1.12 1/2
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[missing figure]

County Of St. LouisSt Louis, Sct.
The State Of MissouriMissouri,

To the Sheriff of St.Louis CountyâGreeting.

You are hereby commanded to summon John WarfieldJohn Warfield
that setting aside all manner of excuse and delay, he be and appear in proper person
before the Judge of our Circuit CourtCircuit Court , on the 20th day ofJanuary at the City of St. LouisCity of St Louis, then and there to testify and
the truth to say in a certain matter of controversy now pending in our said Court,
wherein RalphRalph a man of color is plaintiff and
Coleman DuncanColeman Duncan is defendant on the
part of the plaintiff; and have you then there this writ.

[missing figure]
Witness, Archibald GambleArchibald Gamble , Clerk of our said Circuit CourtCircuit Court , at the
City of St.LouisCity of St Louis, this 18th day of January in the year of our Lord one thousand eight hundred and thirty four

A.GambleArchibald Gamble

Clerk C.C.
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RalphRalph
vs
Coleman DuncanColeman Duncan

for

John WarfieldJohn Warfield 20

20th of January
for Plaintiff

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Executed this writ on John WarfieldJohn Warfield
in the city of St LouisSt Louis on the 20th day of January 1834

John K. WalkerJohn K Walker Sheriff

by JJames Brotherton BrothertonJames Brotherton
Dep Shf

Service $ 50
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State of MissouriMissouri,
County of St. LouisCounty of St Louis, Sct.

To the Sheriff of St. Louis CountyâGreeting.

You are hereby commanded to summon TheodoreTheodore L McGill LTheodore L McGill . McGillTheodore L McGill
that setting aside all manner of excuse and delay, he be and appear in proper person
before the Judge of our Circuit CourtCircuit Court , forthwith day of
at the City of St. LouisCity of St Louis, then and there to testify and
the truth to say in a certain matter of controversy now pending in our said Court,
wherein RalphRalph is plaintiff and
ColemnDuncanDuncan defendant on the
part of the plaintiff and have you then there this writ.

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Witness, Archibald GambleArchibald Gamble , Clerk of our aid Circuit CourtCircuit Court , at the
City of St. LouisCity of St Louis, this 20th day of January in the year of our Lord one thousand eight hundred and thirty four

A. GambleArchibald Gamble Clerk C.C.

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Executed this writ on Theo LTheo L McGill .. McGillTheo L McGill
in the city of St. LouisSt Louis on the 20th day of January 1831

JohnJohn K Walker K. WalkerJohn K Walker Shff.

Service 50
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Novr Term 1833

RalphRalph
vs
Coleman DuncanColeman Duncan

subpoena for
Theo LTheo L McGill .McGillTheo L McGill
for plff
forth with

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RalphRalph
vs
Coleman DuncanColeman Duncan

The defendant moves the Court to grant
him a new trial in this case Because

1 The verdict is against evidence

2 against law

3 against the instruction of the court

4 The court instructed the jury erroneously
in front of the plaintiff

EEdward Bates BatesEdward Bates
for deft

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RalphRalph
vs
C.DuncanDuncan

motion for new trial

filed January 24th 1834

A GambleArchibald Gamble Clk

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State of MissouriMissouri
St Louis County SS.

Circuit CourtsCircuit Court third Judicial July term in the year of Christ 1830

RalphRalph a man of color complains of JamesJames Duncan Duncan
& Coleman DuncanJames Duncan of a plea of trespassassault &
Battery & false imprisonment for than hereto fore
to wit the thirteenth day of May in the year of Christ eighteen hundred & thirty at the County ofCounty of St Louis
St LouisCounty of St Louis aforesaid the said Defendants with force
& arms made an assault upon the said plaintiff
& there beatbruisedwounded & ill treated him
then & there with force & arms falsely & unjustly
imprisoned the said plaintiff & kept him
him in prison there withoutany Lawful authority
on cause for a long span of time to wit for
a span of nine days & then nextensuing
And said plaintiff further says than before & at
the time of the committing of the said several
grievances he was & still is a free person & that
said Defendant held & detained & still hold &
detain him in Slavery wherefore said plaintiff
says he is greatlyinjured & hath sustained damages
to five hundred dollars therefore he sues

G.A.Bird atty for plff

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RalphRalph a man of color
vs
JamesJames Duncan Duncan &
Coleman DuncanJames Duncan

This is an action for
freedom in the form
presented by statements
Damage is $ 500 the
Clerk will plead
Summons

G A BridG A Brid atty
for plff

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RalphRalph
vs
J & C DuncanDuncan

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On Demand I promise to pay
RalphRalph twenty Dollars for value
received witness my, hand& seal
December 2nd 1829

Coleman DuncanColeman Duncan

ExhibitA
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Ralph vsJas &: Coleman DuncanColeman Duncan - suit for freedom

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Instructions

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1. That the constitution of IllinoisIllinois takes date & was obligatory
from the time it was passed unless some
other date is founded in the body of the document

given

2. That althought the plaintiff may have resided in
the state of IllinoisIllinoissince the adoption of the constitution
of that state since the year 1825, or
in the territory of IllinoisIllinois before the adoption
of said constitution still such residence will
not of itselfwork the emancipation of the plaintiff
unless it appear to the satisfaction of the jury,
that such residence in IllinoisIllinois was with the
consent of the then master of the plaintiff

given

3. That the execution of the note by the defendant
to the plaintiff as given in evidence in this case does
not operate a manumission of said plaintiff

given

4. The ordinance of 1787 does not & cannot control the
operation of the constitution of IllinoisIllinois regard to
the subject of slavery.

given

5 AnyNo temporary stay in IllinoisIllinois by RalphRalph
the plaintiff with the consent
of his master, with no view to residence there
and without staying there long enough to
acquire the character of a resident, can
operate the emancipation of the plaintiff.

not given

6. That no residence of RalphRalph in the Territory or state of IllinoisIllinois
or the territory of MichiganMichigan can operate to emancipate
the plaintiff unless it is proved to their satis
faction of jury that the master operated to
such residence

given

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7. That the plaintiff having been found
in the territory or state of IllinoisIllinois or territory
of MichiganMichigan does not alone authorize a
presumption that his master consented
to his being there, but such consent must
be proved

given

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Wethe Jury find
a verdict In favour of the defendant

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RalphRalph
vs
DuncanDuncan

Motion for a mistrial

all the evidence, is continued in the depositionsexcept,
the testimony of JohnJohn Warfield WarfieldJohn Warfield , he stated
that, to his knowledge, the plaintiff wasemployed,
by James DuncanJames Duncan , brother of deft in IllinoisIllinois near
GalenaGalena, at Mining, during the years 1828 & 1829

The reasons ruled in favor for a newtrial, are as stated

1 Our statuterequiresthat plaintiff shall in a suit
for freedom allege ``that before & at the time
of the committing the grievance in declaration
mentioned Dft held & detained & still holds & -
detaoms plaintiff in slavery'' & the lawrequires to
maintain this action that then allegations shall be
fully proved and that in this case they were
not proved.

1 Insist, that those allegations weresufficiently from &,
from the facts, that Deft. in KentuckyKentuckyactually held &
claimed plaintiff as a slave - that he hired him
as his slave to JesseJesse Duncan DuncanJesse Duncan for the purpose of having
him taken & put to labour in IllinoisIllinois - that he
defended this said by pleading that plaintiff was a
slave - that during this suit by his motion which
is spread upon the record the plaintiff was
by aware of this courtdelivered to defendant
an the presumption, that he was Dft slave

The truedoctrine in MissouriMissouri, is that black persons
in this state are presumed to be slaves untill the
contrary appears. he who has oneowned &
possessed a slave is still in presumption of law
owned & possessed of him unless the contrary
isproved on the supposedownerdisclaimed
he who claims a Black person in Mo.
as his slave, of such Black has not about him the
record evidence of his freedom, in the eve of the
lawholds him in slavery - because he is presumed
to be a slave & if he is claimed as such is liable to
all the disabilities of slave Laws of Mo.
and Because the statutedeclares that suits for freedom
``shall be broughtagainst the person holding the
petitioner in slavery or the one claiming him or her as a
slave state suits freedom law Mo. 405

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2 the insist that it is not necessary to prove that at the
time of the commencement of the suitDeftactually
had the plaintiff by the throat of the head in actualpossession

If this doctrinewent to prevail no man who
is free a slave de facto could evermention
a suit for freedom and the statute

Because no man who has not the receipt or property
in a thing can have constrictionspossession of this
thing - therefore if a wrongfully held him as a slave
the minute he escapesfrom the custody of a
and goesbefore a Judge
to sue for freedom the judge may tellhim
and may not let you see - Because if you are
a free man you can not in lawbe in
possession of the man who claims you and if
you are not so in possession you could not
maintain your suit if you shouldsueyou
mustwait untill you are put in &
if your will bring your before me
& you bring your suit you cando
according to the Statute & not otherwise

but the statute was made to protect those who
are unable to protectthemselves - the allegations
required in the Declaration were probably intended
vs a farm for imprisonmentwho are
must assign and that the court maybe
in the declaration try in the plaintiffs
of complaint & the Defendants claim and
that defendant maybe Simply plea the general
issueamid that being drawn to his plea of satisfaction
the statute is nearly cumulative & wasneverintended
to make it necessary to produce more or other
to maintain an action under the
statute than at theLaw -
the Statute declares that in trespass freedom the Deff
shall declare in trespassassault - and
that the Jury if theyfound for the plaintiff
shall assess Damages as in other cases

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In actions of trial it wasneverthought
necessary for the plaintiff to prove all the
allegations in his declaration he need only
proveso much as shown he had cause of
action&he shall recoverpro - tanto
as he proves - In this case the answer is -
honestly - the place where& the time when the
offencescomplained of werecommitted are
Immaterial / , on the
subject of proving the facts alleged in action
of .

On the trialdeftobjected to reading same
depositions because they said no legal
naturethatgiven - they were read
& properlythis&complains for argument

BirdBird for Plff

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RalphRalph
vs
DuncanDuncan

Behalf of Plff
an
motion for N trial

BirdBird atty

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1. That unless the jury find from the evidence that
the plaintiff was held in slavery orrestrained
of his liberty by the defendent at the time of
the commencement of this writ
the plaintiff cannotrecover in this action -

given

2. That if the jury shall be of opinion that the
plaintiff is entitled to his freedom stillissue
they also find that he has been held in
slavery by the defendant since that
to freedom accrued the plaintiff can not
recover in this action - -

given

3. Unless it appear to the jury by the evidence in the
cause, that the defendant Coleman DuncanColeman Duncan
did restrain the plaintiff of his liberty on this
state the plaintiff cannot recover in this action --

refused

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That it is not necessary for the plff in this case to prove that the
defendant Coleman DuncanColeman Duncan was ever personally present in the
State of MissouriMissouri holding the plaintiff in slavery in order
to recover in this action

That if any other person than Coleman DuncanColeman Duncan held the plff
as a slave at the time of the commencement of this action
holding him for said Coleman DuncanColeman Duncan then the plaintiff
may maintain this action against saidColeman DuncanColeman Duncan

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in order that the defend

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1. If the jury from the evidence shall believe that JohnJohn Gordon
GordonJohn Gordon which he claimed plaintiff as a slave
and then hired or permitted the plaintiff to hire
himself to Labour in the state of IllinoisIllinoisprevious
to the 3rd December AD 1818 the plaintiff ought
recover his freedom

2. That the statements made by JohnJohn Gordon GordonJohn Gordon in
relation to RalphRalph being hired to labor in
IllinoisIllinoiswhichsaidGordonGordon claimed&owned
said RalphRalph as a slave are goodevidence as
against the Defendant claming under said
GordonGordon

3. That If the Jury shall believe from the evidence
that same plaintiff has been claimed as the slave
of the defendant he has with the knowledge
& assent of the defendant been hired to
labor in the state of IllinoisIllinois the Jury ought
to find a verdict for the plaintiff

4. That If the Jury shall believe from the evidence
that at any time since plaintiff has been
entitled to his freedom the Defendant has held
said plaintiff as a slave in this by himself or
any other person in this in KentuckyKentucky IllinoisIllinois or
MissouriMissouri the jury ought to find for the
plaintiff

5 That our statute which requires plaintiffs in
suits for freedom to prove their rights to freedom
amounts to nothing more than a legislative
declaration that all negros and mulattos
shall be to be slaves untill they
to the contrary.

5. That it is not necessary in this case that
the plaintiff should prove by direct & positive
evidence that eitherJohnJohn Gordon GordonJohn Gordon previous to 3rd Dec 1818 or Deftsince he claimed plaintiff
as a slave gave his consent to the plaintiff
being hired to labor in the state of IllinoisIllinois
but such consent may be inferred from

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the proof of such facts as create the connection on the minds of the Jury - that such consent was given

6. That all the plaintiff in this case is only bound to
produce the last evidence the nature of his case
admits of and such as it is in his power to produce

6. That If jury shall believe from the evidence that
plaintiff is entitled to his freedom & that Deft at &
before the commencement of this suit held him in
slavery the jury ought to assess
the plaintiff Damages to at least such sum
as plaintiff's laborwouldbeworth and the
Jury may if they are convinced that defendant
has held plaintiff as a slave proving
him to be free give Damages in addition
for the sakeofassumption

refused

7 That everyquestion asked to defendants witnesses
in regards to suits character is improperly asked
and the answer to every such improper
questionought to be entirelydisregardedby
the jury-refused- but the court states the
proper question on such point is what is the
general character of the witness for truth and
veracity on oath and that all evidence of more
general character to impeach the credibility of
the witness is incompetent.

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RalphRalph
vs
DuncanDuncan

Instructions asked
for by Plff