Polly Wash, a woman of color v. Joseph M. Magehen
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ThomasThomas
of
by him - to


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Circuit CourtCircuit Court Co.1839

St. Chambers
Petition of - - -
Polly - -

Sue on a poor person
to

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St Louis County
State of MissouriMissouri

I the undersigned
Judge of the circuit court for County of StCounty of St Louis
LouisCounty of St Louis in State of MissouriMissourito make the following
in the matter of petition by Polly WashPolly Wash to case
to sue as a poor person to her literty- to ,. that the said PollyPolly wsh be allowed to sue as as poor person
to establish her right to freedom; sue as a poor personand assign HarrisHarris as her counsel
as the - - - 2nd That the said Polly WashPolly Wash here
reasonable liberty to attend her counsel and the court as
may require, that the he not that of the jurisdiction
of this Court that he not subject to any servity on account
of her application for freedom - Witness my hand & seal this
9th day of October 1839

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To the Honorable Luke ELuke E Judge
of the Circuit Cout for County of MissouriMissouri are
the State of MissouriMissouri

The petition of Polly WashPolly Wash respectfully the following statement for the purpose
of attaining lease to the as a poor person in
the prosecution of a suit to her freedom
your petitioner that some time in the
year of 1820. on 21. She was residing in Wayne
County. KentuckyKentucky in the custody of the
slave of one JosephJoseph - that sometime
in the same the exact month not now
recollected, when she was fourteen years of age
she was removed by said her &
home as aforesaid to the state of IllinoisIllinois & resided under his charge & immediate control
at a place about four miles from the town
of Edwardsville in said state for several weeks
during which time out by her master
aforesaid to different persons to spin &
perform the usual & duties incumbent
upon a house servant at the State of two
dollars a week- That her said master regularly this amount of as the remuneration
for her services
That-
afterwords your petitioner was taken up
the missouri river & detained for about
five years- That after different & trespass
she was at last treated in the family of
the Taylor Berry) and these remained twelve
or thirteen years. during which time after
the decade of said Berry one Judge WashWash
of this County who married the widow of said
Berry as agent in the out of year
petitioner- and about four years ago was hired by said WashWash , to one
of the , as

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and in that capacity of chamber
made several trips up the IllinoisIllinois as
for as , for wages at the rate of fifteen
dollars a month & or one time within
the jurisdiction of the State of IllinoisIllinois has
detained for atleast five weeks. That she has
hired by by said WashWash for the purpose
of running up of said of IllinoisIllinois
and judge WashWash the wages
the rate of fifteen dollars a month for the
as aforesaid -
Your petitioner that she is restrained of then liberty by one who holds her
by of a sale to him by a of this County, that she is poor & her so porperty of her own on the strength of which to
pay costs of suit in presenting her claim
to freedom- She therefore prays, in as
much as the above facts can he fully establiched. That she may be permitted
to sue as a poor person in order to obtain
her freedom- her in duty found
she will

her

x

WashWash
mark
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State of MissouriMissouri
County of St. LouisCounty of St Louisss.

But remembered that on this
third day of October, eighteen hundred and thirty nine
before the .F.M.Kenny! a Justice
of the plea certain and for the county aforesaid, came
WashWash , and made oath that the facts continued
in the foregoing petition, so far as stated from her
knowledge, are true, and so far as stated from the information she belives to be true

to and subscribed
October third A.D. 1839

Benj. F.M.Kenny

Justice
her

x

WashWash
mark
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St. Louis Circuit CourtCircuit Court
November Term 1839

PollyPolly Wash WashPolly Wash
vs
JosephJoseph M MJoseph M . Vaughan

Suit of for
freedom - - -
$300.00
allowed to
sue on poor person
Clerk will
on which under the
circumstances

for

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Circuit CourtCircuit Court November Term A.D. 1849


County of St. LouisCounty of St Louis
State of MissouriMissouri

polly wash of
Color by attorney complains of
JosephJoseph M MJoseph M Mage of a plea of the for
false impresent. In that to unit on
the thirteenth day of september one thousand eight hundred and thirty nine at the county aforesaid
the said deft with force and arms an assault made
on the said plaintiff and three and these and
illtreated her the said plff and there and there unlawfully
imprisoned the said plaintiff and these
hath kept and detained her in prison from the day last
aforesaid to this day contrary to the form of the statute
in such case made and provided and the
peace and dignity of the state. And the plaintiff arms
that before and at the time of committing the said several
grievances she most and still is person that
the deft held and still hold her (the said plff) in
slavery wherefore the said plff says that she
is greatly injured damage to the
amount of five hundre dollars the

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wash
November term 1839

And the said by his attorney
the
that the plaintiff ought not to have or
her aforesaid a action thereof against him because
he says that before the said term of the
said several approved the said PollyPolly
work was still is a scan without their that before detained
she she was still is a free person
suit at the county aforesaid and this he
the said after he
prays judgement

Jn. RulandJohn Ruland


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March Term 1834.

And the said plff by her
that before at the time of
the said supposed as
of said the plff
was not she still a slave at county
aforesaid this plff puts herself upon she

for plff
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County of St. LouisCounty of St Louis, ss.


The State Of MissouriMissouri,

To the sheriff of St. Louis County-Greeting:

We command you to Summon JosephJoseph M Magehan M MagehanJoseph M Magehan
if he be found in your County, that he be
and appear
before the judge of our Circuit court, on the first day of the next term thereof, 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 third Monday of November next, then and there to answer untoPollyPolly
wash of a plea if trespass for false imprisonment
to the damage of said plaintiff of five hundred
And have you then there this writ.

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Witness, John RulandJohn Ruland . Clerk of our said Court,
with the seal thereof hereto affixed, at office, in the
City of St. LouisCity of St Louis, this ninth day of October in the year of our Lord eighteen hundred and thirty-nine.

Jn. RulandJohn Ruland

Clerk.
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I acknowledge myself bound for all costs that may accure in the above cause.

Witness my hand and seal, at St. LouisSt Louis, this day of 18

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Petitioner ordered to be by Sheriff Book 10 page 87 12 p 249
of 13 p 8514 p 67

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no 167

St louisSt Louis circuit court
november term 1839

Poly wash vs Josephm Magehan

suit for $ 500

Filed 9th 1839

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Executed this writ in the County of Saint LouisCounty of Saint Louis
by offering to read it and the declarations petition
and the order of the honorable Judge LawlessLawless to JosephJoseph Mclaughan on the
14th October 1839 all of which he refused to have

MarshallMarshall Brotherton BrothertonMarshall Brotherton
Sheriff


1.00
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County of St. LouisCounty of St Louis, ss.


The State Of MissouriMissouri,


To RobertRobert Wash WashRobert Wash
Greeting:-

You are hereby commanded, that setting aside all manner of excuse and delay, you appear
before the Judge of our Circuit CourtCircuit Court , on the eight day of april 1841 at the city of St. LouisSt Louis, then and there to
testify, and the truth to say, in a certain matter of controversy now pending in our said Court,
wherein Polly WashPolly Wash is
plantiff and Joseph M MagehanJoseph M Magehan is
defendant on the part of
and herein you are in no wise to fail.

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Witness, John RulandJohn Ruland , Clerk of our said court, with the
seal thereof hereto affixed, at office, in the City of StCity of St Louis.
LouisCity of St Louis,
this seventh day of april in the year of our Lord, one thousand eight hundred and forty one

John RulandJohn Ruland

Clerk, C.C.
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Polly WashPolly Wash
vs
J. M. Magehan

for 8th apl
for deft.

Robt WashRobert Wash

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Executed

M BrothertonM Brotherton Shff


50 cts
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Polly WashPolly Wash
vs
Joseph MJoseph M Magehan . MagehanJoseph M Magehan

In the Circuit CourtCircuit Court , for the CountyCounty of St Louis
of St.LouisCounty of St Louis, State of MissouriMissouri.


T0Joseph.M.Magehan

You Are Hereby Notified, That Depositions of Witness to be read in
evidence in the above cause, on the part of the Plaintiff, will be taken at
the house of SamuelSamuel Wood, near Troy
in the County of MadisonMadison and State ofIllinois IllinoisIllinois, on the Sixthday of April. AD. 1840, between the hours 8 o'clock in the
froenoon, and 6 o'clock in the afternoon: and that the taking of said depositions, if not completed on that day, will be continued from day to day at the same place and between
the same hours, till completed.

March 31st AD 1840

Polly WashPolly Wash

H.L.

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noticed to

J.M.


of taking
Depositions
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Served the within notice in the county of St. LouisSt Louis on the
31st day of March 1840 by delevering to Joseph MJoseph M Megahan
a true copy of the same

Marshall BrothertonMarshall Brotherton Sheriff


by


fee 50
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County Of St. LouisSt Louis, Sct.


The State Of MissouriMissouri,


To any Judge or Justice of the peace or other Judicial officer Of the
state of IllinoisIllinois
Greeting.

We, reposing special trust and confidence in your integrity and circumspection, do authorize
and require you, that you cause to come before you, such person or persons as
shall be named to you by polly wash or Harris LHarris L Sprout
Attorney or Agent, and him or them examine upon his, her or their corporal oath, (to be
by you admministered, ) 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. LouisCounty of St Louis,
wherein said polly wash is
plaintiff and one Joseph M MagehanJoseph M Magehan is
defendant on the part of the plaintiff and having
so reduced the said depositions so taken by you as aforesaid in 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, John RulandJohn Ruland , Clerk of our said CircuitCircuit Court
CourtCircuit Court at the City of St. LouisCity of St Louis, this Thirty firstday of March in the year of our Lord, one thousand eight hundred andthirtyforty.

RulandRuland

Clerk C.C.
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Deposition of witness sworn and examined at the Louse
of samuel word near troy in the county of MadisonMadison
and state of IllinoisIllinois before me samuel by a
justice of the peace within and for the county aforesaid
in a certain cause now in the Court for the County ofCounty of St Louis St. LouisCounty of St Louis state of
MissouriMissouri between Polly WashPolly Wash wash plff and
joseph a the
of the place this 6th day of april A.D. 1840 at 8 o clock in the morning between the
of lawful age being produceed
sworn and examined on the part of the plaintiff
saith that the has know the plaintiff
for a longtime the Deponent know plff in KentuckyKentucky
in the of justice token the
in their county the know her to her the same Deponent

hour long she recollects the plff was alomost ever since she plff
was born she plffbelonged to the of KentuckyKentucky
the cage of KentuckyKentucky and
was about sworn a years of age or
she was about seven or eight years of age to
armed man thier about the one
of the of plff the was living in Wayne county
in the state of KentuckyKentucky somewhere near ten
miles from the peace of the birth of plff
deponent had a sister living within a mile and
ahalf miles of the birth place of plff
and was frequently there deponent for frequently
saw the mother than plff carry the child (now

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plff I about. Deponent known PollyPolly the plaintiff
as property about these four years a
Deponent as to the number
of years about there
may have a six years or more
for one
man came on to this country the of the present County
of said her that
the self has from a fifteen
years of age. Deponent knew said
as well as she knew any neighbour said
that is JamesJames Wood & the in of Deponent
that is and with
men to be than together
- say that she saw them together
a thousand times, they new so in time -
Deponent know that it has been twenty three
years, last fall, she the husband same
came to the present County of MadisonMadison
& , - the said checklist came
the fall after, about the last of October on
the first of . Deponent would say that
was the last of October or the first of
November for to the last of her knowledge & belief -
Deponent says that said & PollyPolly remained
here in the County of MadisonMadison state of IllinoisIllinois
from the last of October or first of member until

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the last of March or the last of April
following - - - -

Nothing able to complete the taking
of said Depositionis by that the hour
( to 1 is at the moment of
& the time is not sufficient to go further
into the negotiation of matter with
the suit aforesaid I adjourn the further taking
of the same till to then to
at the same place & between the same
hours, mentioned in the annexed notice

SamuelSamuel I. .

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april seventh day, year aforesaid eigth october
in the to adjournment
sand being further unarmed say
plaintiff left illinois at the time aforesaid
it was generally reported that PollyPolly was
untitled to his freedom - & the said man
to has came
& take away the plaintiff, and has DavidDavid from of his sansWilliamWilliam
brother came away the plaintiff as
they said to, MissouriMissouri plaintiff was hered
out to Law
& to - was in the
of saying that he intended to

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plaintiff for at the death of him &
his life that she should serve bady sent
him & his cause old man that
arrived in IllinoisIllinois they and they ever
for MisouriMissouri - that they stuppid here because
they thought the was too cold for them
to pursue then journey they were bath
getting and - his family here of himself
his wife for & plaintiff he said a & battle the its about a
month thin he got a house at & stood
there -
by counsel for
you have said me bracket while he was in
IllinoisIllinois as aforesaid hered plaintiff to work
for your son Law & for
your to state have you know she
was hired - how long she was hired in what & what images she & what
to whom her images were paid
Answer - old man & told me plaintiff wa
Ring at my son in Laws to pay for land
they gate for plaintiff
at there - not have
plaintiff stand there or what images
she at as I understand from
& to pay for a track
the plaintiff - question. find the norms of
self, our in
and convey to any other person or his children
answer his propertyno. when I say he was

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failing I mean that failing in
constitution as any other drinking man does
&
plenty & property - question - how many
in his term had our
here in MadisonMadison Co.. answer
answer. Deponent does not know,
a five - said brought with him to the
of Deponent knowledge a small
him, He had about a dozen for
sincerely, said
had so or any other
cattle twagger. his team, was not in
very good but plenty good enough to enable
him to go along any where question by
- was his wife, or the at any time in IllinoisIllinois while they were here -
answer - plff was a little , but not so, to present her going along if
had wished plff was a in this
spring but very little so - question by Depts
During the time aforesaid, any losses tray away any
of answered or answer our
pours in the spring as any , but no accident

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happened him question twenty two years ago
has the present MadisonMadison county, thirty or densely
settled I mean where can stopped
and please state the names of persons who lived
near at the time.

Answer It was pretty well settled
me
my husband

a man by
the name of LeonardLeonard lived at Greggs me
me and of
same name JamesJames those
more the three miles

by how far was at from where me
this county by the
loads usually travelled to the

Answer about seventeen miles to the at St. LouisSt Louis
It was about 20 miles miles to Twenty two years ago the roads are
bad from here to St. LouisSt Louis or from here to
has your I don't know far I had these
river travelled within but I have same
to St. LouisSt Louis I was there about twenty years ago
the roads were these

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by Did your hear of any bridges being
broken at that time an those roads

Answer I do not know that they were nor did I
hear that they were

Do can you till me whether the
of 1819 twenty two years age was a mile
secure one

Answer It was a very one that that
was hire

by Do you recalled whether the
the set or command sworn after
arrival here or not

Answer Before his arrival there had been frost that
but the I think the was
laterally mild for a month after his arrival
It there became very cold and continued
through the

by Do where stapped here was
generally understood the neighbourhood
far as your know that he was bound
far missouri that he only intended to
stop here temporarily This question is to
by plaintiff

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Answer I hered have say he was bound for
messouri and this is all that I know about
I dont know what he said to
folks dont care far I am tried this
answer abjected to by plaintiff

by left here
to what place do you understand they
inteaded to

Answer I did not here them say and do not know
of wood postponed by contact of parties for the purpose
taking the of of lawful age produced
sworn the part of the plaintiff
saith That he did not know
PollyPolly the plff untill she with joseph
in the present county of madison
the plff here in the face of 1817 or
1818deposit came here about the year 1810 he said
to by that he was
to settle in missouri

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that polly the plff was hired not to his
wife for about three
nor paid for her services deponent
thinks that he services were paid for
in a the winter was a one staid here in madison county
for what reason he knows form
fall untill the last of April on the first of May in a long cabin belonging
to kept third says that
polly the plff was treated as a slage was
talked as touch by generally
as deponent
but it thinks him that he has lead the
old man say that he intended freeing
the plff when plff first came here she
was a slip of a girl apparantly between 14 or
16 years of age The place hese the county
was at the time of plaff was quite
thickly settled of dept does not pretend merely think they paid for in a
paid for her services

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in matters plantiff has had
not to Deponents wife cannot say
exactly in what way he paid for the
of the plff so much time has elasped
but know that he did pay to satisfy
for the same Deponent know that his thought
was born about the time that plaintiff came to live with him his The plff
had been living with same wood before
that

by dependent not know whether old man his at me or not
he did at my place at
the brought me has hold
such things as mourns gernally
take what things he had me I cant
say JosephJoseph were both advanced
in years he had but one hand one of his arms
was off above the his family consisted of
the girl spoken of
I have lived in IllinoisIllinois there has been more
or less the other in the month of november
The roads be between here and the are
generally had in the mississppi
the months of march and april

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was in spring of 1818 I can not say

by Deft
You have spoken of the hiring of plaintiff
to your wife pay for his hire as I think
your as arthur down does not
convey the idea intended by your I wish your
again to state all your know about this
hiring and the payment of her wagesmy wife says so

Answer of the to by plaintiff I know
she worked at my house my wife says
the paid for his in a for the
plaintiff and I have heard the plaintiff
say I may have paid him in
or other things I do not recalled but I know
was paid for her he
paid me no rent for the house I do
not recalled that I charged
for any thing or kept any amount with
him or that he even paid me any thing
the handled together and generally and
his team after said left this
settlemant say two three four or five
years he called an me at my house
this county-

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JosephJoseph I am informed and belive is
dead my understanding is that he did in
missouri thought I do not nut know this
to be a before plaintiff life illinois
I hered a report that she was intelled to
her freedom The that that was
here was a secure one and the spring was
a backward spring & the
by
you state that had
furniture in his
was this statements put down by atty
without authority or if not how do you know
the such wasn't the contents

Answer Dept merely says that he brought with Luis
a waggon the waggon when
deponent frquently used the waggon
to had some furniture
in his that sented of dept
he bought and
the only two
in the neighbourdhood of the
now know prety and
fruther deponent siath not

his

x

mark
to before
one on this 7th day of April 1840
between the hours aforesaid
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SamuelSamuel

The examination word can by
consuit of parties could have travelled
on of he had chosen he bought some
with him that not which he save
us Mr.Comkett was well could have to
polly away if he had chosen those was
nothing to him from so doing or
travilling brought the potatoes or the age of
all the way from KentuckyKentucky or the edge of that time
they considered quite an
they of an upon that quantity the were not
frogen he gave same to my husband the rest
he by the side of the so that
he could take them when he crushed
to go away the had no are accommodations
for him he did not calculate to
stay there long while that was here
there was for a man the and
almost
daily to which was the
common route

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I know the plaintiff I have not
the plaintiff since she was here that untill samething like a forthnight
age whom she come to my house I know
these I had sum her before her face was
familiar to me after talking about old times
& facts & persons I became fully convinced that
she was the same person that was here
with same twenty two years ago
she said she had came to hunt us and after talking
some time she about the Batteys & Brackets
& other neighbour & things asked Pal
where she had been al this time & why
she had come here - She said she had
come here to sue of they could say have some
she had said here & said she had an idea
of under to get her freedom I these stated to her I recollected such facts as I have
stated. & I told her I was the thing to testify to
such facts as I known here at at St. LouisSt Louis
I do not know of any persons who have
made up a to and plaintiff in her
just for freedom. Deponent never heard
a things in his life-

her

x


mark
Sworn to subscribed before me
before me this 7th day of April 1840 between the hours aforesaid

SamuelSamuel Laybold


( )
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SamuelSamuel Word of lawful age being produced
sworn examined on the part of plaintiff deposeth
& saith I first know JosephJoseph one armed man thirty nine years age last
fall he then & in by man the time of
the afterwards moved unto the border of KentuckyKentucky where he had a
& & she had the
character of an honest & truth
was a little addicted to drink when
I last knew him in he had a
girl I never knew him to
have lent our own I moved here me the fall
of 1816 - The night fall JosephJoseph
arrived at the place where I was there
in this County she came with a waggon
& horses he brought with him house hold
furniture bedding Sam Iresh of a
& he brought with home the
negro girl mow called Pally & present
I am confident she is the same she
was there as man as I can judy about
years old - She assumed here I think

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the last of autumn or the first of
November AD 1817 - she said he had sold
his plan in the appeared to he in
search of a name myself and had
been old argument - he stapped - me
for a time, the particular reasons why he did
so I do not recollect - I have no doubt
I invited him to stap and rest a while hile she could
not be well accommodated with me and therefore stop with me was only untill he could
find same more suitable place - The fall
of his arrival but in early but after this
time there were pleasant spills of weather
the winter was him he arrived here
he had came about three hundred and eighty miles from
his former residence same time after his
aarivalhe appeared to be dissatisfied that he
had sold his property
he had sold his property if he had not sold
It was my understanding that
intended to settle me but how
I got this improper I do not know
The old mans residence here was temporary
he purchased no name here nor -
remember hearing him manifest any such
intruction the brought with the him a five
battle which at

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I frequently hered old man say that
it was his intention to see the plaintiff for
at the death of himself and
me when here was between fifty and sixty years old I recollect some of the plaintiff while
here with at moons
kept his cattle - It was then in
there and funding the battle were up, the
man or not for want of food
far they had - I heard bracket say that
he did not intended to remove his stack
untill they had grown that they
could be recruited when travelling
me mr.bracket is dead us I am informed and believed
and has been dead for several years report says
he lived up the missouri about franklin when he did
the plaintiff stayed here in in IllinoisIllinois to near the
last of april 1818 - when she was taken away
as I understand to MissouriMissouri The old man here I think untill after the middle
of may I recollect the had grown
us to he sufficant to recounil battle and the
spring was quite late and backward
states further that after
here in now MadisonMadison County he remained
number of persons with waggons were to missouri These was nothing to

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from
where he chase to my
remained at my
I his waggon was not he took and such things as he wanted
by my house I this.
at the requst of ) I
had where assined removed from my
house & established a where I to
remove my house the came
an said had not term to remove my house
& I lived in the camp untill spring
Mr.bracket while here was treated as any other
neighbour that is with
here & &
where was here I talked upon him
as unsettled I heard mr.bracket say ans same
accounts he liked IllinoisIllinoiswill an same accounts
he had objections on amount of told names &
& sudden changes I much heardhim of
his trying to buy an home here I have now no
distance recollection of hearing have say where
he intended to settle while plaintiff was
here she was claimed by me as his
slave & treated as such of that in a reasonable
& indulgent way

SamuelSamuel Wood Senior


Sworn to subscribed before me
this 7th day of April . 1840
between the aforesaid

SamuelSamuel

()
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MaryMary of lawful age being produced
sworn & as a for the plaintiff
and says - some I can remember any
thing I have known me bracket be then
out the age the first that
I recalled of the plaintff who as now
present she belonged to old mr.bracket who
was then living at I came here
with my father & mother mr. & mrs.SamuelSamuel
& my husband in the fall of 1816
I have heard the of my father
& mother as above unthen read my recollections of the fails
stated by them in the general. corresponds
with thus - Mr bracket & family with the
plaintiff around here as I think the last
of october as the false of nowhere
I dont know when plaintiff left here but
I know she was here at a meeting which
I beleive took plan the last of
April - my husband moon
hered the plaintiff of mr.bracket for
a Dollar a & paid him in provision
for his stack & himself such as earn fodder I heard them matter the
she was hered first for two weeks this
was while bracket at my father after
mr.bracket moved to me she was
again hered to my husband on the some
times but how long she worked I can not
recollect - soon after

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mr.bracket arrived here he made a bargain
with my husband to his cattle I think
in number at this Dollars for
heard - he gat my husband also to
same of his houses - Mr. bracket
to be my any one to persuade his father
to to immediately for
he had no way of gang to misouri of park houses for some reasons unknown
to the and man declined giving
of the until spring & then
off on park houses with his wife
old man bracket brought with him to illinois four or five hours - this waggon was loaded
when he arrived in illinois household
furniture & as if it contained
such as mourns generally take with
them at was reloaded as
I believe I saw the waggan afterwards & empty and used in - I
bracket the old man living me Pasys -
house my husband from a
on me July 1818 - & then
me bracket moved in there my husband
left at this place barn &
to me - before
me which I
wa in may 1818 he & my husband had a
settlement in my and he paid
my husband has started into
eight Dollars & for this sum he gave
his note which has some him paid

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I understand - old me bracket then regretted
lutterly that he life - he was
then as he said about to to missouri
when I first saw him in illinois I dont
know where he intended to settle - the old man
a to at a great lap what to do
but said if he had not sold his place
he would return to I heard my
husband old mr.bracket & his son talking
about the of plaintiff
in illinois the said she would be five
according to the Laws of IllinoisIllinois if this
father kept the plaintiff there until spring
my husband advised old me mr.bracket to
the plaintiff found to him by
the old man said he would not have
her in dentured & he would keep her there
until spring of the did get fun he said
he wanted plaintiff with him for she
was kinder to him than his own children
and he intended where him & his
dead that she should be from

they spoke to the old man of another plan
to prevent her from becoming for it was
to send her to MissouriMissouri for a time
& then her that she
should not be in illinois for more than
60 days at a time - the old man refused
to adapt this plan I know of
one reason or cause which prevented

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or could prevent old man mr.bracket from
going on to MissouriMissouri or elsewhere where
he first arrived in illinois I know that
many praple were daily traveling to
me missouri which the old man remained
here -

not being able to complete the taking of said
depositions by reason of the of the house
the further taking of the same till to
then to be continued at the same place
to same hours mentioned

SamuelSamuel

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to adjournment as above stated on
this eighth day of in the your one thousand
hundred and forty between the hours of of eight in
the said six the afternoon or
the house of some the
of said as follows

on this of christ, between the Loui aforesaid
to the above port many Moone
of her testimony my says further that
appeared healthy, his wife also was also in good health &
with or either of their night have or gone whether
they thought proper I rely the plff has in the
cost of April, form the of
a meeting about the time. The plff
away by a ton of &

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left himself further Deponent saith now

MaryMary Moort


this 8th day of April 1840

SamuelSamuel

I
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The past is to the above that
and he made to the manner of certifying depositions by and in
us to the justice

G A Bind

for

H. . speak

.


plffs
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I. samuel a justice of the peace within for the
County of madison in the state of illinois to certify that
in of the
of word in the county state
word. ,
word MaryMary
and examination reduced to
& by then in the the the aforesaid in
this said depositions war

at the house of samuel word in the county of
of illinois this eigth any A.D. 1840

SamuelSamuel

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This hereby certified that on the
sixth & eigth day of April in the year of thousand hundred fourty

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is a Justice of the peace within the county of
MadisonMadison in the state of IllinoisIllinois duly
and acting as such and that face faith
and credit are due to his acts as such

In testimony whereof
brown Clerk of MadisonMadison County have subscribed my name offered the seal of office this
10th day of April in the year of the one thousand eight hundred and forty

BrownBrown
Clerk

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April 13 1840.

Jn. RulandJohn Ruland Clerk

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[missing figure]
Polly WashPolly Wash
vs
Jos: M. Magrhan

for plff

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Polly WashPolly Wash
vs
Joseph MJoseph M magrhan

Suit for freedom
in the CircuitCircuit Court
CourtCircuit Court of St. Louis
County MissouriMissouri

I Polly WashPolly Wash the defendant
in the above suit having recoverd
my freedom there by he come untitle
to recieve the money of said
suit hereby acknowledge to have
received the same in full from
the shiff hereby releasing the shriff
and also releasing Mr.HaydenHayden
who hered me at the hiring
made under the order of court
from all to me or to any
person for me

St. LouisSt LouisSept 22nd 1843


PollyPolly his

x

WashWash mark


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WashWash
vs

magrhan