Mary, a woman of color, for herself and her children, Samuel, and Edward v. Launcelot H. Calvert
View original image: Page  001
[missing figure]

MaryMary a free woman
of Colour and children, Plaintiff
against Launcelot H CalvertLauncelot H Calvert , Defendant

State of MissouriMissouri
in the Circuit CourtCircuit Court
of St. LouisSt Louis[ Count ]

Plaintiff states that she is
a free woman of colour and that she is a
free person and entitled to her freedom for the
reasons herein after stated to wit
That
many years ago when she plaintiff was a
child the exact time she does not know that
she was the slave and belonged to a man
named James BowdJames Bowd in the State of KentuckyKentucky
who was her master and owner and
that her said master and owner removed from
the State of KentuckyKentucky to the State of OhioOhio and
took her the plaintiff with him and there
continued and resided permanently in
said State of OhioOhio for more than one year
keeping plaintiff in his possession at his aforesaid
residence in the State of OhioOhio and therefore
Plaintiff Claims that on account of her
said residence in the State of OhioOhio that she
is entitled to her freedom and that she is a free
person. Plaintiff states further that after
her said residence in the State of OhioOhio that
she was carried back by the said James BowdJames Bowd again to
the State of KentuckyKentucky and remained a short time
and was put in the possession of one Bryson
Stilwell who brought her to this State where she
had been but a short time when she was sold by
the aforesaid BowdBowd to one WilliamWilliam P Owsley a
negro and slave trader and dealer and she was
immediately shipped by him the said Owsley from

View original image: Page  002
[missing figure]
her residence and home at the time of sale, the
city of Hannibal in this State to the city of StSt Louis.
LouisSt Louis by & in charge of one A. I. Butler also a negro and slave
trader and dealer plaintiff being then ignorant of
her right to freedom and that she was a free person and
upon its being made known to said Butler that
the plff was a free person he sent immediately
back to Hannibal where she removed sometime
and the contract for her sale having been rescinded
as she was informed, she was again sold by said BowdBowd
to one George. W. Harris and by HarrisHarris again to said
Owsley who sold & sent her to Dr. Bonnett of St. LouisSt Louis
and since the sale to Dr. Bonnett she the plff
has been put in possession of Lynch and
Tooley & the defendant in this suit who now has
her in possession and holds her as a slave and
various other persons all negro and slave traders
and dealers and to all of whom except the deft
in this suit plff has been informed she had been
sold and pretended sales all being made with a
view as plff believes to annoy and perplex her and
thereby make her abandon her suit for freedom
against the aforesaid HarrisHarris who is since the
dead commencement of said suit dead and
the suit has been dismissed by her attorney
at Hannibal in the Court of common pleas of said city by
order of Plff where suit had been commenced
against said HarrisHarris as aforesaid and plaintiff having
no certain knowledge of who is now her pretended
owner and master brings her suit against
defendant who now holds her in possession as
a slave as aforesaid.
Plaintiff also states, that

View original image: Page  003
[missing figure]

that she has received much other bad
treatment and abuse from some of the
persons who have had her in possession
such as confinement in their negro yards
or jails and while in said yards or
jails refusing to let her all her husband &c

Plaintiff also states that she has two
children one about three years old
named SamuelSamuel and the other an infant
about six months old named EdwardEdward
both born since the time at which she was
brought to this State by the aforesaid Bryson
Stilwell which children and as she believes entitled
to freedom and are free because she was a
free person herself at the time said children were born and the aforesaid children
are now in possession of and held as
slaves by the defendant in this suit and
the plaintiff asks for her children as well
as herself the tender consideration of the
Court and that such order and proceedings
be made and had in the premises as to the Court may deem
fit and proper.
And plaintiff now asks for
herself and her said children in consideration
of their many wrongs and grievances and their
so ignorant and unprotected condition
the tender consideration of the Court and that
[ Judgement ] be had for their freedom and
that herself and children be declared free and
released from the claim or claims of all
persons whatsoever to their services of that
of others of them and that they be and are free persons
of colour.

MaryMary and children by
their counsel

RichmondRichmond Major

&

RichmondRichmond

View original image: Page  004
[missing figure]

To the Judge of the Circuit CourtCircuit Court of
St. Louis County

Your petitioners MaryMary and her
children SamuelSamuel and EdwardEdward most respectfully
state that they are free persons of colour and
now held as slaves by Launcelot H CalvertLauncelot H Calvert of
the city of St. LouisSt Louis and State of MissouriMissouri
and she MaryMary , wishes to commence suit
against said CalvertCalvert the freedom of herself
and her children and that she & they are poor persons
without any property or means of any
kind and therefore she prays the Court for
leave to sue for the freedom of herself and children as poor
persons according to the statute in such
cases provided.

MaryMary a free person of
colour for herself & children
by her

attys RichmondRichmond Major

&

RichmondRichmond

View original image: Page  004
[missing figure]

Personally appeared before me this 5th day of October 1850. J C RichmondRichmond
who being duly sworn says that the statements in the above petition are true.

JoelJoel C RichmondRichmond


Sworn to & subscribed before me
the 5th day of Nov. 1850.

A. HamiltonAlexander Hamilton Judge 8th Judicial Circuit Mo.

View original image: Page  004
[missing figure]

To the Clerk of St LouisSt Louis Co the CircuitCircuit Court
CourtCircuit Court of St. Louis County

It is hereby ordered
that the above and within named MaryMary
a woman of colour for herself and children
SamuelSamuel and EdwardEdward be allowed to sue for the freedom
of herself and her said children without giving any security
for costs and that she have reasonable liberty
to attend her counsel and the Court as occasion
may require and that she and her children be not removed out of the Jurisdiction of this Court and that
she be not subject to any severity on account
of her application or suit for freedom
Nov 5th 1850

A. HamiltonAlexander Hamilton ,

Judge &c
View original image: Page  005
[missing figure]

JoelJoel C RichmondRichmond Attorney for the Plaintiff
makes oath and says that he believes the
above and within petition and the matters
as therein stated are true.

JoelJoel C RichmondRichmond

View original image: Page  005
[missing figure]

Sworn to and subscribed before me
this 5th day of November 1850 Witness my hand
& official seal.

[missing figure]

John H. Watson, Law Commissioner
of St. Louis County

- by
PhilipPhilip

C. Mauro.

Dpt.
View original image: Page  006
[missing figure]
View original image: Page  007
[missing figure]

And that the above said woman MaryMary
and her children SamuelSamuel and EdwardEdward be brought
before me at on the day of November 1850.

View original image: Page  008
[missing figure]

MaryMary a free
woman of colour
& Children

Against

Launcelot H. Calvert

Filed 5th Nov 1850

M. S. CerreM S Cerre Clk.

View original image: Page  009
[missing figure]

1851 1 month to plead 21 p 27 One month further 21 p..
to pet . And pet filed. & answer filed 21. Apl 1852. Defendant withdraws ans & dem. 22 p 34.
Dismissed June 8th 1832. by plffs atty 22 p 2

View original image: Page  009
[missing figure]

Saint Louis Circuit CourtCircuit Court
April Term 1851

MaryMary of Color and her children
SamuelSamuel & EdwardEdward
vs
Launcelot H CalvertLauncelot H Calvert
Summons

View original image: Page  009
[missing figure]

Pet for freedom

Major & RichmondRichmond

It is ordered that the named
[ Merry ] a Woman of Color for herself
and children SamuelSamuel and EdwardEdward be allowed
to sue for the freedom of herself and
said children without giving Security for
Costs and that she have reasonable liberty
to attend her Counsel and the Court
as occasion may require and that she and her children be not
removed out of the Jurisdiction of this Court and
that she be not subject to any severity on account
of her application or suit for freedom Nov 5th 1850

A. HamiltonAlexander Hamilton Judge &c

Mast M S CerreM S Cerre Clk
Issued Nov 5th 1850
M S. CerreM S Cerre Clk

View original image: Page  009
[missing figure]

Executed this writ in the county of Saint LouisSt Louis
this 5th day of November 1850 by delivering to LancelotLancelot H Calvert
HLancelot H Calvert CalvertLancelot H Calvert a true copy of the petition and writ
and further executed this writ by offering to read the same
and the order of the judge to said defendant which he refused to hear.

Service $1 00
order 1 00
$ 2 00

HenryHenry B Belt Sheriff

By

RobtRobt Peyinghaus dpty

View original image: Page  010
[missing figure]

County of St. LouisCounty of St Louis, Ss.

The State of MissouriMissouri,

To the Sheriff of St. Louis County, Greeting:

We command you to SummonLauncelot H. Calvert
to appear
before the Judge of our circuit court on the first day of the
next term thereof to be held in the city of St. LouisSt Louis,
within and for the County of St. LouisCounty of St Louis, on the third Mon-
day of April next, then and there to answer unto
the complainant MaryMary and her children SamuelSamuel & EdwardEdward as set forth in the answered petition
And have you then there this Writ.

[missing figure]
Witness. Michael S. CerreMichael S Cerre , Clerk of said
Court with the seal thereof hereto affixed at
office in the city of St LouisSt Louis this
5th day of November in the year of our Lord eighteen hundred and fifty

M S CerreM S Cerre

Clerk.
I acknowledge myself bound for all costs that may accrue in the above cause. Witness my hand and seal at St. LouisSt Louis, this day of 18
[missing figure]
View original image: Page  011
[missing figure]
MaryMary of Color & her
children
vs
Launcelot H CalvertLauncelot H Calvert

In the Circuit CourtCircuit Court
April Term AD 1851

Defendant demurs to the petition of plaintiffs
because there is a defect of parties plaintiff
In this that the suit is brought by plaintiffs
jointly whereas they have as petition shows
no joint or common interest in each others
freedom that is to say in the cause of action
set forth in the Petition.

T. PolkT Polk P.D

View original image: Page  012
[missing figure]

C. C.Apr. T. 1851

MaryMary of color & her
children
vs
Launcelot CalvertLauncelot Calvert

Demurrer to petition

T. PolkT Polk P. D

Filed May 24th 1851

M. S. CerreM S Cerre Clk


withdrawn
View original image: Page  013
[missing figure]
MaryMary of Colour
vs
Launcelot H CalvertLauncelot H Calvert

In the Circuit CourtCircuit Court
April Term AD 1851

Defendant admits that plaintiff MaryMary
is a woman of color, but he utterly denies
that she is free or ever was free. He also denies
that the said or other of them is, or ever
was, entitled to freedom He states that he has
no knowledge sufficient to form a belief as
to whether James BowdJames Bowd ever took the said
MaryMary from the State of KentuckyKentucky to the StateOhio
of OhioOhio & there kept her for more than a year -
or as to whether she was taken back again to
KentuckyKentucky.
He admits that said slave was brought
to this State but he does not know when or by
whom.
And as to each one of the other allegations
in said petition defendant says that he
has no knowledge thereof sufficient to enable
him to form a belief.

Polk
Atty for Deft

View original image: Page  013
[missing figure]

Launcelot H. Calvert above named plaintiff,
being sworn on his oath says he believes the foregoing
petition, & the matters therein, as stated, are
true.

Lancelot H CalvertLancelot H Calvert .

Sworn to & subscribed before
me this 19th day of June 1851

PeterPeter W Johnston
Justice of the Peace

View original image: Page  014
[missing figure]

CirCircut Court .CourtCircut Court - April TermAD 1851

MaryMary of Colour
vs
Launcelot H CalvertLauncelot H Calvert

Answer of Deft

Filed June 20, 1851

M. S. CerreM S Cerre Clk


withdrawn
View original image: Page  015
[missing figure]
MaryMary (a woman of colour) plaintiff
against
Lancelot H CalvertLancelot H Calvert

In the StCircuit Court .
Louis CircuitCircuit Court
CourtCircuit Court
June

Plaintiff MaryMary by leave of the Court
amends her petition as follows viz -
By striking from the petition the names
of her two children SamuelSamuel and EdwardEdward
and presenting this suit henceforth in her own name only.

She also adds to her
petition the following

Plaintiff states that before and at the
time of the committing of the grievances
in the petition named, she was and
still is a free person, and that the
defendant held and still holds her in slavery.

MaryMary of colour by

R. F. & J C RichmondRichmond, Attys

View original image: Page  016
[missing figure]
MaryMary (woman of colour)
against
L H Calvert

Filed June 20 1851

M. S. CerreM S Cerre Clk

View original image: Page  017
[missing figure]

Depositions

Opened & filed
Oct 6. 1851

M. S. CerreM S Cerre Clk

View original image: Page  018
[missing figure]
View original image: Page  019
[missing figure]
MaryMary a woman
of colour vs
Launcelot H CalvertLauncelot H Calvert

In the Circuit CourtCircuit Court
of St Louis County
State of MissouriMissouri

To Lancelot H CalvertLancelot H Calvert
Sir

You are
hereby notified that depositions to be
read in the above entitled cause will
be taken at the office of PeterPeter Hooting Esq
in the town of FelicityFelicity county of Clermont
and state of OhioOhio on the 24th day of September next between the hours of 7 in
the forenoon and six in the afternoon
and will if necessary be continued from
day to day until completed.
St LouisSt Louis MissouriMissouriSeptember 1851

MaryMary
By her

Attorneys

R F & J.C. RichmondRichmond

View original image: Page  019
[missing figure]
View original image: Page  020
[missing figure]

Service of the within notice
to take depositions by receiving a
copy of the same, acknowledged
St LouisSt Louis Mo September 3rd 1851

T. PolkT Polk atty for Deft

View original image: Page  020
[missing figure]

Notice to take depositions in
case of
MaryMary
vsCalvertCalvert

View original image: Page  021
[missing figure]

1st
Depositions of witnesses produced
sworn and examined at the town of
FelicityFelicity in the County of ClermontCounty of Clermont
and State of OhioOhio before me George
. W. Richards a Justice of the peace
within and for the County and
State aforesaid in a certain
case now pending in the CircuitCircuit Court
CourtCircuit Court of Saint LouisSt Louis County in
the State of MissouriMissouri wherein MaryMary
a woman of color is plaintiff
and Launcelot H CalvertLauncelot H Calvert is defendant
and for said plaintiff in pursuance
of a notice hereto attached and at
the time and place therein mentioned.

P H Hastings Atty for plaintiff
and Thornton F Marshall Atty for Deft
present

James HendricksonJames Hendrickson of
the County of ClermontCounty of Clermont and State ofOhio
OhioOhio of lawful age being first duly
sworn by me as hereafter certified deposes
as follows

Question by plaintiffs Council
state what you know about a colored woman
named MaryMary who lived with one James BowdJames Bowd
in the County of Brown in the State ofOhio
OhioOhio if you know any thing about her

Answer

I did know a colored girl who lived
in Brown CountyBrown County with James BowdJames Bowd by the name
of MaryMary in the State of OhioOhio.

Question by same----State when
and how state when
and how long said MaryMary came to the StateOhio

View original image: Page  022
[missing figure]
of OhioOhio who brought her to OhioOhio who
she [ staid ] with in OhioOhio & how long she remained in said State.

Answer.

MaryMary came to the State of OhioOhio
about the year 1840 I do not know that I
could state who brought her there
She came
to OhioOhio with BowdsBowd family
She remaind in said
State between one and two years immediately
following the removing of said BowdBowd to the State of OhioOhio.

Question by same Did said MaryMary
live with and in the family of said BowdBowd
during the time [ reffered ] to above and as a servant while in OhioOhio and did
James BowdJames Bowd live in OhioOhio during the one
or two years above mentioned.

Answer.

MaryMary did live within the Family
of James BowdsJames Bowds the time above [ referd ] to
as a servant and [ don ] the work.
James BowdJames Bowd
lived in OhioOhio the one or two years above mentioned.
Question by same.

State how long James BowdJames Bowd remained in the State of OhioOhio and where
he came from when he came to OhioOhio.

Answer

James BowdJames Bowd remained in the State of OhioOhio between one and two years, came to OhioOhio
from the State of KentuckyKentucky.

Question by same ----- When you speak
of the time said MaryMary lived in the family
of said BowdBowd do you mean the time
BowdBowd lived in OhioOhio.

Answer.

I did

View original image: Page  023
[missing figure]

3rd page
Please state how old you think said
MaryMary was at the time she came with BowdBowd
to OhioOhio and what her color was

Answer

I think MaryMary was between twelve
and fourteen years old from her appearance
and size.
Her colour is what I would call
a dark copper colour not Black or yellow

Question by same - Did you ever see
said MaryMary after she left OhioOhio if so where

Answer

I seen said MaryMary afterwards at
AugustaAugusta in the state of KentuckyKentucky and in
the family of said James BowdJames Bowd .

Question by same - How long has
it been since you have seen said MaryMary last

Answer

It has been between six and seven years

The Deft atty comes and objects to the foregoing
interrogatories because they are leading and otherwise
illegal

Question by atty for Deft - Where you acquainted
with James BowdJames Bowd previous to this coming
to the State of OhioOhio, and where did he reside
immediately preceding his removal to OhioOhio?

Answer

I was not acquainted with JamesJames Bowd
BowdJames Bowd before he came to the State of OhioOhio.

I never had seen him.

By same - Where you acquainted with this
negro girl MaryMary before she came to the StateOhio
of OhioOhio, or had you ever seen her anterior
to that time, if so when?

View original image: Page  024
[missing figure]

4

Answer, I was unacquainted with the girl
and never seen her until she came
to the State of OhioOhio.

By same - Where did you reside during the
years of 1840 & 1 & 2 & what was your occupation

Answer

I resided on the farm of SamuelSamuel
Martins about a mile and half from the
Ohio RiverOhio River opposite AugustaAugusta in BrownBrown County
CountyBrown County OhioOhio.
I was farming

By same.
How did James BowdJames Bowd first come
to the state of OhioOhio - was it by steam boat or otherwise,
if by steam boat what was her name &
about what time in the day or night did
she land him in said state.

Answer

He came to the State of OhioOhio by
Steam Boat Maysville Packet down the
River between twelve and one o clock
in the day

By same - Did any person besides James BowdJames Bowd
and family get off of the boat on said occasion
and if so who.

Answer

There was several of JamesJames Bowds
BowdsJames Bowds family and some other persons
that I do not know who got off of the
boat.

By same - Do you know whether MaryMary
was brought to the State of OhioOhio at the time
above alluded to by coercion or voluntary
or how or by whom she was brought
here. Answer I do not know She
came with BowdsBowd Family BowdBowd told me
he brought her to OhioOhio-

By same - What were you doing at the steam

View original image: Page  025
[missing figure]

(5)
boat at the time referrerd to - had you business
then if so what business had you.

Answer

I has no particular business but was down there when the steam
boat came.

By same - What was the height of MaryMary
when she first landed in OhioOhio, at the
time spoken of.

Answer

MaryMary was about four feet and
and a half high when she landed

By same - When you well acquainted with
her after she came to the state of OhioOhio and did
you frequently see her during that time.

Answer

I seen her frequently

By same - What was her size when you
saw her last.
had she any blemish or marks
either upon her face or person.
Was she delicately
made or would you know her if you
would now see her.

Answer

She was perhaps a little over of five feet high.
She would weigh about one
hundred and thirty lbs.
I do not recollect
of her having any scars about her.

I think
I would know her now.

By same.
How long was it after MaryMary left
State of OhioOhio and went to AugustaAugusta Ky, was it when you
saw her last, and was she then entirely grown.
Answer
I think it was near two years She was grown
at time.

View original image: Page  026
[missing figure]

6

By same.
State as nearly as you can her
weight when you last saw her

Answer

I suppose she would have weighted
about a little over one hundred and thirty

By same
Where you in the habit of
visiting James Bowd's family or his house
after he left the state of OhioOhio & removed to
AugustaAugusta Ky.

Answer

I frequently visited his house while he lived in KentuckyKentucky

By same
Has James BowdJames Bowd any other
negroes besides MaryMary & state their names if so please state
their names.

Answer

He has one negro woman and
a child besides MaryMary the child about
eight years old
I do not recollect
the names of the woman or child

By same Was there any other negro or negroes put off of the Maysville
packed in the State of OhioOhio with James
Bowd's family at the time you have
stated that BowdBowd landed besides
MaryMary

Answer

There was one negro woman.
I do not know her name.

By same Have you had any conversation
with the counsel for the plaintiff or any other
person in relation to said negro woman
MaryMary recently, if so what was it, and have
you been shown any written questions upon
this subject.

View original image: Page  027
[missing figure]

7

Answer

I have not talked with any
person about the negro girl recently>
I have been shown the old depositions.

By same
You state you have had
no conversation recently in regard to
said negro, have you had at any time
if so when and with whom and what do you mean
by old deposition.
Are they depositions
of others taken in regard to this same
negro at some previous time

Answer

I have talked with different
persons about the negro woman have talked
with Mr. Hastings today.
The depositions referred to were the depositions
taken before about the same woman
and showed to me by Mr. Hastings the
attorney in this suit for plff.

By same You have stated
in your previous answers that you
were well acquainted with said negro
woman MaryMary and frequently visited BowdsBowd
house and family. Now please state in
what manner said negro was employed
and whether she was active, industrious
and sprightly or what her habits were.

Answer

She was employed part of the time as
a nurse part of the time in the kitchen.
She was a keen looking girl pleasant looking

View original image: Page  028
[missing figure]
(8)
with a smiling countenance She
was of tolerably industrious habits.

By same, Do you state whether she
was of was of industrious or indolent habits

Answer I suppose she was neither

I think she was of tolerable
industrious habits-

By same- was she healthy & stout or
was she delicate & frequently sick?

Answer
She was generally healthy when she was grown up she was stout & healthy

By same- You state there was another
negro woman landed in the State ofOhio OhioOhio
with BowdBowd & family at the time he BowdBowd
came to said state. Now state her size
height, color & from appearance probable age & what became of her, answer this
question from you saw & know of
your own personal knowledge
not from what others have told you
and her name:

Answer
She would have weighed about
one hundred and forty ponds she was
about five feet half or a little over her colour
was rather mulatto colour I expect she
was about twenty years old from her
appearance -

By same- How long did the last
woman live with James BowdJames Bowd -

Answer -

She lived with him about six
or eight months-

View original image: Page  029
[missing figure]

(9)

By same. How do you know where
James BowdJames Bowd came from when he
came to the state of OhioOhio at the time mentioned.

Answer

He told me they came from Louis
County KentuckyKentucky.

Witness reexamined by plaintiffs counsel

Question by Plaintiffs counsel
State if you know MaryMary a woman of
color plaintiff in this case if so where
and how long and under what
circumstances

Answer

I know one MaryMary a woman of
color lived in the family of JamesJames Bowd
BowdJames Bowd in the state of OhioOhio in Brown CountyBrown County
I do not know whether she is the
plaintiff in this case or not.
I knew her about the year 1840 - between one
and two years.
She lived in the family
of James BowdJames Bowd as a servant girl

Question by same

State what you
suppose the age of MaryMary was when
living with BowdBowd in OhioOhio and
describe her size and appearance.

Answer

From her size and appearance she was about twelve or fourteen years of
age. I think she was about four feet and a half high. Her colour was what I would
call a dark copper colour.

View original image: Page  030
[missing figure]

(10)

Question by same

When you speak of said MaryMary a colored
woman living with BowdBowd from
one to two years do you mean
the whole time she [ staid ] with BowdBowd
or only the time she was with
him in OhioOhio.

Answer

Only the time she was with him
in OhioOhio.

Question by same

Do you know of said MaryMary ,
having living with said BowdBowd after she left OhioOhio
in the state of KentuckyKentucky if so
how long and under what circumstances

Answer

I do know MaryMary lived with
James BowdJames Bowd in AugustaAugusta KentuckyKentucky about
two years after she left OhioOhio she lived with
him as a servant girl.

Question by same

Did James BowdJames Bowd take said MaryMary
with him to the state of KentuckyKentucky

Answer

Yes he took her with him to the
state of KentuckyKentucky

Question by same

how long did in what County
in the state of OhioOhio was it that
James BowdJames Bowd lived at the time you
say said MaryMary lived with him

Answer

In Brown CountyBrown County

View original image: Page  031
[missing figure]

(11)

Question by same

Where were you living
at the time said BowdBowd lived in OhioOhio

Answer

I was living on the farm of
SamuelSamuel MartinMartin about a mile and a
half from AugustaAugusta in BrownBrown County
CountyBrown County OhioOhio

Question by same

Who brought said MaryMary to the
state of OhioOhio at the time she came

Answer

I do not know who brought her
She came in the family of James BowdJames Bowd
Said BowdBowd told me he brought her
there to the state of OhioOhio

The defendant by his atty comes and
objects to all the foregoing interrogatories
propounded by plaintiffs atty because
they are not rebutting in their character,
but questions in chief.
Further this deponent saith not.

James HendricksonJames Hendrickson
Lakins depositions in the case adjourned
to 25th day of Sept 1851 at 8 o clock AM
Sept 25th 1851 met to and All
also HenryHenry B Hendrickson of ClermontClermont County
CountyClermont Countyand of lawful age being first
duly sworn as hereafter certified deposes
as follows.

Question by plaintiffs [ council ]

State if you know MaryMary a woman of
color plaintiff in this case if so when
and how long and under what circumstances

View original image: Page  032
[missing figure]

(12)

Answer

I [ new ] a [ colord ] girl by the name
of MaryMary in about ten years ago living
in the family of James BowdJames Bowd as a servant
girl in OhioOhio Brown CountyBrown County and lived
there about two years.

Question by same

State if you know who bought MaryMary to OhioOhio

Answer

She came with the family of
James BowdJames Bowd

Question by same

Had James BowdJames Bowd any other colored
persons in his family besides MaryMary
at the time said MaryMary was at said BowdsBowd
house if so how many and what were their
names

Answer

He has one colored woman
besides MaryMary I think her name was LucyLucy

Question by same

State the size age and color of
said MaryMary .

Answer

I suppose her age to be about twelve
years at the time she landed in OhioOhio. Her color dark mulatto
She was common size
at that size.

Question by same

Where did said MaryMary come from when she
came to OhioOhio and under what circumstances

Answer

She came in the family of James BowdJames Bowd by steam boat about one
o clock they landed in the day.

View original image: Page  033
[missing figure]

(13)
He James BowdJames Bowd stated they came from Lewisbergh
Lewis County KentuckyKentucky do not
the name of the Steam Boat it was the
Marysville Packet.

Question by same:
do you know what became of MaryMary - or
if she left OhioOhio, if so state all you
know about that matter

Answer

She lived in OhioOhio something near
two years.
She moved with the family of
James BowdJames Bowd to AugustaAugusta KentuckyKentucky.
I was frequently at BowdsBowd in AugustaAugusta
when she was there some year or two
after she left OhioOhio.

Question by same - What was the
color of the other colored woman at
said BowdsBowd you call LucyLucy , also state her age at the time
BowdBowd first moved to OhioOhio.

Answer-

I would call her a dark mulatto
I would suppose her to be twenty or twenty
five years old - she was of tolerably large
size at the time said BowdBowd came to
OhioOhio.

Question by same --- has James BowdJames Bowd ever said anything to you about said MaryMary if so what did he say

Answer - I do not know as he did - in particular

Question by same
Was it the two years immediately after said
BowdBowd moved to OhioOhio that said MaryMary lived with him

View original image: Page  034
[missing figure]

(14)

Answer-
It was

Question by same
Where were you living at the time you
say that said BowdBowd lived inels OhioOhio also
state what year that was

Answer
I lived on what was called
BowdsBowd hill farm Brown CountyBrown County OhioOhio
about a half mile from James BowdsJames Bowds
house - it was about the year 1840-

Question by same
do you know what finally become of
said MaryMary

Answer -
I understand from
general talk that MaryMary was sold
to some person in the State of MissouriMissouri

The Defendant by his Atty comes & excepts to the last answer of the witness as [ heresay ] &
otherwise illegal, and to all the interrogatories
of Plaintiff as illegal

Question by Defts Atty - [ Where ] you in the
habit of visiting James Bowd's home & family
during his residence in OhioOhio - and were
you well acquainted with this negro
woman MaryMary

Answer
I was in the habit of visiting them
frequently
I was well acquainted with
the girl MaryMary

By same - was she quiet & active in
her movements, of a lively & sprightly countenance

View original image: Page  035
[missing figure]

(15)

& expression of the eyes, quiet spoken or
otherwise, and had she any marks or
blemishes on her person or face that
were visible & if she had any marks or
blemishes describe them, and when you last
saw her was she healthy & stout or delicate.

Answer

I would say she was sprightly
quick in her movements lively and pleasant
countenance lively expression of the
eye quick spoken I do not recollect any
mark or blemish her appearance was
stout and healthy when I last seen her

By same - How old was she when you
last saw her?

Answer-

I would supose she was about
sixteen.

By same - Did James BowdJames Bowd come
with his family to the State of OhioOhio, when
they moved to this State; was their any other
persons besides BowdsBowd family & negroes
landed at that time, if so who were they,
and do you know that then two negroes
belonged to Bowd's family or some
other person & if you do how do you
know that fact.

Answer

He was on the boat when they
landed he came off the boat employed
hands to assist him to move - I do not
know how long he staid with his family
there was. there was a young lady by the name
of Racheal Bell no other strangers to my recollection

View original image: Page  036
[missing figure]
(16) I do not recollect any others landing - at
that time - I do not know who the
Negro belonged to that were with BowdBowd .

By same - How do you know whether MaryMary
the Plaintifff in this suit is the same negro that
lived in BowdsBowd family at the time you have
stated.
Answer this question from what you
know of your own knowledge & not from
rumor or what others have told you?

Answer

I do not.

By same - Where you present at the departure
or removal of James BowdJames Bowd from this
State to KentuckyKentucky - if so who else were present
on that occasion and did you see the
negro woman MaryMary leave with BowdBowd
at that time & how were they conveyed
across the river and by whom.
Did BowdBowd own any
other negroes in Ky either before he
came first to OhioOhio or after his removal
to that State of Ky and if he did how
many and their names & color, and
how, when and at what time did you
see MaryMary after BowdsBowd removal to Ky
was it his house or kitchen or
where.
And do you know whether said
negro came to OhioOhio voluntarily or
was she compelled.

Answer-

I was not present no further than
I seen them moving across the river I do not
recollect who else was present at that time
I did not see MaryMary this negro woman with
BowdBowd at that time.
They crossed in a ferry
flat I think.
It was himself and some
hired hands - I do not know who - BowdBowd said

View original image: Page  037
[missing figure]

(17)
he said he moved a negro man he seen off
from him he had two other negros [ wheather ]
they were known or not I do not
know, their names I do not know.
She was rather dark colour about eighteen
months after he BowdBowd removed he [ cald ]
on me to do a piece of work in AugustaAugusta
and MaryMary was still living with the
family - as usual doing the domestic
work about the house.
I dont know
wheather said MaryMary came to OhioOhio voluntarily
or not.

By same - were the two negros named
in your answer to the last question owned
by BowdBowd after he returned to Ky or before
and [ where ] they in his possession after
he returned to Ky.
Were they women
men or what?
Were they black, mullatto
copper colored or what was their color
as near as you can tell.
What work
was it that you done for BowdBowd at the
time you have alluded to & did you
board with Mr BowdBowd at the time
you were engaged in said work
if 2d
was [ their ] any person else besides you
boarding in the family at that time, or
was Miss Rachael Bell living with
said BowdBowd at the time named and
if any others living with him at the time
name them

Answer - I do not know. They were in
his possession after he removed to KentuckyKentucky
there was a woman and a small Girl - the
woman was a dark mulatto the Girl was rather
lighter

View original image: Page  038
[missing figure]
(18)
I was [ reparing ] a [ sellar ] and boarded with
Mr. BowdBowd , while I was engaged with BowdBowd
three days I think.
there was no other
person boarding in the family at that
Miss Rachael Bell was not boarding with
BowdBowd at that time no other persons
boarding with said BowdBowd at the that time.

By same - Had you not frequent
dealings with James BowdJames Bowd and
did they not terminate in an unfriendly
manner?

Answer-

I had dealings with BowdBowd frequently

we had no particular difficulty we had
frequently but nothing serious.

By same - Did you not have some
dispute or altercation with said James BowdJames Bowd
in relation to the price of a House Boat
or the manner of payment for the same
did you not state & think BowdBowd
treated you badly in regard to the
matter & did not his deportment in
relation to that affair excite
unkind feelings for him.

Answer-

We had a dispute about the price
of the boat and how it should be paid
I thought BowdBowd treated me badly it excited
bad feelings of course.

reexamined by Plaintiffs Counsel

Question by Plaintiffs Counsel
State if you are friendly
with Mr James BowdJames Bowd at the present

View original image: Page  039
[missing figure]

time and have you at present any
unkind feelings towards said BowdBowd
and have you any difficulties with
said BowdBowd at the present time unsettled

Answer-

I am friendly with James BowdJames Bowd
at the present time - our old difficulty are
all settled
I do not like said BowdBowd
I have no difficulty with BowdBowd at this
time.

Further this Deponent saith not.

HenryHenry R Hendrickson

Wm Maxwell of lawfull age being produced
sworn and examined on the part of
the plaintiff deposeth and saith

Question by Plaintiffs Council
State if you know MaryMary a woman
of color plaintiff in this case if so
when and how long and under what
circumstances also state all you
know about the matter if you know
any thing.

Answer-

I know MaryMary a woman of colour
who lived with James BowdJames Bowd but [ wheather ]
or not she is the plaintiff in this case I [ canot ]
tell Said MaryMary lived with James BowdJames Bowd
between one and two years in Brown CountyBrown County
OhioOhio about the year 1840 1 or 2 3 - or about
that time I never was much about their
house have been passing and reposing
several times and seen said MaryMary .
I suposed
her to be a servant but do not know have seen
her at work in the kitchen and nursing James BowdsJames Bowds

View original image: Page  040
[missing figure]
(20)
child.
I know nothing about how she
came there

Question by same

State what you [ supose ] the age of MaryMary
was when living with James BowdJames Bowd in
Brown CountyBrown County OhioOhio & describe her size and color
and appearance.

Answer

I supose she was from 12 to 14
years of age at that time she was darker
than a mulatto and not as dark as some
negroes.

Question by same

Did you ever see said MaryMary at any
other place than BowdsBowd house

Answer

I do not know that I did I might
have seen her crossing the river.

Question by Dfts Atty - How did you
know that the negro girl that lived with
BowdBowd at the time referred to was named
MaryMary & what was her weight.

Answer I heard the family call
her MaryMary I have heard Mr. BowdBowd call
her MaryMary .
She would weigh from 100 to 120 lbs
I think.

By same - Are you a member of what is called the abolition party in the
State of OhioOhio;

Answer

I do not know that I am
a member but I am decidedly opposed
to slavery.

By same - Have you ever voted
for an abolition candidate for Governor

View original image: Page  041
[missing figure]

(21)
of OhioOhio or for President of the United StatesUnited States, if so
when and their names

Answer

I do not think I did I voted
for Martain VanBuren in 1848 for President
The above Question and answer objected
to by plaintiffs council as being irrelevant
and illegal and otherwise informal

Question by Dfts Atty: Have you not
consulted or talked with the Atty for the
Plaintiffs in this suit as to the best course to
adopt in the taking these depositions, or
what certain individuals would depose to upon the subject and have you not
informed the Atty for Plaintiff what
questions to put to certain persons would answer and advised
him upon the subject.

Answer -

I talked some with him yesterday
but did not consult with in regard to
the best course to be taken in taking these
depositions I told him Mrs. MorrisMorris would
be a good witness in this case.
I told plaintiffs attorney to ask HenryHenry R Hendrickson one of the
witness in this suit if James BowdJames Bowd did not
eat dinner with him the other day and
if they were not now friendly.
I have not
advised him to ask any other questions.

By same - Have you & James BowdsJames Bowds
not had some difficulty & have you
no unfriendly or unkind feelings for him?

Answer

Yes he has held me at spite for two
years we did not speak I do not like his
ways but would do him no injury

View original image: Page  042
[missing figure]

(22)
Further this deponent saith not.

Wm Maxwell.

View original image: Page  042
[missing figure]

HenryHenry Wise of lawfull age being
produced sworn and examined on the
part of the plaintiff deposeth and saith

Question by plaintiffs council
State if you know a colored
woman of the name MaryMary if so
where did she live who did she live
with state the time and under
what circumstances.

Answer

I was not much acquainted
I [ new ] two colored persons one a girl
between twelve & 16 years of age the
other I think was between twenty & thirty
years old.
They lived at James BowdsJames Bowds in
Brown CountyBrown County, OhioOhio the oldest one name
I have forgotten the name of, the youngest
one name was MaryMary as I understood
I did not learn the name from JamesJames Bowd
BowdJames Bowd family - could not be positive
about the time when they were in OhioOhio.
I [ supose ] it is some ten or twelve years
since he be first seen there to this side of the
river I know but little of the circumstances
saw her working about the house
She
was a dark colour but not Black

Question by Dfts Atty - Where do you reside?
Are you not a member of what is called
the Abolition party in OhioOhio? Have you
ever voted for an abolition candidate

View original image: Page  043
[missing figure]

for Governor in OhioOhio or for President
of the United StatesUnited States if so who were they;
[ where ] you summoned to come
here as a witness or what induced
you to come.
How far do you
live from this place (FelicityFelicity )

Answer

I reside in LewisLewis Township BrownBrown County
CountyBrown County OhioOhio about four mile and a half
from FelicityFelicity OhioOhio.
I am an abolitionist
as I understand
I voted for what they
call free soilers for a number of years. I voted
for free soil candidate for Governor of
OhioOhio I voted for [ Martain ], when
he was elected president of the United StatesUnited States
I also voted for [ Martain ] VanBuren as
a free soil candidate for president in 1848.
I was not summoned to come [ hear ] I heard
that they were taking deposition in regard
to this Negro woman MaryMary in FelicityFelicity OhioOhio
I wished, if I could be of any benefit
to the Girl by telling the truth and being
forthcoming my son told me that Esq
Mc Lefurt wished me to come.
The last above question and answer excepted to by plaintiffs
Council as illegal and irrelevant
and otherwise informal.
Further this deponent saith not.

HenryHenry Wise

View original image: Page  044
[missing figure]

Opened & filedOct 6th 1851.

M. S. CerreM S Cerre Clk

View original image: Page  044
[missing figure]

I George W. Richards a Justice of the Peace in and
for the township of FranklinFranklin in the County of ClermontCounty of Clermont
and State of OhioOhio do hereby certify that the above
or within named James Hendrickson
Hendrickson William Maxwell & HenryHenry Wise
were by me first duly sworn to testify the truth
the whole truth and nothing but the truth and
that the foregoing depositions by them respectively
subscribed were reduced to writing by me
(except the first answer of HenryHenry R Hendrickson
who wrote the same himself) and were
taken at the time and place specified in the
[ inclosed ] notice In testimony whereof I have
herewith set my hand this 25th of September in the year 1851.

G W Richards, J P

View original image: Page  044
[missing figure]

Justice fees

2 subpoenas 34 Constable Simmons fees 75
25
12 3 witness fees 1.50
writing 5500 words 5.50 25
$6.21 2.50 $2.50
$8.71 Total

View original image: Page  045
[missing figure]

The State of OhioOhio, Clermont CountyClermont County

ss.

I, R. W. Clarke, Clerk of the Court of Common Pleas of said
county, certify that G. W. RichardsEsq., before whom
the foregoing Depositions were taken and acknowledged,
was, at the time of the taking and acknowledging thereof, an acting
Justice of the Peace in and for said county, duly
commissioned and qualified as such; that the same is in due form of
law, and the signature of said Justice thereto is genuine.

[missing figure]
In testimony whereof I have hereunto set
my name and affixed the seal of said Court,
the27th day of September 1851.

R. W. Clarke

Clerk.
Opened & filed Oct 6th 1851

M. S. CerreM S Cerre

Clk
View original image: Page  046
[missing figure]
View original image: Page  047
[missing figure]
MaryMary
vs
CalvertCalvert

Deposition Opened &

FiledNov. 15th, 1851

M. S. CerreM S Cerre Clk

View original image: Page  048
[missing figure]
View original image: Page  049
[missing figure]

Depositions of witnesses produced
sworn and examined at the
office of J C RichmondRichmond Esq
in the city of Saint LouisSt Louis in the
cause pending in the CircuitCircuit Court
CourtCircuit Court of Saint LouisSt Louis
County State of MissouriMissouri wherein MaryMary a woman
of color is plff in her suit
for freedom and LauncelotLauncelot H Calvert
H CalvertLauncelot H Calvert is defendant and on
the part of the plff, the notice
to take the same being
waived by Samuel T Glover
for the deft who also consents
that the taking the said
depositions may be adjourned
till tomorrow morning the 13th November at same place at 7 1/2
o'clock A.M.

S T Glover
for Deft

JoelJoel C RichmondRichmond
for Plff

View original image: Page  049
[missing figure]

James HendricksonJames Hendrickson of lawfull age being
produced, sworn and examined on the part of the
plaintiff, deposeth and saith:
he is a resident of the town of ClermontClermont County
CountyClermont County, State of OhioOhio; he knows a man
with the name of James BowdJames Bowd , he lived in
Brown CountyBrown County, State of OhioOhio, about the year
eighteen hundred and forty, said BowdBowd moved
to OhioOhio from the State of KentuckyKentucky, and brought
with him, two negroes, one a girl about &
between twelve and fourteen years of age with the
name - MaryMary ; her color was about a dark copper
color; the other was a darker color about between
twenty and twenty five years of age, so near as
he can judge - her name was LucyLucy .

The negro girl MaryMary remained in the State ofOhio

View original image: Page  050
[missing figure]

OhioOhio about two years; I deponent have seen
this same negro girl in the State of KentuckyKentucky about
the year eighteen hundred forty three or four, in Bracker
county in the town of AugusteAuguste ; she was then in
James BowdsJames Bowds family and I deponent was very
well acquainted with the negro girl when she was
living in the State of OhioOhio and in the State of KentuckyKentucky.
Said BowdsBowd moved back from the StateOhio
of OhioOhio - to the State of KentuckyKentucky to
the town of AugusteAuguste .

Deponent stated, the girl MaryMary present
he knows the girl is the same who he deponent
knewst in the State of OhioOhio and in the State ofKentucky
KentuckyKentucky and who lived in the family of said
Mr James BowdsJames Bowds ; the years in which the
girl MaryMary was taken to OhioOhio and brought
back to the State of KentuckyKentucky he could not
state positively, but, it was about the time
as he before stated.

Crossexamination by S. T. Glover for defendant

Question: how long has it has been, since you saw
the girl here present, previous to your arrival
in St LouisSt Louis this week?

answer: about seven or eight years ago.

question: Where you seen her last?

answer: in AugusteAuguste KentuckyKentucky.

question: when you seen her in KentuckyKentucky on
this occasion, how long was you with her
and seen her?

answer: it was about one year.

question: what was about a year?

answer: that I saw her in AugusteAuguste , KentuckyKentucky
the last time.

question: what was you doing in AugusteAuguste
KentuckyKentucky for about one year?

View original image: Page  051
[missing figure]

Answer: I was living on Mr. BowdsBowd farm in OhioOhio
opposite AugusteAuguste , and was doing work for Mr.
BowdsBowd by days in AugusteAuguste , KentuckyKentucky

Question: You did not live in AugusteAuguste that year?

Answer: no, my family resided in OhioOhio during
that time.

question: How many days during that year, did
you work for said BowdsBowd in AugusteAuguste ?

answer: I dont know how many, but good many.

question: can you give the number of days?

answer: if I should guess, about 60 days
or more

question: was sort of business was you employed
in during this work in KentuckyKentucky?

answer: most every kind of laboring, making
plank fences, and and

question: how do you [ recognise ] the girl MaryMary
here present?

answer: I recognize her by her looks, colour
figure, just as I would any other person
where I was acquainted with.

question: Can you give any other reason for
recognizing her?

answer: no other.

question: do you remember any marks?

answer: none

question: had you much conversation
with her?

answer: o yes, as she was passing in the
house, as any other servants.

question: when was the first time you ever
saw her?

answer: the first time I ever saw her, was
when Mr. BowdsBowd moved to the State of OhioOhio.

question: which was the darker of the two?

answer LucyLucy was the darker.

View original image: Page  052
[missing figure]

question: you observed any difference between the appearance
of the girl here present and the appearance
she had when you saw her in AugusteAuguste the last
time?

answer: I don't see very much difference in her appearance
now, more than she is now a little more fleshy.

question: she was as tall as she is now?

answer: she was about as tall as she is now.

question: was her frame as large then as it
is now?

answer: her frame was about as large then as
it is now>

question: had you much conversation with the
girl here present while you say she was in OhioOhio?

answer: not very much more, than of talking
while passing about in the house of Mr. JamesJames Bowd
BowdJames Bowd .

question: from the time you saw her last
in OhioOhio, as you say, till you saw her the last
in AugusteAuguste as you say, did you see any change
in her appearance?

answer: I saw no change in her
appearance more than she had [ growt ]
some and more heavy.

question: when you saw her last in KentuckyKentucky
in AugusteAuguste was she full grown?

answer: she was then about as tall, as she
is now, and her frame about as large, and she
is now a little more heavier and fleshier.

question: on what business did you come
to St. LouisSt Louis?

answer: I come here on the purpose to
identify this girl MaryMary present.

question: under what circumstances did you
come?

answer: I was send here for that purpose

View original image: Page  053
[missing figure]

Objection: The above question, last mentioned was
objected to in time by plaintiffs counsel here
present.

AdolphAdolph Frehr FrehrAdolph Frehr


Not. Public
View original image: Page  053
[missing figure]

question: who send you?

answer: no one particular person; it was
a kind of public concern.

Objected to this question and answer by the plaintiffs counsel.

AdolphAdolph Frehr FrehrAdolph Frehr

View original image: Page  053
[missing figure]

question: who were those persons to make up
this public concern and how was the thing
managed?

Answer: the persons was the citizens of the town
of FelicityFelicity , in the State of OhioOhio, in Clairmount
County

Objected to by plaintiffs counsel.

AdolphAdolph Frehr FrehrAdolph Frehr

View original image: Page  053
[missing figure]

Question: What had they to do with it?

answer: I dont know Sir.
Question

Objected to this question
by plaintiffs counsel.

AdolphAdolph Frehr FrehrAdolph Frehr

View original image: Page  053
[missing figure]

Question: Had they any name or the persons
who send you?

answer: I know some of them, went by
the name of abolitionists.
question

Objected to this question and
answer by plaintiffs counsel.

AdolphAdolph Frehr FrehrAdolph Frehr

View original image: Page  053
[missing figure]

Question: Were them not knowing as the anti slavery
society those persons?

answer: some of them was knowing as anti
slavery men; whether they was formed in a

View original image: Page  054
[missing figure]
society or not, he deponent cannot
say

Objected to this question and answer
by plaintiffs counsel.

AdolphAdolph Frehr FrehrAdolph Frehr

View original image: Page  054
[missing figure]

Question:

Are you a member of an antislavery society?

Answer: No Sir:

Objected to this question by pltfs
counsel.

AdolphAdolph Frehr FrehrAdolph Frehr

View original image: Page  054
[missing figure]

Question:

What arrangements was made for your coming
here? Please to state the particulars.

Answer: I cant state any particulars, all
I know, is, that money was furnished me, to pay my
expenses here.

Question: Who furnished the money?

answer: a man of name of Joseph Parrish
furnished me the money; I dont know, how
Parrish got the money.

Objected to this question by
plaintiffs counsel.

AdolphAdolph Frehr FrehrAdolph Frehr

View original image: Page  054
[missing figure]

Question:

1) How much money?

2)How did Parrish know, you were to come
to St. LouisSt Louis?

3) Was there any conversation between you
as to your testimony?

4) Were you to have any thing part your
except your expenses?

od 1. Answers: I received thirty eight Dollars
for two of us.

od 2. Answer: He told me, he me to
come, and pay my expenses, and he would
furnish me the money to pay my expenses.

View original image: Page  055
[missing figure]

od 3. Answer: No Sir, none.

od 4. Mr. Parrish told me, that he would pay me
as much money, as I could earn at home
in the same length of time.

To all this 4 questions and answers
the counsel of the plaintiff
objected.

AdolphAdolph Frehr FrehrAdolph Frehr

View original image: Page  055
[missing figure]

Question:

You were to receive pay for your time
when you get back?

Answer: I was.

Objected to this question
by plaintiffs counsel.

AdolphAdolph Frehr FrehrAdolph Frehr

View original image: Page  055
[missing figure]

Question:

Suppose that MaryMary should not obtain
her liberty in this suit, are you to be
paid for your time?

Answer: Yes Sir.

Question: Are you an abolitionist, my friend?

Answer: No Sir. I never was.

Question: Who you voted for, for the last
President?

Answer: I voted for General Cass.

Question: Who you voted for the time before?

Answer: I always voted the Democratic
Ticket

Question: Who did you vote for the last time when
Van Buren was a candidate.

Answer: I voted for Cass.

Question: Did you ever voted for Van Buren

Answer: I did, when he first was elected President

To all these questions, plaintiffs
counsel objected.

AdolphAdolph Frehr FrehrAdolph Frehr

View original image: Page  055
[missing figure]

Question: Have you been on terms of

View original image: Page  056
[missing figure]
friendship with Mr. BowdBowd ?

Answer: Mr. BowdBowd and myself is perfectly
friendly so far as I know, and always was,
since our acquaintance.

Question: You feel any interest in this suit?

answer: None at all particularly.

Adjourned by consent to two o'clock afternoon
November 13 at 2 o'clock [ a. n. ] the
same witness recalled.

Question by plaintiff: WillWill the money you receive to pay
your expenses here, be more or less,
whether MaryMary , plaintiff in this suit, gains
her freedom or not?

Answer: It will make no more or no less.

Question: is the woman MaryMary here present, plaintiff
in this suit, the same person, who lived
with James BowdJames Bowd in OhioOhio and of whom he
deponent have spoken in this testimony?

Answer: yes, she is the same woman.

Objected to this question by
defendant.

AdolphAdolph Frehr FrehrAdolph Frehr

View original image: Page  056
[missing figure]

Question by defendant: how you know that this MaryMary
is plaintiff in the suit?

Answer: I was told that this MaryMary was
plaintiff in the suit.

Question: Who told you?

Answer: Mr. RichmondRichmond told him.

And further deponent says not.

James HendricksonJames Hendrickson

Adjourned over by consent till the 14th November, at 8 o'clock in the morning.
View original image: Page  056
[missing figure]

State of MissouriMissouri
County of St. LouisCounty of St Louis

I, Adolph FrehrAdolph Frehr , Notary Public
within and for the County of St. LouisCounty of St Louis, do

View original image: Page  057
[missing figure]

hereby certify that James HendricksonJames Hendrickson , the
deponent, whose place of residence is in the town of
, Clairmont County, in the State of OhioOhio, 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 thirteenth day of November in the year eighteen hundred and fifty one, between the hours of [ eighth ] and
[ tenth ] o'clock in the forenoon, and two o'clock and four
o'clock in the afternoon at the office of JoelJoel C. Richmonds
Office in the City and County of St. LouisCounty of St Louis and StateMissouri
of MissouriMissouri.

Given and certified, the thirteenth day of November 1851.

Adolph FrehrAdolph Frehr

, Notary Public.
View original image: Page  057
[missing figure]

HenryHenry R Hendrickson of lawful age
being produced, sworn and examined on the part
of the plaintiff, deposeth and saith:

Question by plaintiff: where you reside?

answer: I live in the town of Nevill, Clairmont
County, State if OhioOhio.

question: how long have you lived there?

answer: about ten months.

question: did you ever live in any other County in the State of OhioOhio and
if so state how long and when?

answer: I did live in Brown CountyBrown County State of OhioOhio some
fifteen years.

question: state what time you lived in BrownBrown County
CountyBrown County?

answer: I did live in Brown CountyBrown County between the
years 1837 and 1850.

question: did you know James BowdJames Bowd , and if so
state when you first become acquainted with him?

answer: Yes, I know James BowdJames Bowd , and became
acquainted with him since the year eighteen
hundred and forty; and have known him since that

View original image: Page  058
[missing figure]
time.

question: where did you become acquainted with
him, at what place?

answer: in Brown CountyBrown County, State of OhioOhio.

question: do you know whereabout Mr. BowdBowd
resided before he came to the State of OhioOhio?

answer: he resided in Louisburg, Louis County
State of KentuckyKentucky.

question: do you know how long BowdBowd do you
know that James BowdJames Bowd resided in the State of OhioOhio, and if so, state how long?

answer: yes, James BowdJames Bowd did live in the StateOhio
of OhioOhio, in Brown CountyBrown County, two years.

question: where were you present, when JamesJames Bowd
BowdJames Bowd landed in the State of OhioOhio? with his family

answer: Yes I was.

question: do you know that James BowdJames Bowd brought
a family to the State of OhioOhio?

answer: Yes he did.

question: do you know that if there was any
negro family servants with Mr. BowdsBowd family?
when they landed in Brown CountyBrown County, State of OhioOhio?

answer: Yes, there was two coloured persons
a woman and a girl in James BowdsJames Bowds family

question: do you know the names of the
coloured persons spoken of?

answer: the womans name was LucyLucy , the
girls name was MaryMary .

question: what was about the age of the girl
to judge from her appearance?

answer: I suppose, something over twelve
years of age.

question: do you know the colour of the girl MaryMary ?

answer: I would call her a dark mulatto.

View original image: Page  059
[missing figure]

Question: how long did the girl MaryMary remain
in the State of OhioOhio?

answer: she remained in the family as long as
Mr. BowdBowd lived in the State of OhioOhio, near
two years.

question: were you in the employment of Mr.
James BowdJames Bowd , when he was living in OhioOhio?

answer: I did live on the farm, and tended
the farm on which Mr. BowdBowd lived, during
the time he, Mr. BowdBowd , lived in OhioOhio.

question: were you often at the house of Mr.
James BowdJames Bowd ?

answer: I was there most every day, while Mr. J
Bowd lived in OhioOhio.

question: was the girl MaryMary , living in the family
of Mr. J Bowd at the time, you deponent, lived
on the farm?

This question objected to by
defendants counsel.

Adolph FrehrAdolph Frehr

View original image: Page  059
[missing figure]

answer: Yes, she was.

question: were you well acquainted with the girl
MaryMary ?

answer: Yes, I was, I seen her every day.

question: do you know if Mr. James BowdJames Bowd moved
back to the State of KentuckyKentucky and if so, state?

answer: He moved to AugusteAuguste , State of KentuckyKentucky
Bracken County.

question: did he take the girl MaryMary with him?

answer: I saw her in the family after he lived
in AugusteAuguste .

The last question objected to
by defendants counsel.

Adolph FrehrAdolph Frehr

View original image: Page  059
[missing figure]

question: when did you see the girl MaryMary

View original image: Page  060
[missing figure]
last?

answer: the last time I saw her was about
eighteen months after Mr. James BowdJames Bowd removed
to AugusteAuguste , KentuckyKentucky - it was, so near as
I can recollect in the year eighteen hundred
forty three or eighteen hundred forty four.

question: would you know the girl MaryMary now, if
you was to see her this time?

answer: I think I would.

question: have you seen the girl MaryMary since your
arrival in St. LouisSt Louis this week?

answer: I have.

question: is the woman here present, the one who
lived with James BowdJames Bowd in the State of OhioOhio, of
whom you have been speaking, who is named MaryMary ?

answer: I think she is the same one.

This question objected to by
defendants counsel.

Adolph FrehrAdolph Frehr

View original image: Page  060
[missing figure]

question: have you any doubt about it been the
same woman?

answer: I have not.

Objected to by defendants
counsel.

Adolph FrehrAdolph Frehr

View original image: Page  060
[missing figure]

question: have you any interest in the event of this suit?

answer: I have [ non ].

Crossexamined by defendants counsel:

Question: Did you know James BowdJames Bowd before he
moved to the State of OhioOhio?

answer: I was not particularly acquainted with
him, I seen him passing back and forward to
his fathers.

question: Had you ever been in his house?

answer: I had not.

question: Had you ever seen his residence?

View original image: Page  061
[missing figure]

Answer: No Sir. I mean I never seen his residence
question: in Louis County, KentuckyKentucky.

question: how do you know he have a residence
in Louis County KentuckyKentucky?

answer: I know by good information, that he
was a merchant in that town for some years.

question: from whom did you get your good
information?

answer: from his relatives living in the State of OhioOhio.

question: have you any information whatever
except hearsay?
answer: no, only what I heard him say and others.
question: what did you hear him say?
answer: I heard him say, he moved from Louis
Withdrawn this question by defendant
Adolph FrehrAdolph Frehr

question: how far is it from here to where you
live now?

answer: about eight hundred miles.

question: have you any other business in this
country than to give testimony in this case?

answer: I have not.

question: was you brought here by any process?

Objected to this question by
plaintiffs counsel.

Adolph FrehrAdolph Frehr

View original image: Page  061
[missing figure]

answer: I was not.

question: what induced you to come here, to give
testimony in the case?

answer: partly it was to see this City and partly
give testimony on this case.

question: are you paid for coming?

answer: I expect pay, I have not received
anything.

Objected to this question by
plaintiffs counsel.

Adolph FrehrAdolph Frehr

View original image: Page  061
[missing figure]

Question: from whom do you expect pay?

answer: not of anybody particular, I look to
my brother for my pay.

question: is your brother the same man who gives
his deposition in this cause?

answer: yes, he is.

question: how much pay you expect to get?

answer: I have to get my passage back and forward
and one dollar a day for my time.

question: is no other contract but that with your
brother to receive the money?

answer: No Sir.

question: do you know whether your brother was acting for
himself or as the agent for some other party
in imploring you to come here?

answer: No Sir I dont know.

question: has not your brother told you, who he
was acting for in imploying you to come here?

answer: he has.

question: Who is it?

answer: he said, he was imployed by the peoples
in FelicityFelicity who made the money up for him.

objected to all these questions
by plaintiff's counsel

Adolph FrehrAdolph Frehr

View original image: Page  061
[missing figure]

question: Did he tell you, he was employed by
the abolitionists in FelicityFelicity or by the abolition
society or by any other society,? or association?

Objected to this question by
plaintiffs counsel.

Adolph FrehrAdolph Frehr

View original image: Page  061
[missing figure]

answer: he told him, that he was employed
by the Felicians (Phelistiaes)

question: how is the word Felicians spelled?

answer: it is spelt as it is in the Bible.

question: can you tell, whether these Phelistiaes
are an organized antislavery society?

View original image: Page  063
[missing figure]

Answer: I cant tell, I live nine miles from
that place.

Objected to these questions
by plaintiffs counsel.

Adolph FrehrAdolph Frehr .

View original image: Page  063
[missing figure]

Question: what was Marys size and when you
saw her in OhioOhio?

answer: she was always a heavy, flesh large size
for her and fleshy girl.

question: what was her size as compared with
the girl MaryMary in our present?

answer: she was much smaller.

question: have you seen this girl now present
at any other place than this office since you
come to this City?

answer: I have not, except at the door of this
office when she first got in.

question: have you ever conversed with her,
since you came here?

answer: I never spoke to her except as I said, a good
morning as I came yesterday.

question: when was the last time you saw the girl
before you saw her here.

answer: I saw her about eighteen months after
James BowdJames Bowd left the State of OhioOhio, in the year
eighteen hundred forty three or four; she was
I think about sixteen years of age.

question: [ was ] is the name of your brother, to
whom you have referred.

answer: James HendricksonJames Hendrickson .

Reexamined by plaintiffs counsel.

Question: WillWill your pay be increased or diminished
for coming here by the result of this suit of
MaryMary for freedom?

Answer: It will not according to contract.

View original image: Page  064
[missing figure]

Question: Are you to be paid any more than your
expenses and what you earn by your labor
at home, at one Dollar per day?

Answer: I am not.

question: do you not expect to get a part of the
money you receive, from plaintiffs counsel.

Objected to his question by
defendants counsel.

A Frehr

View original image: Page  064
[missing figure]

answer: my brother told me, he would get a
part of the money here in St. LouisSt Louis.

question: did MaryMary [ growt ]much as she was
living in OhioOhio with James BowdJames Bowd ?

answer: yes she [ growt ] very fast.

question: did you recognize the girl here present
as the one, named MaryMary , who lived with JamesJames Bowd
BowdJames Bowd in the State of OhioOhio, of whom you been
speaking, when you saw her first in St LouisSt Louis
this week?

Objected to this question by
defendants counsel.

Adolph FrehrAdolph Frehr

View original image: Page  064
[missing figure]

Answer: I did recognize her.

Question by defendant:

What business do you follow at home?

answer: I keep a public ferry, cross the OhioOhio River
RiverOhio River.

H R Hendrickson

View original image: Page  064
[missing figure]

State of MissouriMissouri
County of St. LouisCounty of St Louis

I Adolph FrehrAdolph Frehr Notary Public within
and for the County of St. LouisCounty of St Louis, do hereby certify
that HenryHenry R. Hendrickson the deponent whose place of residence is in the town of

View original image: Page  065
[missing figure]

Nevill, Clermont CountyClermont County, in the State ofOhio
OhioOhio, 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 fourteenth day of November in the year eighteen hundred and fifty one, between the hours
of eight and [ eleventh ] o'clock in the forenoon
at the office of JoelJoel C. RichmondRichmond in the City
and County of St. LouisCounty of St Louis and State of MissouriMissouri

Given and certified, this fourteenth day of November 1851.

[missing figure]

AdolphAdolph Frehr FrehrAdolph Frehr

Notary public.
View original image: Page  065
[missing figure]

These depositions of James HendricksonJames Hendrickson
and HenryHenry R Hendrickson
were taken by consent of S TS T Glover
GloverS T Glover for defendant JoelJoel C. RichmondRichmond
for plff.

No objection is so be taken to
authentication but all objections
are saved to the matter
of said depositions.

S T GloverS T Glover for
Glover & Campbell for Deft

JoelJoel C. RichmondRichmond
for Plff.

View original image: Page  066
[missing figure]