George Johnson v. Reubem Bartlett
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State of MissouriMissouri
County of St LouisCounty of St Louis


To the Hon. Alexander HamiltonAlexander Hamilton
Judge of the St. Louis Circuit CourtCircuit Court


Your petitioner, George JohnsonGeorge Johnson , humbly complaining, respectfully represents to your Honor,
that he is a free man of color, and that he is now claimed and held as a slave by Mr.
ReubenReuben BartlettBartlett , in the City and County of St LouisCounty of St Louis, and state of MissouriMissouri. Your petitioner
states the following to be the grounds upon which his claim to freedom is founded;
That he was born of free colored parents, in the free city of BrownsvilleBrownsville, in the
free state of PennsylvaniaPennsylvania; and that he has remained free, to all intents and purposes,
from his birth to the present time: never having owed service or belonged to any
person whatever. Your petitioner further states, that, by reason of his said free birth,
he feels that he is entitled to his freedom; and therfore prays your Honor to
permit him to sue for the freedom of himself, as a poor person wholly and
totally unable to pay costs; and to allow him free access to his counsel and the
Court, and to prevent him from being taken out of the jurisdiction of your
Honor's Court/

Signed.

George JohnsonGeorge Johnson .
[ Deadman ] & Nelson


Attornies

for Petitioner
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George JohnsonGeorge Johnson being duly sworn, on his oath says the matters and things contained in
the foregoing petitin are true; that he is a poor person, restrained of his liberty,
and that he is wholly and totally unable to pay costs.

GeorgeGeorge his

X

mark JohnsonJohnson
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In testimory whereof I have hereunto set my
hand and affixed my official seal this 26th day of October AD 1852

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S J LeviS J Levi
Notary Public


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Filed 26th Oct 1852
M S CerreM S Cerre Clk
George JohnsonGeorge Johnson
vs
ReubenReuben BartlettBartlett

Petition to be allowed to sue as
a poor person.

[ Deadman ] & Nelson
Attornies for Petitioner.

In consideration of the fact, that said
petitioner, George JohnsonGeorge Johnson , is unable to pay
costs, it is hereby ordered by the undersigned
, sole judge of the St LouisSt Louis Cir
cuit Court, that the said petitioner, GeorgeGeorge Johnson
JohnsonGeorge Johnson , a man of color, be allowed to
sue for the freedom of himself, as a poor
person; and that he have reasonable liberty
to attend his counsel and the Court as
occasion may require; and that he be
not removed out of the jurisdiction of the
Court, and that he be not subjected to
any severity on account of his application or
suit for freedom.
Given under my hand at
ChambersChambers , this the 26th day of Oct, in the year 1852.

A. HamiltonAlexander Hamilton , Judge 8th Judicial Circuit. Mo

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George JohnsonGeorge Johnson ,
(a free man of color,)
vs
ReubenReuben BartlettBartlett

In the St Louis Circuit CourtCircuit Court .
November Term. 1852.


George JohnsonGeorge Johnson , the plaintiff in the above entitled cause, states that he is a free man
of color, and, as such, is entitled in Law and Equity, to his freedom, for the
reason that, he was borm of free colored parents, in the City of BrownsvilleBrownsville,
in the free state of PennsylvaniaPennsylvania. Said JohnsonJohnson further states that he was
born in the month of Januray, 1826, and that his said parents were, at
the time of his birth, free colored citizens, of the free state of PennsylvaniaPennsylvania
and the plaintiff further says, that, by reason of his free birth as aforesaid,
he is entitled to his freedom; and yet, notwithstanding this, the plaintiff
states that the said defendant, ReubenReuben BartlettBartlett , on the 8th day of September
last seized the plaintiff, in custody, as the lawful slave and servant of
him, the said ReubenReuben BartlettBartlett . The plaintiff further states that, before and
at the time of seizing the said plaintiff by said defendant, he was, and
still is, to all intents and purposes, a free man; and that the defendant
BartlettBartlett , then held and claimed, and now holds and claims him, the said
plaintiff, as his lawful slave: the plaintiff therefore prays the Court to grant
hims judgement of liberation, and to declare him to be a free man.

George JohnsonGeorge Johnson .


by

Deadman and NelsonNelson ,


Attornies for Plaintiff.
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George JohnsonGeorge Johnson , being duly sworn, on his oath says, that the matters and
things stated and contained in the foregoing petition are true.

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GeorgeGeorge his

X

mark JohnsonJohnson
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In the testimony whereof I have hereunto set my hand
and affixed my official seal this 26th day of OctoberAD 1852.

S J LeviS J Levi


Notary Public
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George JohnsonGeorge Johnson
vs
ReubenReuben BartlettBartlett

Petition for Freedom

Deadman & Nelson


Attornies for Petitioner
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County Of St. LouisSt Louis,

S.S.

The State Of MissouriMissouri,

To the Sheriff of St. Louis County, Greeting


We command you to summon ReubenReuben BartlettBartlett
to appear
before the Judge of our Circuit CourtCircuit Court , on the first day of the next
term thereof, to be held in 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 anwer the complaint of George JohnsonGeorge Johnson
as set forth in the annexed petition
and have you then there this writ.

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Witness, Michael S. CerreMichael S Cerre , Clerk of said
Court, with the seal thereof hereto affixed, at office, in
the City of St. LouisCity of St Louis, this Twenty Sixth day of October in the year of our Lord eighteen hundred and fifty two.

M. S. CerreM S Cerre

Clerk.
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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
185

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Executed this writ in St Louis County October 27th 1852
by delivering a certified copy of the within writ and petition
as furnished by the Clerk to the within named [ Ruben BartlettRuben ]BartlettRuben Bartlett
by reading the order of the court to him.
Fee $ 2.

Jn M Wimer Sheriff

Wm H Sparks Dept
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No. 281
Saint Louis Circuit CourtCircuit Court
November Term 1852

George JohnsonGeorge Johnson Negro
vs Summons
ReubenReuben BartlettBartlett

Pet for Freedom
Deadman & Nelson
Issued 26th October 1852
M. S. CerreM S Cerre Clk

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In consideration of the facts, that said Petitioner GeorgeGeorge Johnson
JohnsonGeorge Johnson is unable to pay costs, it is hereby ordered
by the undersigned Judge of the St LouisSt Louis Cir
cuit Court, that the said Petitioner George JohnsonGeorge Johnson
a man of Color be allowed to sue for the free
dom of himself, as a poor person, and that he
have reasonable liberty to attend his Counsel
and the Court as occasion may require; and
that he be not removed out of the Jurisdiction
of the Court, and that he be not subjected to
any severity on account of his application
for freedom, Given under my hand at chambers
this this 26th day of Oct. in the Year 1852.

A HamiltonAlexander Hamilton Judge 8th Judicial Circuit Mo
A True Copy
attest M. S. CerreM S Cerre Clk
$3 due
Copy 30 cents

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Nov. Term 1852 Demurrer filed 22 p 272
The clerk will please dismiss this suit

HenryHenry N Dedman


August 29th 1853.
Dismissed according to order

M. S. CerreM S Cerre , Clk.

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George JohnsonGeorge Johnson
a free man of color Plff
vs
Ruben BartlettRuben Bartlett Deft

In the circuit court
of St LouisSt Louis county
State of MissouriMissouri

To Ruben Bertlett the above named defendant
you are hereby notified that deposition of
witnesses to be read in evidence in the above cause on the
part of Plaintiff will be taken at the office
of the Jailer of St LouisSt Louis county in the city
of St LouisSt Louis State of MissouriMissouri on the first day of November in the year 1852 between the
hours of eight oclock in the forenoon and
six oclock 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 - This 27th day of Oct. 1852

Dedman & Nelson attys

for
Plff
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Served this notice in the County of St. LouisCounty of St Louis
on the 27th day of October A.D. 1852, by delivering
a true copy of the same to the within named ReubenReuben
BartlettBartlett .
fee 50 cts.

Jn M Winnes Sheriff


W H Sparks Dept.
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George JohnsonGeorge Johnson
vs
[ Rhuben ]BartlettBartlett

St Louis Circuit CourtCircuit Court
November Term 1852

Depositions of Witnesses produced sworn at the
Jail office in the county of Saint LouisSt Louis and StateMissouri
of MissouriMissouri before me a Notary Public in &
for the County and State of MissouriMissouri duly Commissioned
and qualified in a certain Cause now pending in
the St Louis Circuit CourtCircuit Court now pending
in the State of MissouriMissouri between George JohnsonGeorge Johnson
plaintiff and [ Rhuben ]BartlettBartlett
defendant on the part of the Plaintiff.

Willian Conley of [ Lawfull ] age produced
sworn & examined on the part of the plaintiff

Interogater - Where is your place of residence

Answer Bridgeport Fayette County
Pennsylvania

Question Do you know George JohnsonGeorge Johnson
the plaintiff to this suit

Answer Yes. I know the plaintiff
in this suit

Question How long have you known the
plaintiff

Answer I cannot say as to the length
of time but at least seven years

Question Do you know the age of the plaintiff

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Answer I do not

Quesiton When and where was the first time
and place you saw the plaintiff

Answer at BrownsvilleBrownsville Fayette County
Pennsylvania I cant say when
I first saw him
What do you mean by saying
that you cant tell the time when
you seen first saw the plaintiff

Objected to by Defendant in person

Answer I mean I do not recollect
the year month or day
I first saw the plaintiff.

Question About what time ago you first
saw the plaintiff

Answer I cant tell

Question About what age was the defandant
when you first saw him according
to his appearance

Answer To the best of my knowledge
he was about 18 or 20 years of age

Question, Do you know the parents of the plaintiff

Answer Not that I recollect of.

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Question Where is the plaintiffs place of
nativity.

Answer I do not know

Question about what time was the
plaintiff first in your employ

Answer I do not know, he [ as ] been on
boats with me for the last eight years
at different times

Question In what capacity [ di ] he serve while
on your Boat

Answer As Fireman I think he
might have been in other capacity

Question To whom did you pay the wages

Answer The clerk [ allways ] pays the

Question To whom did the clerk pay

Answer I do not know

Question What rivers did the Boat navigate
while GeorgeGeorge was in your employ

Answer I do not know what it might have
been the Cumberland OhioOhio and MississippiMississippi
they were on the western waters

Question While the plaintiff was he in
your employ did you regard
him Bond or free

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Answer Free never knew him has anything
else but a free man

Objection to the Question & Answer
by the Defendant

Cross Examination

When I first knew GeorgeGeorge
to my recollection he was near about the
size he is now I never knew him to be
whipt. I never knew him to be any other
than a free man & by general reputation
he passed as a free man in a free state
I have known him to be in a slave
state have known him to be in StSt Louis
LouisSt Louis. I cant tell how long ago I first
saw him in St LouisSt Louis I never was a
witness in any suit wherein the plaintiff
was concerned before. I never testified
before the Grand jury in this city in this
Case or in no other case.

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Wm Conley


Sworn to and subscribed before me
this 1st day of November 1852
In testimony whereof I have hereunto set
my hands & seal.

S J LeviS J Levi
Notary Publi

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WilliamWilliam H Boyd of [ Lawfull ] age
produced sworn & Examined on the part
of the plaintiff I reside in Birmingham
Alleghany County [ Pensylvania ]


Question Do you know the plaintiff to
this suit George JohnsonGeorge Johnson

Answer I do

Question How long have you known him

Answer between twelve and fourteen years

Question Where was the plaintiff when you
first saw him

Answer BrownsvilleBrownsville[ PennsylvaniaPensylvania ]

Question What was the plaintiff doing in BrownsvilleBrownsville
[ PennsylvaniaPensylvania ] when you first knew him

Answer He was working in a brick
yard with me in the Employ
with one JamesJames Auld

Question To whom was the wages paid for
his labor

Answer It was usually paid to his family
in trade or provision and so
forth I have frequently given him
orders myself

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Question When you say family do you
mean GeorgesGeorges family or his mothers
family

Objected to

Answer I mean the family he resided with
It was a colored family

Do you know any of the members
of that family besides GeorgeGeorge

Answer I do two brothers and GeorgesGeorges
mother

Question Was GeorgesGeorges mother free or slave

Answer She was free at the time I
speak [ PennsylvaniaPensylvania ] was a free
state

Question How old was GeorgeGeorge when you
first knew him

Answer I would judge him to be about
fourteen not over that

Question Is the negro George JohnsonGeorge Johnson
of whom you speak now in your
presence

Answer Yes Sir that him pointing
to the plaintiff

Question What was GeorgesGeorges mothers name

Answer I do not know

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Question Where does GeorgesGeorges brothers
live

Answer I do not know

Question Are they bond or free

I [ allways ] regarded them to be free
I do not know but I believe he [ his ]
older than one of them and older than
the other I take GeorgeGeorge from what
I know of him to be from 24 to
26 years of age

Question Do you know GeorgesGeorges place of nativity

Answer I do not

Question Do you know if GeorgeGeorge was
born in a free or slave state

Answer I do not

Question Did anyone ever claim GeorgeGeorge
as his slave during the whole period
you knew him

Answer Never to my knowledge

Question Is he slave or a free man

Answer I always known him as a free
man

Cross Examination

If you have not

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not known GeorgeGeorge more than 12 to 14
years how do you know GeorgesGeorges

Answer Because she generally looked
after him as a mother do her children
and he called her his mother and
I do not recollect of her calling him
her son I have know GeorgesGeorges mother
about 12 or 14 years I know she
was a free woman living in a free
state and no one claimed her
to my knowledge Deponent says
his age is about 26 years
resided in [ PennsylvaniaPensylvania ] from my
bush up I that my home
I seen GeorgeGeorge on a boat that I was
on running from PittsburghPittsburgh to StSt Louis
LouisSt Louis Seven Years ago
It was on
the steam boat Colorado.
He was fireman. I have been a
witness before when GeorgeGeorge was concerned
here in St LouisSt Louis I was summoned before
the Grand Jury in the July Term 1832 I have seen him off & on the
river for the last Eight years upto
two year previous I have [ mist ] him
and had not seem him until I found
him in Jail in St Louis County
I have never known him to whipped
as to have scars on him if GeorgeGeorge is
a mechanic. I do not know
I have never known him to be a
race rider The colored persons before
mentioned GeorgeGeorge and them [ allways ] called

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each other brothers George WilliamWilliam
& Isaac I dont know they
were brothers I never knew their father

Question Do you believe the institution of slavery
right or wrong

Answer I wont answer that question

Reexamination I have been mate on a boat
that GeorgeGeorge was as fireman
I do not know whom his wages
was paid to

George

WilliamWilliam J Boyd


Sworn to and subscribed before me this 1st day of November 1852 in testimony whereof I have hereunto set my
hand & seal.

S J LeviS J Levi
Notary Public

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I ReubenReuben BartlettBartlett object to the
[ hole ] Desposition on the ground that
the witness refused to answer all
or part of the questions
I hereby certify that the witness above
answered to every questions put to
them by the attorneys for Plaintiffs
and then on cross examination but one as
marked above

S J LeviS J Levi
Notary Public


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Andy B Miller of lawful age produced
sworn & examined on the part of the
plaintiff I resided at St LouisSt Louis in
the state of MissouriMissouri I am about to
leave the state in a few days on the
steam boat Honduras. I have seen
the plaintiff to this suit GeorgeGeorge Johnson
JohnsonGeorge Johnson when I first seen him
I was in BrownsvilleBrownsville in the
state of [ PennsylvaniaPensylvania ] in that as been
about Eight years ago the plaintiff
[ than ] was about eighteen years
of age> I dont know what he was
doing about that time GeorgeGeorge
was living then at that time I do
not know how long he lived in BrownsvilleBrownsville
I know his brother IsaacIsaac . I know
his brother IsaacIsaac for 16 years and I know
him to be a free man IsaacIsaac
his brother is older than GeorgeGeorge
Isacc his brother lives in this City
I do not know GeorgesGeorges mother.
When I knew him in BrownsvilleBrownsville
he was reputed to be free man
of color.

A. B. Miller


Sworn to and subscribed before me
1st day of November AD 1852
In tesitmony whereof I have hereunto
set my hand and affixed my official seal

S J LeviS J Levi
Notary Public

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State of MissouriMissouri
County of Saint LouisCounty of Saint Louis

I Solomon J Levi a Notary
Public in afore said County do hereby certify that
William Conley, WilliamWilliam H [ Boyed ] and AB Miller
the deponents whose place of residence is in BrownsvilleBrownsville
in the State of [ Pensylvania ] was by me sworn to testify
the whole truth of their knowledge touching the matter
in Controversy in the Cause aforesaid, that Deponent
was examined and their examination reduced to
writing and subscribed by said deponents in my presence
on the 1st day of November 1852 between the hours
of Eight o clock in the forenoon & six o clock in the
afternoon at the Jail office in the County ofCounty of Saint Louis
Saint LouisCounty of Saint Louis State of MissouriMissouri

Sworn & Certified this 1st day of November AD 1852 In testimony whereof I have herewith set
my hands and affixed my official seal.

S J LeviS J Levi
Notary Public

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George JohnsonGeorge Johnson
free man of Color
vs Rueben BartlettBartlett
Depositions

In the Circuit CourtCircuit Court
St. Louis County StateMissouri
of MissouriMissouri


Filed November 15, 1852

M. S. CerreM S Cerre Clk


S J LeviS J Levi

Notary fees
$10.00
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State of MissouriMissouri
Saint LouisSt Louis County
In the St. Louis Circuit CourtCircuit Court
November Term 1852

George JohnsonGeorge Johnson vsReubenReuben BartlettBartlett

Defendant de
murs to the
petition of the
Plaintiff because it does not state
facts sufficient to constitute a cause
of action in this to wit
That said Petition alleges that âthe
Defendant on the eight day of September last seized the Plaintiff and
has ever since and does now claim
and hold the said Plaintiff in cus
tody as the lawful slave and ser
vant of him the said ReubenReuben Bart
lettâ without alleging in said Petition any place
County or State where said seizure
claiming and holding of Plaintiff
by Defendant took place.

Defendant prays to be dismissed
with his costs and charges.

John Bruce Thompson
Defts Atty

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In Circuit CourtCircuit Court


281
George JohnsonGeorge Johnson
vs
ReubenReuben BartlettBartlett

Demurrer
for Deft to
Petition

John Bruce Thompson

Filed November 19 1852

M. S. CerreM S Cerre Clk

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State of MissouriMissouri
Saint LouisSt Louis County

In the St. LouisSt Louis
Court of
Circuit Court

George JohnsonGeorge Johnson a free
man of color
vs
ReubenReuben BartlettBartlett

Defendant answers that he denies the
allegation of Plaintiff that he is a free
man of color.

Defendant on the contrary
avers that Plaintiff is a slave and the
legal property of Defendant by purchase.
Defendant further saith he doth not
know where Plaintiff was born nor the
day of his birth nor who were the parents
of the Plaintiff nor has defendant any
knowledge of the place of Plaintiffs birth
or the time thereof or of his parents to
form a belief as the truth of the allegations
of Plaintiff in the above respects in said
Petition. Defendant further saith that
he admits it is believed that he Defendant
took Plaintiff about the time alleged
in Petition as his Defendants slave and
has claimed him as such ever since
and now claims him as a slave by virtue
of a purchase from one A B. McAfee
who accounted a Bill of sale of said
JohnsonJohnson to Defendant on or about the
seventh September 1852. That said
Defendant has lost said Bill of
sale and has no copy thereof but
can prove the contents of the same.
Defendant prays to be hence dis
missed with his costs and charges.

J Bruce Thompson
Defts Atty

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State of MissouriMissouri
Saint LouisSt Louis County

Personally appeared the above defend
ant and made oath that the above
answer and the matters as therein stated
are true

Sworn to before
me 8th March 1853

R Bartlett


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In Circuit CourtCircuit Court


Geo: Johnson
vs
ReubenReuben BartlettBartlett

Answer of Deft

J. Bruce Thompson


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George JohnsonGeorge Johnson
vs
ReubenReuben BartlettBartlett

In the St. Louis Circuit CourtCircuit Court
April Term 1853

Suit for the freedom of Plaintiff
Now at this day comes the Plaintiff in the above
entitled cause and moves the Court to take this
case from its Place upon its docket and set it
for Trial at an early day of the Term and in the
mean time to grant the usual order to Prevent the
Plaintiffs Being removed from the Jurisdiction of
of this Court.

James MJames M Nelson Atty


for Plaintiff
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85
JohnsonJohnson
vs
BartlettBartlett

Motion to set the case earlier
in term

Filed April 29th 1853

M. S. CerreM S Cerre Clk


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George JohnsonGeorge Johnson Plff
vs
[ Ruben BartlettRuben ]BartlettRuben Bartlett Deft

In the Circuit CourtCircuit Court
of St. Louis County
November Term 1852

To [ Ruben BartlettRuben ]BartlettRuben Bartlett the above named
defendant. Sir, you are hereby notified
that depositions of witnesses to be read in
evidence in the above cause on the part of
the Plff will be taken at the office of the
Garter of St. Louis County in St. Louis County
State of MissouriMissouri on the fifteenth day of December 1852 between the hours of 8 oclk
in the forenoon & 6 oclk 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 &
between the same hours till completed.

This the 10th day of Dec 1852

George JohnsonGeorge Johnson by
NelsonNelson his Atty

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George JohnsonGeorge Johnson
vs
[ Ruben BartlettRuben ]BartlettRuben Bartlett

Notice to take depositions

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Served this notice in the County of Saint LouisCounty of Saint Louis, December 10th 1852, by delivering to ReubenReuben BartlettBartlett , the within named
defendant, a true copy of this notice.
Fee - 50

John MJohn M Wimer Sheriff


By W S Chadbourne Deputy

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Depositions of witnesses produced, sworn
and examined pursuant to the annexed
notice, at the office of the Jailor of St.
Louis County, in St. Louis County, State ofMissouri
MissouriMissouri, before me, SamuelSamuel A. Bennett
a Notary Public within and for said county
to be read in evidence in a certain cause
now pending in the Circuit CourtCircuit Court of St.
Louis County, in said state, wherein GeorgeGeorge Johnson
JohnsonGeorge Johnson is plaintiff and ReubenReuben
BartlettBartlett is defendant on behalf of the
plaintiff.

Job V. Kimber, of lawful age, being produ
ced, sworn and examined on behalf of
the plaintiff, deposeth and saith:-

"I reside in Pekin, IllinoisIllinois.
I have lived in BrownsvilleBrownsville PennsylvaniaPennsylvania. That
was my home until three weeks since.

Ques: Do you know George JohnsonGeorge Johnson
the plaintiff in this suit?

Ans: I do know him.

Ques: How long have you known him?

Ans: I can't just state the number of
years I have known him. He worked
for me as fireman on a steamboat
some six years ago. I knew him before that.
I am an engineer. Plaintiff has been
on boats with me since that time.

Ques: Where did you get acquainted
with plaintiff?

Ans: I think

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it was in BrownsvilleBrownsville PennsylvaniaPennsylvania.

Ques: Did he hire himself to you
as fireman?

Ans: He did.

Ques: Who paid him his wages?

Ans: The Clerk of the Boat

Ques: Were his wages paid to
himself?

Ans: Yes.

Ques: Do you recollect what boat
it was & where she ran to?

Ans: The boat that he was on six
years ago was the Colorado, which
ran between St. LouisSt Louis & PittsburghPittsburgh.
Afterwards I knew him on the DanubeDanube
which ran at that time from Cincinnati
to PittsburghPittsburgh

Ques: Was plaintiff at that time
a free man or a slave?

Ans: My impression was that
he was a free man because
he acted for himself. That is my only
reason for thinking so. He lived in
the town where I was born & raised
in a free State.

Ques: Was he known as a free man?

Ans: I dont know whether other
people thought he was a free man
or a slave. I thought he was a free man
Further this deponent saith not.

Job V. Kimber.

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R. Bartlett, Deft appears but
declines to cross examine the
witness

I, SamuelSamuel A. Bennett, a Notary Public within
and for the County of St. LouisCounty of St Louis in the State of MissouriMissouri,
do hereby certify that Job V. Kimber, the
deponent, who resided in Pekin, IllinoisIllinois, was
by me sworn to testify the whole truth of his
knowledge touching the matters in controversy in the
cause aforesaid: that said deponent was examined
& his examination reduced to writing by me and
subscribed by said deponent in my presence, at the
office of the Jailer of St. Louis County, in St.
Louis County, State of MissouriMissouri, on the fifteenth day of December 1852, between the hours of
eight o'clock in the forenoon and six o'clock
in the afternoon: and his said deposition
together with the notice is herewith returned.

In Testimony whereof, I hereto set
my hand & affix my notarial seal
the day and year last aforesaid.

SamuelSamuel A. Bennett


Notary Public
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George W Kimber, of lawful age, being
produced, sworn and examined on behalf
of the plaintiff deposeth and saith:-
"I reside in BrownsvilleBrownsville, PennsylvaniaPennsylvania.

Ques: Do you know George JohnsonGeorge Johnson the
plaintiff in this suit?

Ans: I do.

Ques: How long have you known him?

Ans: I dont know exactly. I knew him
some time, before he went on the DanubeDanube

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I must have known him a year before
that time.
I I knew ran on the
DanubeDanube at the same time my brother
Job V. Kimber did. Plaintiff was hired
as fireman on the boat by my brother.

Ques: Where did you first know
plaintiff?

Ans: I first knew plaintiff in
BrownsvilleBrownsville PennsylvaniaPennsylvania. He was
tolerably small then - considerably smaller
than he is now.

Ques: Are you & plaintiff near of
one age?

Ans: I think we are.

Ques: Did you know him when you
and he were both boys?

Ans: I did, and we played together
many a time.

Ques: What is your present age?

Ans: I shall be twenty three years
old in March next.

Ques: Did you understand plaintiff
to be a freee man or a slave, when you
knew him in BrownsvilleBrownsville?

Ans: I was always under the impression
that he was free of course.

Ques: How old were you when you
first knew & played ball with plaintiff?

Ans: I could not have been over
twelve years old I reckon. We played
ball together.

Ques: Was plaintiff raised in BrownsvilleBrownsville
PennsylvaniaPennsylvania?

Ans: I think he was. I was always

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under the impression that he was born
and raised in that town.

Ques: Did you intend to state in
addition to saying that you had known
him more than a year before he went
on the DanubeDanube with your brother and
yourself, that you had known him and
played with him in boyhood?

(Objected to by Defendant,
because Plff counsel asked him
the question to reconcile discrepancies
in the testimony.)

Ans: I did intend to say so, and
was going on to state it but I was
interrupted.

Cross Examined by Defendant.

Ques: What is the difference between
the age of yourself & your brother as
near as I can tell?

Ans: I dont know, but I suppose
he is four or five years older than myself
at least.

Ques: How long is it since your brother
moved to Pekin IllinoisIllinois?

Ans: I dont know

Ques: Has it been six months

Ans: No, it is not two months
since he left home.

Ques: Where did your brother
live at the time you speak of knowing
plaintiff in BrownsvilleBrownsville, PennsylvaniaPennsylvania?

Ans: He lived in BrownsvilleBrownsville.

Ques: Did your brother know plaintiff

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at the time you speak of playing
with him in BrownsvilleBrownsville?

(Objected to by Plff counsel as
irrelevant)

Ans: I dont know whether
he did or not.

Ques: Did your brother live in the
same family with you & play with
you at that time?

(Objected to by Plff as irrelevant.)

Ans: No, he did not play with me,
but he lived in the same family.

Ques: Was your brother raised in
BrownsvilleBrownsville?

(Objected to as irrelevant)

Ans: Yes, I think so. My mother
used to say he was.

Ques: How long or about how long
is it since plaintiff was employed on the
DanubeDanube?

Ans: I reckon it has been five
or six years. I cant recollect exactly

Ques: Were your brothers chances
opportunities as good to have known
plaintiff as your own at the time
you speak of having played with him
in BrownsvilleBrownsville?

(Objected to by Plff as irrelevant)

Ans: No sir I think not, because
when my brother was not at work, he
was reading, and I was a boy playing
around town.

I was second engineer on the

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Steamer DanubeDanube when plaintiff was employed
on her. Plaintiff was fireman.

Ques: Is th Do you believe that the
institution of slavery is right or wrong?

(Objected to as irrelevant)

Ans: I never studied the subject
enough to form an opinion. I dont
know anything about it.

Ques: What did plaintiff follow
in BrownsvilleBrownsville before he went on a boat

Ans: I don't know.

I don't know how old plaintiff was
when he went on a boat as fireman

Further this deponent saith not.

George W. Kimber

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I, SamuelSamuel A. Bennet, a Notary Public
within and for the County of St. LouisCounty of St Louis
in the State of MissouriMissouri, do hereby certify
that George W. Kimber, the deponent, who
resides in BrownsvilleBrownsville PennsylvaniaPennsylvania was
by me sworn to testify the whole truth of his
knowledge touching the matters in controversy
in the cause aforesaid: that said deponent
was examined, and his examination reduced
to writing by me and subscribed by said
deponent in my presence, at the office of the
Jailer of St. Louis County, in St. Louis County
State of MissouriMissouri, on the fifteenth day of December 1852, between the hours of eight
o'clock in the forenoon and six o'clock in
the afternoon: and his said deposition together

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[missing figure]
with the notice is herewith returned.

In Testimony whereof, I hereto set my
hands & affix my notarial seal, the day
and year last aforesaid.

SamuelSamuel A. Bennett


Notary Public

St. Louis County Mo

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[missing figure]
George JohnsonGeorge Johnson vs
ReubenReuben BartlettBartlett

Circuit CourtCircuit Court

Depositions for
Plff.

Opened & filed August 22nd 1853

M. S. CerreM S Cerre Clk


Fees $3.00 pd by Nobody