To Luke E . Judge of the St. Louis Circuit
Count

The Petition of Delph , alias Delphy a colored
person represents that she was formerly the
slave of Josiah, Ramsey, and was possessed and
owned, by him as his slave to the fourth
day of May in the year of our Lord one thousand
eight hundred and twenty six, at which time,
said Ramsay , then a citizen & resident, of
the state of Missouri , actually living in Callaway , County , made & executed, in due
form of law his deed, of emancipation, of
your petitioner, wherein he declared her free
to which deed, there were two subscribing witnesses
who proved, the same in due, form in
the Circuit Court of Callaway , County
on the twelfth, of November in the year
eighteen hundred, twenty seven, which
County the same deed was duly recorded,
in the Clerks office of said Circuit Court
of Callaway County , by which deed your
petitioner became free, & immediately after
its execution went free, & has in fact gone
at large, & acted, as a free person ever, since
and she, further says that one Stephen ,
Dorris claims her now, as a slave, having
very, recently set up such claim and
has seized, her and attempted by force to carry her away,
from St. Louis a here she now resides &
is now attempting the same thing. Where

fore, she prays, for leave, to sue, in the
St. Louis Circuit Court as a poor person,
in order, to establish her said right, to freedom

Delph ,

St. Louis County SS,: Delph , a colored woman,
being sworn on her oath, says that the above
petition is true,

Delph , her X march
Sworn to & subscribed
before me this 6th July
1836 P..

St. Louis County
at Chambers :July 6th 1836

It is hereby ordered that
Delph the petitioner above, be permitted to sue,
as a poor person in the St , Louis Circuit
Court to establish her right to freedom
& Josiah Spading, is hereby assigned as her
counsel. It is also further, ordered that the
said, Delph have reasonable liberty to attend,
her counsel and the Court as occasion
may require,: and that she be, not removed,
out of the jurisdiction, of the Court, and
that she be, not subject to any severity on,

on account of her, application for freedom 6th July 1836

St. Louis Circuit Court for November Term 1836

County of St. Louis SS,. Delph
permitted to sue, for freedom, by J Spalding her, attorney
assigned by Court, complains of Stephen ,
Dorris of a plea of trespass,, for that the said
Dorris on the first day of July in the year of
our Lord one thousand eight hundred thirty six
at said County, with force and
arms &C. made an assault, upon the said
Delph & her the said Delph , then & there
wounded, burised,, beat & ill- treated,, &
with force pulled, & dragged, about & then &
there imprisoned the said Delph & detained
her in prison there for a long space of time
to wit hitherto, & restrained, her of her,
liberty, against the will of the said Delph
whereby the said plaintiff was greatly hurt
bruised,, & injured; and the plaintiff that

before and at the time of the committing,
said grievances,, that she was & still is a
free person & that the defendant held
and still holds her the plaintiff in slave
ry,, wherefore she saith that she is grieved,
and hath sustained damages to the amount
of five hundred dollars & therefore she
sues, &C.

J ,. Spalding atty, for plff

St. Louis Circuit Court

petition & claim,

Issue summon or
within order

Filed 6th July 1836
John Ruland Clerk

County of Saint Louis - SS,The State of Missouri To The Sheriff of the county of Saint Louis - Greeting:

We command you to summon Stephen Dorris if he be found in your county
that he be and appear before the judge of our circuit court on the first day of
the term thereof to be begun and held at the city of Saint Louis , within & for the county aforesaid, on the second Monday of November next, then and
there to answer unto Delph , a mulattress, of a plea of trespass, to the damage
of said plaintiff of five hundred dollars and have you then there this writ.

Witness John Ruland Clerk of our said court with,
the seal thereof hereto affixed, at office in the City
of St. Louis this sixth day of July, in the year of
our Lord eighteen hundred and thirty six. John Ruland Clerk
By Dpty,
J,. D. Johnston

Executed this writ by reading it together with
the declaration & petition and also the order made,
by the honorable Judge to Stephen Dorris on the
6th Day of July 1836 in the county of St. Louis

Service $1.00
James Brotherton Sheriff
by Louis

No 4
St. Louis Circuit Court
November Term 1836

summons

Filed 6th July 1836 John Ruland Clerk

November term, 1836.

And, the said defendant, by his, attorney
comes, & defends the force & injury, when & says,
that he is guilty, - of the said supposed trespass,
above said, to chare or any part, thereof, in
manner & form as the said plaintiff hath above
thereof complained against him
himself upon, the county

This pleas is withdrawn-book9-page 51

Gamble & Allen attys for d,

No 4
November term 1836

plea not guilty,
Gamble & Allen,.

Filed 22nd Nov. 1836 John Ruland Clerk

County of St. Louis ,sct.State Of Missouri ,To the Sheriff of St. Louis County-Greeting.

You are hereby commanded to summon William Lucas
that setting aside all manner of excuse and delay, he be and appear in proper person
before the Judge of our Circuit Court , on the fourth of April,
next at the city of St. Louis , then and there to Testify,
and the truth to say, in a certain matter of controversy now pending in our said Court,
wherein
Delph is plaintiff and Dorris is,
defendant on the part of the
plaintiff and have you then and there this writ.

Witness, John Ruland , Clerk of our said Circuit Court , at the
City of St. Louis , this 14 day of March
in the year of our Lord one thousand eight hundred and thirty-seven John Ruland Clerk, C.C.

Executed this writ By reading it
to Wlmm Lucas March 14th 1837 in
the county of St. Louis ,

James , Brotherton shff,
By J Gordon D Shff, Service $ - 50

March Term 1837.

Subp, for
Wm Lucas , 14
for plff

action, in Circuit Court
of St Louis, County

Take notice, that on the twentieth day of March
in the year of our Lord one thousand eight hundred and thirty-seven, between
the hours of six in the forenoon and six in the
afternoon, of that day, at the post office, in the City of Jefferson , Missouri ,
depositions will be taken by the undersigned, to be read on the trial of the above
entitled case, on behalf of the defendant; 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, until completed.

To the above named plaintiff
3rd March 1837S. Dorris deft by, his attos,B.

Served, this notice by delivering a true
copy thereof to the within named Delph
on the 3rd day of March 1837 in the county
of St. Louis

James Brotherton Sheriff By M Brotherton D Shff, Service 50 cts,

depositions, of witnesses produced sworn, & examined
on, the twentieth day of March in the year of our Lord
one thousand eight hundred and thirty seven between the
hours of six O'clock in the forenoon and six O'clock
in the afternoon of that day at the Post office in the city
of Jefferson , in the State of Missouri before, me George
W ,. Miller a Justice of the peace within, and for the County
of Cole , in a certain cause now depending in the Circuit
Court of St.Louis County in said State between Delph , plaintiff
and Stephen C. Dorris, defendant on the part of the Defendant.

The examination of witnesses, continued
until tomorrow morning between the hours aforesaid

Tuesday 21st March 1837.
Beverley, A. Ramsay, of lawful age, being produced
sworn and examined on the part of the Defendant
Deposith and saith

That Delf a mulatto, girl now
about 32 years of age was born a slave for life, the
property of Josiah, Ramsay Senior Late of Callaway
County in this State,- that said Josiah , Ramsay by
deed of Sale conveyed, said Delf to Jonathan , Ramsay
by said Delf was afterwards conveyed to
Stephen C. Dorris now of said County of Callaway -
That said Josiah , Ramsay never at any time
owned any other Slave of the name of Delf
and that said Delf has been seen by this deponant in the City of St.Louis where she now resides-

This deponant further Saith, That he, knew one
Thomas Patterson who was a subscribing, witness
to the deed by which said Josiah , Ramsay Conveyed
the said Delf with, other property to the said Jonathan ,
Ramsay - That said Patterson removed from, the State of Kentucky , to the territory

now State of Arkansas ,, and that some years ago
it was currently reported and has ever since, been
believed by his Connections in the State of Missouri
that said Patterson is dead- and this deponent
Saith that said Josiah , Ramsay died in the County of Callaway in the month of September
in the year Eighteen hundred and thirty four.

B. A. Ramsay
subscribed, and sworn to before,
me a justice of the peace within and
for the County of Cole - State
of Missouri , on this 21st Mar on 1837

GW. Miller Justice
Robert H. Jones of lawful age being also produced
sworn and examined on the part of the defendant
deposith and Saith-

That in the month of May in the
year Eighteen hundred and thirty five he attended
to the taking of depositions in the Territory of Arkansas ,
in a certain suit depending between the former Slaves of Josiah, Ramsay Senior Late of Callaway County
plaintiff and Jonathan , Ramsay defendant- That he took the depositions of Ambrose Huggins, and
his wife, who both Stated on oath, that the wife, of
Said Huggins was the daughter of Thomas Patterson
who was a subscribing witness to a deed of conveyance
of certain Slaves from said Josiah , to said
Jonathan , Ramsay &,. That said Patterson died at
the house of said Huggins in the Territory now State
of Arkansas ,- That depponent knew Delf a mulatto girl
slave the property of said Josiah , Ramsay and the he never knew any other slave of the same name
belonging to the said Josiah , Ramsay - That said Josiah , Ramsay died some years ago in said
Callaway County .-

Subscribed, and sworn to
before me a justice of The Peace
Witness and for the County of Cole,
& State of Missouri on this 21 March 1837 GW Miller,
Robert H. Jones

St.
Justice,

I George M. Miller a justice of the peace within
and for the County of Cole in the State of Missouri
do hereby certify that B.A Ramsay and Robert
H. Jones the deponent were, by me severally
sworn to testify the whole truth of their knowledge, touching the Controversy aforesaid
that they were examined and their examination
reduced to writing, and by them respectively, in my presence
on the day between the hours and at the place
in that behalf, aforesaid

GW,. Miller
Justice of the Peace

Deposition for Defendant

Opened & filed 27th March 1837 John Ruland clerk Deposition excluded
for irregularity

County of St. Louis ,sct.State Of Missouri ,To the Sheriff of St. Louis County- Greeting.

You are hereby commanded to summon William Lucas
that setting aside all manner of excuse and delay, he be and appear in proper person
before the Judge of our Circuit Court , on the 4th of april instant
at the city of St. Louis , then and there to Testify,
and the truth to say, in a certain matter of controversy now pending in our said Court,
Wherein Delph is
plaintiff and Stephen C. Dorris is
defendant on the part of the, defendant
and have you then and there this writ.

Witness, John Ruland , Clerk of our said Circuit Court , at the
City of St.Louis , this first day of April
in the year of our Lord, one thousand eight hundred and thirty-7 John Ruland Clerk, C.C.

March Term 1837 est,

sum William Lucas deft, 4th

Executed this writ on William Lucas on the 1 day
of april 1837 by reading it to him in the
County of St. Louis

James Brotherton Sheriff
By B.F. Clark D Shff, service, 50

Action in Circuit Court of
St.Louis County.

Take notice, that on the sixteenth day of March
in the year of our Lord one thousand eight hundred and thirty seven, between
the hours of six in the forenoon and six in the
afternoon, of that day, at the Court House in the town of
County, State of Kentucky , depositions will be taken by the undersigned, to be read on the trial of the above
entitiled case, on behalf of the defendant; 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, until completed.

Stephen Dorriss by his
attos,B. Allen, To the above named Delph
plff,
St.Louis 3rd March 1837

Served this notice by delivering a true
copy thereof to the within named Delph
on the 3rd day of March 1837 in the
County of St. Louis

James Brotherton Shff,
By M , Brotherton D Shff, service, 50th

County Of St. Louis ,Sct.The State Of Missouri ,To any Judge of Justice of the Peace or, other judicial officer of the State of Kentucky
Greeting:

We, reposing special trust and confidence in your integrity and circumspection, do authorize
and require you, that you cause to come before you, such person or persons as shall
be named to you by Stephen Dorris & Delph of them
his or her
Attorney or Agent, and him or them examine upon his, her or their corporal oath, (to be by you administered,) now pending in our Circuit Court , for the county of St. Louis , wherein Delph is plaintiff and Stephen Dorris is defendant on the part of the Defendant and having so reduced
the said depositions so taken by you as aforesaid in writing, you are required to send the
same, together with this commission, enclosed under, your seal, to our said Circuit Court ,
with all convenient speed.

Witness, John Ruland , Clerk of our said Circuit
Court , at the City of St.Louis , this third
day of March in the year of our Lord, one
thousand eight hundred and thirty seven.Johan Ruland Clerk C.C.

Commonwealth of Kentucky , Livingston County

Depositions, of witnesses produced sworn, and examined at
the court in the town of Salem, Livingston County state of
Kentucky , before me Christopher Haynes, an acting Justice
of the peace in and for the county of Livingston state of
Kentucky ,, In a certain cause now depending, in the circuit
court in the county of St Louis and state of Missouri
between Delph a woman of Coulor, plaintiff & Stephen
C Dorriss defendant on the part of the defendant

David Brown of lawfull age being produced
sworn and examined on the part of the defendant
deposeth, and saith. That, he was well acquainted,
with Thomas Patterson , in the years 1806. 7 & 8 in
this County that he has often soon him write
and that he was well acquainted, with his signature, and verily believes, and has no doubt,
that the signature, of the said Thomas , Patterson
signed to a paper as a witness, now shown to be a bill of sale, from Josiah
Ramsay to Jonathan , Ramsay for certain negroes,
is the proper and genuine, signature to the said
Thomas Patterson , said Paket, or bill of sale is,
hereunto attached and marked thus, (A) (a) and
among other indorsements, on the, back is one in
these words filed 12th Octoer 1835 of
Clerk. This Deponant further sayeth that he
thinks and believes the, said Thomas Patterson left,
this county Livingston , sometime in the spring
summer, summer of the year of 1808 and went to
Arkansas , as since which time he has not seen him, been in this state of Kentucky , as this deponant
knows, of he further sayeth that he has heard

and believes the report true that the said Thomas
Patterson died a few years since in the now new
state of Arkansas ,, he further sayeth that said
Thomas Patterson was taken esteemed, and believed,
among his acquaintances, while living in this
county as a correct honest, and upright
man,, and further this Deponant sayeth not,

David Brown

Christopher Haynes, a justice of the peace for
Livingston and state of Kentucky , do certify
that David Brown the depandant was
by me, sworn to testify the whole truth of his
knowledge touching, the matter in controversy
in the court, aforesaid that the Deponant was examined
and his examination reduced to writing and
subscribed by said Deponant in my presents
on the 16th Day of March 1837 between the
hours, of six in the fournoon, and six in the
afternoon at the court house in the town, of
Salem, Livingston County , & state of Kentucky ,
given and certified this 16th Day of March 1837

Christopher Haynes J.P.,

Presely, Gray of lawful, age being,
produced and sworn, on the part, of the Defendant
deposeth,. deposeth that, the Distance from this
place Salem, Livingston County to St,Lewis Missouri
by the Common rought, of travelling is
not more than one hundred and Eighty
miles and further this deponent saith, not

Presley, Gray

I Christopher Haynes, a justice of the peace for
Livingston and state of Kentucky , do certify
that Presley, Gray the Deponant was by me,

Sworn to certify the whole truth of his knowledge
touching the matter in Controversy in the case aforesaid
that the deponent was examined and his examination
reduced to writing and subscribed by said Deponant
in my presents on the 16th day do March 1837 between
The hours of in the morning and six in the evening
at the court house in the town, of Salem,
County and State of Kentucky given and certified
this 16th of March 1837.

Christopher Haynes,

I Christopher Haynes, an acting Justice of the peace
for Livingston County and State of Kentuckyy
do certify that in persuance, of the within
commission and notice come before me at
the Court house in the town, of Salem in,
the County last, aforesaid David Brown
and Presley Gray, who were there by me, sworn
and examined and such examination
reduced to writing and subscribed by them
respectively in my presents and their said
Depositions are now herwith returned given,
at the Court house in the County of Livingston and state of Kentucky this
16th day of March 1837.

Christopher

It is hereby certified that Christopher Haynes,
on the sixteenth day of March in the year of our Lord one thousand eight hundred and thirty seven
was and now is an acting Justice of the Peace within
and, for the County of Livingston and state of
Kentucky duly commissioned and acting as
such and, that full faith, and credit are due
to his acts, as such.

In testimony whereof I James L Dallam , Clerk of the
Livingston County Court & for the State
of Kentucky (it being a have hereunto subscribed,
my name & affixed the seal, of office, this 16th day of March eighteen hundred and thirty seven.James L Dallam,

Depositions for defendant

Opened and filed April 1st 1837 John Ruland Clerk

Justices of the

For and in Consideration of the of thirteen
hundred and twenty five
by Jonathan Ramsay , the whereof is hereby
acknowledged I Josiah Ramsay , of the county of
Livingston , and state of Kentucky , do hereby sell
and convey, to Jonathan Ramsay , of the county and
state af my negroe woman, Bell and my two Negro
girls Amy , and Delph , with there further increase,
and also my two negro boys and George
reserving, to myself the use of and
under my hand and seal, day

8th August 1809 of it

filed 12th october
1835

1808

page and

Commonwealth, of Kentucky , Livingston County

Patterson Clerk of the County Court ,
for said County as hereby certify the this
bill of sale, from Josiah Ramsey, to Jonathan Ramsay , was on the 4th day of October 1808 produced
in, open court and acknowledged by the said Josiah ,
to be his set and deed, and the same was ordered,
to be recorded. In testamany whereof and that
recorded the same and this certifecate
my hand this 9th day of february 1833

order of the court by
depositions, taken from Arkansas , Territory the
12th 1835 in the
Amy vs Jonathan , of
depending in the
Circuit Court

I am requested to state what I know about
the execution, of a Bill of sale or paper purporting,
to be signed by Josiah , Ramsay and which is dated
27th of August 1807 and which I have this day
examined in the clerk's office of Circuit Court
of St. Louis county where I found the same
attached to depositions, of David Brown &
Presley, Gray entitled, in the cause of Delph
or, Dorris - that paper purports, to have
been executed by Josiah , Ramsay in 1807
and I never saw him write before about seven
or eight years ago when he had
in his fingers and indeed, was able to
a pen - so that although I incline, to think that
signature at the bottom of sd, paper was made
by him I wish it to be understood what
my means of forming, an opinion - I never
saw any of his writing except his signature
and whether he could write any more, than
that I do not know - my opinion above expressed, is founded on some small similarity of,
the character of this signature and those, which
I have seen him make - he was a farmer St Louis 4th of april 1837

W . Lucas ,

In the Circuit Court
County of St. Louis Missouri

Take notice, that on the fifteenth day of june
in the year of our Lord one thousand eight hundred and thirty- seven, between
the hours of six,. in the forenoon and seven in the
afternoon, of that day, at the office of clerk of the circuit
court of the county of Cole, state of Missouri
depositions will be taken by the undersigned, to be read on the trial of the above
entitled case, on behalf of the defendant,; 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, until completed.

To the above named plaintiff.Stephan Dorriss, deft
his atty, B Allen,.

notice

Served this notice by delivering
a true copy therof to the within
named Delphe, on the8th day of may
1837 in the county of St. Louis

James Brotherton , service 50th By M Brotherton ,

Depositions of witnesses produced sworn and
examined on the fifteenth day of June in the year of
our Lord one thousand eight hundred and thirty seven
between the hours, of six, in the forenoon, and seven in
the aternoon, of that day, at the office of Clerk of the Circuit Court of the county of Cole state of Missouri
before me George. M. Miller a justice, of the peace, within
and for the county aforesaid, in a certain cause now
depending in the Circuit Court of the County of
St. Louis in the state of Missouri , between Delph
plaintiff and Stephen Dorris defendant an the
part of the Defendant

Robert H. James of lawful age, living produced
sworn and examined on the part of the defendant
deposeth, and saith, - that,

About the last of May, in the year eighteen
hundred and thirty five he (Deponent) was in the
state, then territory,, of Arkansas , and among the
relations of Thomas Patterson , and in the neighbourhood
and at the cause where he understood
said Patterson resided during his life, and that he
(this deponent) then, & from said Pattersons
relations understood he said Patterson was dead,
and at the same time heard, said relations of
said Patterson testify to the hand writing of
said Pattersons as a subscribing witness to a deed,
of sale from Josiah , Ramsay to Jonathan , Ramsay
for Delph and other slaves,, and that he then, and
there heard the same persons state on oath that
said Patterson was dead and that he died, some
one two or three years before that time, the time
not now certainly recollected, by this deponent>

Robert H Jones ,

Sworn & subscribed to before me
on the day at the place and within the,
laws first aforesaid.

G. W. Miller,

Beverley, A. Ramsay of lawful age, being produceed
sworn & examined on the part of the defendant
deposeth, and saith that

Delph a Mulatto, girl now about thirty two years of
age was born, a slave for life the property, of Josiah
Ramsay sent late, of Callaway county in this state
that said Josiah by deed of sale conveyed, said Delph
to Jonathan , Ramsay by whom said Delph was
some years afterwards conveyed, to Stephen , C. Dorriss
said defendant, now of Callaway county
that said Josiah never at any time since the birth
of said Delph owned, another slave of the name
of Delph ; that said Delph has been seen by this
deponent in the City of St. Louis where, he understands,
she now resides - that he, this deponent - know one
Thomas , Patterson who was a subscribing witness,
to the said deed, of sale by which said Josiah
Ramsay conveyed, said Delph , with other slaes, to
said Jonathan , Ramsay , that said Patterson
removed, from the state of Kentucky , to the territory,
of Arkansas , and that some years ago it was currently,
reported among his acquaintances, & connections
in the state of Missouri , and believed by them
that said Patterson was dead, - and that said
Josiah Ramsay died in Callaway county , in September 1834

Beverly A. Ramsay

Sworn & subscribed to
before me, on the day at
the place and
within the hours first aforesaid

JP.

I George Miller a justice of the peace,
within & for the county of Cole, in the state
of Missouri , do hereby certify, that Robert H Jones ,

and Beverley, A.Ramsay the deponents were
by me severally sworn, to testify the whole truth of
their knowledge, touching the matter in controversy
aforesaid, that they were examined and their
examination to writing in their presents
and by them respectively subscribed
in my presence on the day between the hours
and at the at the plece in that behalf first aforesaid

. Miller J,. P,.

for defendant,

Dep: opened & filed 21st June 1837 John Ruland Clerk
Regularly taken

Depositions

opened & filed 21st June 1837 John Ruland Clerk

.
Paid 25

To the Clerk of the
Circuit court
of St. Louis

St.Louis
Mo,

County of St. Louis , set.State Of Missouri ,To the sheriff of St. Louis County Greeting:

You are hereby commanded to summon William Lucas ,
that setting aside all manner of excuse and delay, he be and appear in proper person
before the judge of our Circuit Court , on the 26th July next
at the city of St. Louis then and there to Testify,
and the truth to say, in a certain matter of controversy now pending in our said Court.
wherein Delph is
plantiff and Stephen W Dorris, is
defendant on the part of the Plaintiff
and have you then and there this writ.

Witness, John Ruland , Clerk of our said Circuit court, at
the City of St. Louis , this 27th day of June
in the year of our Lord, eighteen hundred and thirty- 7 John Ruland Clerk, C.C.

William Lucas , not found in my county,

James Brotherton , sheriff
121/2
By Joseph W MClurg Dshff,

July Term 1837

Plantiff

William Lucas ,
26 July

County of St. Louis , set.State Of Missouri ,To the sheriff of St. Louis County Greeting:

You are hereby commanded to summon William Lucas ,
that setting aside all manner of excuse and delay, he be and appear in proper person
before the judge of our Circuit Court , on the 26th
at the city of St. Louis then and there to Testify,
and the truth to say, in a certain matter of controversy now pending in our said Court.
wherein Delph is
plaintiff and Stephen W Dorris, is
defendant on the part of the defendant,
and have you then and there this writ.

Witness, John Ruland , Clerk of our said Circuit court, at
the City of St. Louis , this 27th day of June
in the year of our Lord, eighteen hundred and thirty- 7 John Ruland Clerk, C.C.

William not found in my county,

james sheriff
121/2
By Joseph

July term 1837

defendt

William Lucas ,
26th July

St. Louis Circuit Court

Take notice that on the 26th day
of June AD 1807 between the hours of six, in the
forenoon. and six in the afternoon of that day at
the office of the Clerk of the County , Court of
Callaway , County . State of Missouri the depositions of
William H Russel,, William Scott, and others will
be, taken by the undersigned to be read on the
trial, of the above entitled cause, on behalf of
the plaintiff which if not completed on that day
will be continued, from day to day until, all are,
taken at the same place and between, the same hours, as above.

Delph by her atty,
I. . Stone To the above named
Stephen Dorriss

I do, hereby acknowledge due, service of
the within notice on me, this sixteenth day of June 1837

C Dorriss,

Dorriss

Deposition for plaintiff

opended filed 3rd july 1837 John Ruland clerk

Depositions of witnesses, produced sworn,
and examined on the twenty, sixth and twenty ninth, days of June
eighteen hundred and thirty seven between
the hours of six in the morning and six in
the evening of the days at the clerk office
of the county court of the county of Callaway and, state of Missouri in the Town of Fulton ,
before me Martin Basket, an acting Justice
of the peace within and for said county in
a certain cause now pending in the Circuit
Court of the County of St Louis state of
Missouri between Delph , a woman of colour
plaintiff and Stephen C Dorris, Defendant on,
the part of the plaintiff

Willaim H Russell, of lawful age produced
sworn, and examined on the part of the plaintiff
deposeth, and saith

Question by the defendant state wether or, not and at what time
you examined the records of the county court of Livingston county
Kentucky , touching the record of a bill of sale from Josiah Ramsay , to Jonathan Ramsay , sometime
in the month of August, 1835 to to take deposition in a
by against Jonathan Ramsay , for
freedom and which then the records
a bill of sale and
by Josiah Ramsay to Jonathat Ramsay and ascer,
tained that notwithstanding it, was executed, many
( in the year ) that, it was not
recorded until, a in 1830
question by same Did examine regularly throuh the records
from the year 1806 to 1835 and state

that there, was no record made until, many years
after it that it was not recorded untill after
1830

question by same do you know any thing in relation to the character of
Jesse Patterson , clerk of the Livingston county court at the time
said bill of sale was recorded Answer I took depositions,
in Livingston county Kentucky proving, that
said Jesse Patterson clerk, of Livingston County Kentucky
at the, time said bill of sale, was recorded was a professional gambler, otherwise his character, was fare
sworn, to and subscribed before me on the
day at the place and within the hours first aforesaid June, the 26th at, 6 o clock P.M., the proceedings in this
case is adjourned, until tomorrow morning 6 o clock

June, the 27th 1837 met pursuant, to adjournment, and your
and, half past five in the evening, until tomorrow
morning 6 o clock

June 28th 1836 met pursuant to ajournment,
and adjourned, this day half past five in the evening, until tommorow
morning 6 o clock

June 29th met pursuant, to adjournment,
William B Scott being, of lawful age being produced sworn and
examined, on the part of the plaintiff
deposeth and saith

question by the defendent, state when you were acquainted Delph , the daughter of the plaintiff in this suit
Answer I am and have been from 1817 up to the present
time

question by same state whether or not she lived with Josiah Ramsay , up to the year 1826 as his slave

Answer she lived with Josiah Ramsay , as his slave up to some

time in 1826 or 1827

question by same, did or did not Josiah Ramsay , appear
to be the only person exercising owenership over her upto that
time Answer he did

question by same did or did Delph , after that time go
at large as a free woman and continue to act as such
Answer, she did go at large and act as a free woman

question by same, did or did not Jonathan Ramsay , live
near Josiah Ramsay , during the time said slave was in
his possession, Answer he did

question by same, did or did not Josiah Ramsay so, always
pretend, to an unencumbered, title to the slave Delph ,

Answer he did
question by same, did Jonathan Ramsey, ever set up
any title to or pretend, to have any title, to the said slave during the
life time of Josiah Ramsey,

Answer he never did to my knowedge
question by same, is this signature to the acknowledgnment of service, notice marked
in the hand witing of Stephen C Dorris,

Answer it is

state your age and residence-Answer I am, 49 years of age
reside in Callaway , county state of Missouri and within
about six miles of the city of Jefferson , and further
this deponent saith not

sworn to, and subscribed before me on the day at that place
and within the hours specified in the adjoinment

Martin Basket, Justice of the peace,

State of Missouri
Callaway County ,

I Martin Basket, an acting
justice of the peace within and for said
county do hereby certify that William H Russell, and William B Scott, the deponents
were by me severally sworn, to testify the whole
truth of their knowledge touching the matter
in controversy, aforesaid that they were examined
and their examination reduced to writing and
by them respectively subscribed in my presence,
the day at the place and between the hours
in that behalf first aforesaid

Martin Basket, Justice of the peace

state of Missouri
Callaway , County

I Israel B Grant, Clerk
of the county Court of said County do
herby Certify that Martin Basket, whose
signature appears to the forgoing Certificate
was, at the time of signing the same and
acting justice of the peace within and
for said county duly commissioned, and
qualified, and that his acts as such are
entitled, to due faith and credit,

Given, under my hand
and the seal of said
court this 20th day of June 1837,
subscribed - 894
Subscribed - 25
for this 50th

County of St. Louis ,set.State Of Missouri ,To the sheriff of St. Louis County Greeting:

You are hereby commanded to summon Wm Lucas, Wm Lucas,
that setting aside all manner of excuse and delay, he be and appear in proper person
before the judge of our Circuit Court , on the 28th
at the city of St. Louis , then and there to Testify,
and the truth to say in a certain matter of controversy now pending in our said Court,
wherein Delph is
plantiff and Stephen Dorris,
defendant on the part of plff,
and have you then and there this writ.-

Witness, John Ruland , Clerk of our said Circuit court, at
the City of St. Louis , this 17 day of October
in the year of our Lord, eighteen hundred and thirty- seven Jn. Ruland Clerk, C.C.

Wm Lucas , not found in my county,

James Brotherton , sheriff
non est, 12 1/2
By Joseph W MClurg,

November term 1839

Plff,

Wm Lucas ,28th November

County of St. Louis , set.State Of Missouri ,To the sheriff of St. Louis County Greeting:

You are hereby commanded to summon Wm Lucas ,
that setting aside all manner of excuse and delay, he be and appear in proper person
before the judge of our Circuit Court , on the 28th November next
at the city of St. Louis then and there to Testify,
and the truth to say, in a certain matter of controversy now pending in our said Court.
wherein Delph is plantiff and Stephen Dorris is,
defendant on the part of Defs,
and have you then and there this writ.

Witness, John Ruland , Clerk of our said Circuit court, at
the City of St. Louis , this 17 day of Oct,
in the year of our Lord, eighteen hundred and thirty- seven Jn. Ruland Clerk, C.C.

Wm Lucas , not found in my county, not
being alive

James Brotherton , sheriff By Joseph W MClurg Dshff, 12 1/2

November term 1839

Deft,

Wm Lucas ,28th November

County of St. Louis , set.State Of Missouri ,To the sheriff of St. Louis County Greeting:

You are hereby commanded to summon Wm Lucas ,
that setting aside all manner of excuse and delay, he be and appear in proper person
before the judge of our Circuit Court , on the24th November
at the city of St. Louis then and there to Testify,
and the truth to say, in a certain matter of controversy now pending in our said Court.
wherein Delph is
plantiff and Stephen Dorris is,
defendant on the part of deft,
and have you then and there this writ.

Witness, John Ruland , Clerk of our said Circuit court, at
the City of St. Louis , this 15 day of November
in the year of our Lord, eighteen hundred and thirty seven Jn. Ruland Clerk, C.C.

Wm Lucas , not found in my county, being
dead

James Brotherton , sheriff By non est, 12 1/2

November term 1839

Deft
W Lucas

County of St. Louis ,sct.State Of Missouri ,To the sheriff of St. Louis County Greeting:

You are hereby commanded to summon Wm Lucas ,
that setting aside all manner of excuse and delay, he be and appear in proper person
before the judge of our Circuit Court , on the24th November
at the city of St. Louis then and there to Testify,
and the truth to say, in a certain matter of controversy now pending in our said Court.
wherein Delph is
plaintiff and S Dorris,
defendant on the part of Plff,
and have you then and there this writ.

Witness, John Ruland , Clerk of our said Circuit court, at
the City of St. Louis , this 15 day of November
in the year of our Lord, eighteen hundred and thirty seven Jn. Ruland Clerk, C. C.

W Lucas , not found being dead

non est, 12 1/2 James Brotherton ,
By Joseph

November term 1839

Plff
W Lucas ,
24th

November term 1837

And the said deft, by his attorney comes,
and defends the force & injury when & says for
further plea, in this behalf with leave, of the Court
has obtained that the said plaintiff ought
not to have or maintain her aforesaid action there
of against him the said defendant because he
says that the said plaintiff before & at the time
of the commencement of her suit aforesaid against
him the said defendant, was & still is the slave
of him the said defendent this he the said defendant
is ready to verify, wherefore he says

B. Allen,

And the said Deft, for replication to the additional,
plea of the by him with of
that for any thing the said the not
to be became she says that at the time of the comnencement
of her saint aforesaid she was not the slave
of him the said the
of the county

No 4
November Term 1836

additional plea application,

Filed December 8th 1837 John Ruland Clerk

St. Louis april 19 1838

We the Jury, find
verdict, for the defendant,

169

If the jury, believe from the evidence
that Josiah Ramsay , excuted the bill,
of sale to Jonathan Ramsay , and the
deposited in the clerks,
office in Kentucky , it is the opinion
of the court, that there is no legal evidence,

before then of its destruction
or of any and

St. Louis Circuit Court

Delph being duly sworn on,
her oath saith that her appeal, from
the judgement, of the court, in this case
is not made of vexation, or delay, but
because this affiant belives that she is
aggrieved, by the defendant, of the court

Sworn, to and subscribed in
open Count this 21st
April 1838 Delph her X mark

Affidavit, filed april 21st 1838

John Ruland Clerk

March Term 1838

March Term 1838
Be it remembered that on, the
trial, of this case the defendent read in evidence
the following depositions (here insert
the depos, of deft those not read)
Defendent also read in evidence the following
instruments (here insert the Bill of sale of
Josiah Ramsay ,to Jonathan Ramsay , and of
Jonathan Ramsay , to plantiff)

Defendent here closed his case the
plantiff there offered & read in evidence
the deposition of William Lucas ,
also the deed of emancipation, and the certificates thereon and the
following depositions (here insert the other depositions of plantiff) saint
Bill of sale from Josiah , to Jonathan Ramsay , in evidences was are a good deal
worn and some what tone and parted together are the back, with
cloth

this, was all the testimony given
in the case & the court there upon instructed
the jury that there was no evidences before
them of a of said Delph by
Jonatha to Josiah Ramsay or of said Bill
of sales being in or
from which they could it one or
the other of which was necessary, in and
that the deed of emancipation, should
and that it was for the jury, to
determine wheather the Bill of sale given
in evidence Josiah Ramsay , to
Jonathan Ramsay ,was executed, by the
Josiah Ramsay , the original owner of the
slave. To the giving which instructions the
plantiff by her counsel, excepted & prayed

the court, to sign & seal, this Bill
of exceptions, what is done accordingly

Bill of exceptions,

Filed,april 21st 1838 John Ruland Clerk

Bill of Exceptions

Depositions

David Brown

March Term 1838

Be it remembered that on the trial of this
cause the Defendant read in evidence the following depositions
“Commonwealth of Kentucky ,, Livingston County , Depositions
“of witnesses produced, sworn and examined at the court in
“the Town of Salem,, Livingston County , State of Kentucky ,
"before me Christopher Haynes, an acting justice of the peace
"in and for the county of Livingston & State of Kentucky ,, in a
“certain cause now depending in the circuit court in the
"county of St. Louis and State of Missouri , between Delph
“a woman of coular plaintiff & Stephen C Dorriss defendand,
"on the part of the Defendant. David Brown of lawful
“age being produced sworn and examined on the part
“of the Defendant deposeth and saith; that he was well acquainted
"with Thomas Patterson in the years 1806, 7 & 8 in this
“county, that he has often seen him write and that he was
“well acquainted with his signature and verily, believes &
"has no doubt but the signature of the said Thomas
" Patterson signed to a paper as a witness now shown me
“ purporting, to be a Bill of sale from Josiah Ramsay to
“ Jonathan , Ramsay for a certain negro is the proper and
"genuine signature to the said Thomas Patterson , said paper
“or bill of sale is here unto, attached and marked thus (A) (a)
“and among other endorsements on the back, is one in these
“words “filed 12 October 1835 I. O. Clerk. This Deponent
“further saith that he thinks and believes, that said Thomas
" Patterson left this county, Livingston , sometime in the spring
“or summer of the year 1808, and went to Arkansas ,, since
“which time he has not been in this State Kentucky , as this
“Deponent knows of - he further sayeth that he has heard &
“beleives the report true,, that the said Thomas Patterson
"died a few years since in the now new State of Arkansas , he,

"further sayeth, that said Thomas Patterson was taken esteemed,
“and beleived among his acquaintances while living in this
“county as a correct, honest and upright man and further
"this Deponent sayeth not. David Brown . I Christopher
"Haynes, a justice of the Peace for Livingston and state of Kentucky ,
"do certify that David Brown the Deponent was by me,
“sworn to testify the whole truth of his knowledge touching the
“matter in controversy in the cause aforesaid that the deponent
“was examined and his examination, reduced to writing
“and subscribed by said Deponent in my presence on the 16th
“Day of March 1837 between the hours of six, in the four noon
“and six, in the afternoon at the court house in Town of Salem
“ Livingston , County & state of Kentucky , and certified this
“16th day of March 1807. Christopher Haynes JP,

Presley, Gray

“Presby Gray, of lawful age being produced and sworn
“ on, the part of the Defendant Deposeth deposeth that the distance
"from this Salem, Livingston county to St. Louis Missouri by
“the common rought of travelling is not more than one
“hundred and eighty miles and further this Deponent sayeth not
"Presley Gray." - I Christopher Haynes a justice of the peace
"for Livingston and State of Kentucky , do certify that Presley
“Gray the Deponent was by me sworn to testify the whole
“truth of his knowledge touching the matter in controversy,
“and his examination reduced to writing and subscribed
“by said Deponent in my presence on, the 16th day of March
“1837, between the hours of in the morning, & six, in the
“evening at the court house in the Town of
"Salem, Livingston county and state of Kentucky ,
“given and certiffied this 16th of March 1837. Christopher
“Haynes I Christopher Haynes, an acting justice of
"the peace for Livingston county and state of Kentucky , do

“certify that in pursuance of the within commission and notice came
“before me at the court house in the Town of salem in the county
"last aforesaid David Brown & Presley Gray who were there by me sworn
“and examined and such examination redused to writing and subscribed
“by them respectively in my presents and their said Depositions
“are now herewith returned given at the court house in the county
"of Livingston and state of Kentucky , this 16th day of March 1837
" Christopher Haynes JP,". "It is hereby certified that Christopher
“Haynes, on the sixteenth day of march, in the year of our Lord
“one thousand eight hundred and thirty seven was & now is an
"acting justice of the peace within and for the county of Livingston
“and state of Kentucky , commissioned and acting as
“such and that full faith, and credit are, due to his acts, as such

In testimony whereof I James L Dallam , Clerk of the
" Livingston County Court & for the state of Kentucky ,, (it being a
“of Record), have hereinto subscribed my name & affixed, the seal
“of office, this 16th day of March Eighteen hundred and thirty
“seven. James L , Dallam ."

“Depositions of witnesses produced
“sworn and examined, on the fifteenth day of June in the year
“of our Lord, one thousand eight hundred and thirty seven, between
“the hours of six in the forenoon and seven in the afternoon, of
“that day, at the office of the clerk of the circuit court of the
"county of Cole, State of Missouri , before me George W Miller
“a justice of the peace within and for the county aforesaid
“in a certain cause now depending in the circuit court of
"the county of St. Louis , in the state of Missouri between Delph
"plaintiff & Stephen Dorriss defendant on, the part of the Defendant
Robert H Jones . ". " Robert H Jones , of lawful age being produced sworn and
“examined on the part of the defendant deposeth and saith,;
“that about the last of May in the year Eighteen hundred
“and thirty five he (Deponent) was in the state, then territory,
“of Arkansas ,, and among the relations of Thomas Patterson
“and in the neighbourhood and at the house, where he under

stood said Patterson resdided, during his life time, and that
“he this Deponent, then and from said Pattersons Relations
"understood he said Patterson was dead, and at, the same
"time heard said relations of said Patterson testify to the hand,
"writing of said Patterson as a subscribing witness, to a deed
"of sale from Josiah Ramsay to Jonathan , Ramsay for Delph
“and other slaves, and that he then and there heard, the same
"persons state on oath, that said Patterson was dead, and that
“he died some one, two or three years before that time the time
"not now certainly recollected by this deponent. Robert H
“ Jones ,. Sworn and subscribed to before me on the day at the
"place and within the hours first aforesaid. G W. Miller J. P.

Beverly A Ramsay

Beverly A Ramsay of lawful age being produceed sworn
“& examined on the part of the Defendant deposeth & saith
"Delp a mulatto, girl now about thirty two years of age was
"born a slave for life the property of Josiah Ramsay
"late of Callaway county in this state that said Josiah
“by deed of sale conveyed, said Delph to Jonathan , Ramsay
"by whom said Delph was some years afterwards conveyed,
"to Stephen C Dorriss, said Defendant now of Callaway county
“ Mo,. That said Josiah never at any time since the birth
"of said Delph , owned another slave of the name of Delph
"that said Delph has been seen, by this Defendant in the
" City of St. Louis , where he undersstands she now resides
"That he this Deponent knew one Thomas Patterson who
“was a subscribing witness,, to the said Deed of sale by
"which said Josiah Ramsay conveyed said Delf with,
"other slaves to said Jonathan Ramsay - that said Patterson
“removed from the state of Kentucky , to the Territory of Ar
“Kansas, and that some, years ago it was currently report,
“ed among his acquaintances, & connections in the state
"of Missouri and believed by them that said Patterson was

(2)
"dead - And that said Josiah Ramsay died in Callaway ,
“ County, Mo. in September 1834. Beverly A Ramsay.
“Sworn and subscribed to before me, on the day at the place
"and within the hours first aforesaid . G W Miller, J. P. I George
“Miller a justice of the peace within and for the county
“of Cole,, in the state of Missouri do hereby certify that
" Robert H Jones , & Beverly A Ramsay the deponents
“were by me severally sworn to testify the whole
“truth of their knowledge, touching the matter in con,
“ troversy, aforesaid, that they were, examined, and
“their examinations to writing in their presents and by
“them respectively subscribed in my presence, the day between
“the hours, and at the place in that behalf first
"aforesaid. G W Miller J. P." The defendant also gave
“Bill of sale
J Ramsay to J Ramsay
“in evidence the following instruments-” for and in consideration
“of the sum of thirteen hundred and twenty,
“three dollars to me in hand paid by Jonathan , Ramsay the
"receipt whereof is hereby acknowledged I Josiah Ramsay of
"the county of Livingston and state of Kentuky, do hereby
“sell and convey to Jonathan , Ramsay of the county and
“state afore,, my negro, woman Bell, and my two negro,
“girls Amy, & Delp with their, future increase, and also my
“two negro, boys Ephraim & George reserving, to myself the use
“of sd, negroes and their increase for and during, my natural
“life - Given under my hand and seal this 27 day of august
“1807 Josiah Ramsay

Test Thos. Patterson. Commonwealth
“of Kentucky ,. Livingston county to wit. I Jesse , Patterson Clerk
“of the county court for said county to hereby certify that this
"Bill of sale from Josiah Ramsay to Jonathan , Ramsay was
“on the 4th day of October 1808 produced, in open court and
"acknowledged by the said Josiah to be his act, and deed, and
“the same was ordered to be recorded - In testimony whereof
“and that I have recorded the same and this certificate

“ hereunto, set my hand this 9th day of February 1833. Jesse , Patter
“son Clerk.”

Know all men by these presants that I Jonathan Ramsay
"of the county of Callaway & state of Missouri have this day
“bargained and sold, to Stephen C Dorriss of the city of Jefferson ,
“and state af a Mulatto, woman now supposed to be in St. Louis
"about 30 years of age called Delph , formerly the property of Josiah
" Ramsay of the county of Callaway and conveyed conveyed by, said
" Josiah to me by deed bearing date the 27th day of August
“1807, in which deed the said Josiah reserved to himself
"the use and benefit of the said Delph for and during his natural,
“life, now for and in consideration of the sum of two,
“hundred and sixty dollars to me in hand paid by the above
“S C Dorriss, I hereby convey and transfer to the said S C Dorriss
“all the right, title, interest and claim I have in and
"to the said Delph , he the said Dorris being well acquainted,
"with the foundation of my right and claim to said Delph
“and he takes the same without any recourse, to me and if
"the said Delph shall sue, for her freedom I am not to be
“at any trouble or expence in defending the same. Given
“under my hand and seal this 21st day of June 1826. Jonathan
" Ramsay . Test, J B Bowlin. The Defendant here closed his
“case -

Plaintiffs Evidence

“The Plaintiff then offered & read in evidence the Deposition of
" William Lucas ,, also the deed of Emancipation annexed, thereto
“and the certificates thereon;

“five or ten dollars) the whole amount which was to be paid
"by the said Delph for her freedom, including the payments
“already made, was to be either three or four hundred dollars
“and this deponent beleives that the sum acknowledged
“to have been recovered on account was between eighty or
“ninety dollars- this deponent beleives that at the time of
“the execution of the said deed of emancipation Jonathan ,
" Ramsay the step son of the said Josiah , Ramsay resided
“about one mile from the Residence of the said Josiah ,, and
“that the said Jonathan , resided there for several years
before and since. W Lucas . Sworn to and subscribed
“before me this 14th day of March A.D. 1837. J W . Walsh Justice,
"of the peace. St. Louis County' And the said deed of
“emancipation is as follows to wit. “Know all men
“that I Josiah , Ramsay senior, out of my own
“free choice and in consideration of the faithful services,
"of my mulatto female slave called Delph do by these presents emancipate and set free my said female mulatto slave called Delph from this day
“forth to go, without being obliged to serve or obey myself,
"or any other persons- she said Delph being aged about twenty
“three years - As witness, my hand and seal this fourth
“day of May in the year of our Lord one thousand
“eight hundred and twenty six Josiah , Ramsay senior
“signed sealed and delivered, in presence of William Lucas , Andrew
"Lockhart." " State of Missouri County of Callaway , set
“I O Hockaday Clerk of the Circuit Court within
“and for the county aforesaid, do certify that “At a Circuit
"Court held for Callaway County at the house of Joseph
“T Litton, in the Town of Fulton , the place fixed for
“holiday said Court on Monday the 12th day of November
“A.D. 1827.” “This Deed of Emancepation from Josiah ,
" Ramsay senior. to a certain mulatto slave named Delph
“ dated the fourth day of May A.D.1826 was this day produced
“in open court, and proved to be the act and
“deed of the said Josiah , Ramsay senior according to law

by the oaths of the two, subscribing. witnesses William Lucas
"who is personally known to the court and Andrew
“Lockhart, whose, identity was proven by John Conger
“and Irvine, O Hockaday In testimony whereof I have
“ hereunto, set my hand and affixed the seal of said Court }“at office, this 12th day of November A.D. 1827, and the
“8th year of the State Irvine, O Hockaday.” and the said
“endorsements are as follows to wit-” Josiah , Ramsay senior
"to Delph Deed of Freedom. 1827 November 12th Proved in open court
“subscribing witnesses and ordered to be certified filed for
“Record, on same day & fee not paid. W Lucas to
“pay I O Hockaday Clerk.” “Proved in open Court by the
"oaths of William Lucas & Andrew Lockhart; Lockharts identity
"being proved by John Conger & I O Hockaday N B Tucker,.”
“Recorded in Book B folio, 95 & examined I O Hockaday Clerk
“Plaintiff also read in evidence the following deposition
““Depositions of witnesses produced sworn and examined
“on the twenty sixth and twenty ninth day of June
“Eighteen hundred and thirty seven between the hours
“of six in the morning and six in the evening of those
“days at the Clerks office in the county court of the
"county of Callaway and State of Missouri in the Town
"of Fulton , before me Martin Bas

“Ref. an acting Justice of the peace within and for said county
“in a certain cause now pending in the Circuit Court of the
" County of St.Louis and State of Missouri between Delph a woman
"of colour plaintiff and Stephen C.Dorris Defendant on the
“part of the plaintiff.”

W H Russell.

William H Russell of lawful age, produced
“sworn and examined on the part of the plaintiff deposith and saith
“Question by the Defendant. State whether or not and at what time
"you examined the records of the county court of Livingston County
" Kentucky , touching the Record of a Bill of sale from Josiah , Ramsay
“ to Jonathan , Ramsay ? Answer. Some time in the month
“of August 1835, I to Livingston county, Kentucky to take
“deposition in a suit instituted by sundry, Negroes against
“ Jonathan , Ramsay for freedom, and which there examined
“the Records touching a Bill of sale, said to have been executed
“by Josiah , Ramsay Sr . to Jonathan , Ramsay , and
“ascertained that not withstanding it was executed many
“years since (I think in the year 1807) that it was not recorded
“until a period subsequent to 1830. Question, by same
“Did examined regulaly through the records from the year
“1806 to 1835-? Answer, I made a thorough examination
“between these periods, and State positively that there was no
“record made until many years after it purports, to have been
“executed, and I feel very confident that it was not recorded
“until after 1830. Question by same. Do you know any
“thing in relation to the character of Jesse , Patterson Clerk
“of the Livingston , County Court , at the time said Bill of
"sale was recorded ? Answer - I took depostions in Livingston
"county Kentucky , proving that said Jesse , Patterson Clerk
"of Livingston County Kentucky , at the time said Bill of sale
"was recorded was a professional Gambler, otherwise his
"character was fair. William Henry Russell . Sworn to and
“subscribed before me on the day at the place and

“Within the hours first aforesaid. Murtin Baskett J.P.
“June 26th at 6 O'clock P.M. the proceedings in this case
“is adjourned until to morrow morning 6 O'clock.
“June 27th 1837. Met pursuant to adjournment, and
“ adjourned, half past five in the evening adjourned until
“tomorrow morning 6 O'clock. June 28th 1836. met pursuant
“to adjournment and adjourned this day at half past five
“in the evening until tomorrow morning 6,O clock. June
“29th met pursuant to adjournment,.

"W.B. Scott

" William B.Scott of lawful age being produced sworn
“and examined on the part of the Plaintiff deposeth and
“saith, Question by defendant. State where you were
"acquainted- Delph the daughter of the plaintiff in this
“suit? Answer - I am and have been from 1817 up to the
“present time. Question by same. State whether or not she
“lived with Josiah , Ramsay Sr up to the year 1826 as his
“slave? Answer She lived with Josiah , Ramsay Sr , as
“his slave up to some time in 1826 or 1827. Question by same. Did or did not Josiah , Ramsay Sr , appear to be
“the only person exercising, ownership over her up to that
“time ? Answer He did. Question by same. Did or Did
" Delph ater that time go at large as a free woman and
“continue to act as such ? Answer She did go at large &
“ act, as a free woman . Question by same. Did or did not
“ Jonathan , Ramsay live near Josiah , Ramsay Sr . during,
“the time said slave was in his possession ? Answer he did always
“Question by same “did or did not Josiah , Ramsay Sr . pretend,
“to an unencumbered, title to the slave Delph ? Answer
“He did. Question by same. Did Jonathan , Ramsay ever
“set up any title to or prtend to have any Rite to the said
“Slave, during the life time of Josiah , Ramsay Sr .? Answer
“He never did to my knowledge. Question by same. are

(3)
"you acquainted with the hand writing of Stephen C Dorriss,
“the defendant in the cause ? Answer, I am Question, by same
“Is this signature to the acknowledgement of service of the
"notice marked A in the hand writing of Stephen C Dorriss, Answer
“It is state your age and residence-Answer, I am
"49 years of age-resided in Callaway County State of Missouri ,
and within about six, miles of the city of Jefferson ,
“and further this Deponent saith not. Wm B Scott, Sworn to
“and subscribed before me on, the day, at the place and with
“in the hours specified by law,in the last adjournment,
“ Martin , Basket justice of the peace. State of Missouri
" Callaway county. set. Martin Baskett, an acting justice
of the peace within and for said county as hereby certify,
"that William H Russell & , the deponents
“were by me severally sworn, to testify the whole
“truth of their knowledge, touching the matter in ontroversy,
“aforesaid - that they were examined and their examinations
“reduced to writing and by them respectively subscribed
“in my presence on the days, at the place and between
“the hours in that behalf first aforesaid. MArtin Basket,
"justice of the peace. State of Missouri Callaway county
“ Israel B Grant, Clerk of the county court of said
county do herby certify that Martin Martin Basket, whose
“signature appears to the foregoing certificate was at
“the time of signing the same an acting justice of the
“peace, within and for said county, dully commissioned
“and qualified and that his acts as such are entitled
“to due faith and credit given under my hand
“and the seal of said court this 30th day of june 1837
“I B Grant, Clerk.” said Bill of sale from Josiah , to Jonathan Ramsay , it appeared in evidence was an old
“paper, a good deal worn and somewhat turn and pasted
“together on the back with cloth. This was all the testimony given

“in the case, and the court therefor instructed the jury, that
“there was no evidence, before them of reconveyance, of said
“ Delph , by Jonathan , to Josiah , or of said Bill of
“sales being cancelled, or annulled, or from which they could
“presume it, one or the other of which was necessary, in
order that the Deed of emancipation, should operate - and
“that it was for the jury, to determine, whether the Bill
“of sale given in evidence from Josiah Ramsay , to Jonathan ,
“ Ramsay , was executed, by the Josiah Ramsay ,
the original owner of the slave to the giving which
“instructions the plaintiff by her counsel excepted and
“prayed the court to sign and seal this her Bill of exceptions,
“which is done accordingly

"State of Missouri
County of St. Louis

I, John Ruland Clerk of the Circuit Court in and for said county certify the foregoing
to be a true copy of the Bill of exceptions and
“of all the papers therein, reffered to, which was filed
“in the case of Delph vs, Stephen C Dorriss, as the
“same now remain, among the files of my office

In testinomy whereof I have
hereunto, set my hand and affixed
the seal of said court at
office in the city of S Louis ,
this 9th day of may AD 1838. Jn , Ruland clerk.

(4)
“Which are in the words and figures following to wit
" William Lucas being duly sworn, to State the truth the whole
“truth and nothing but the truth in a certain cause pending
"in the St.Louis Circuit Court , wherein Delph is plaintiff
"and Stephen Dorris is Defendant and being examined on
“the part of the plaintiff deposeth and saith- that the paper
“now shown to him dated the 4th of May 1826, purporting, to
"be a deed of emancipation of Delph by Josiah , Ramsay senr
“and which is hereto annexed, was drawn by deponent at the
"request of said Ramsay at sd, Ramsay house on, the day the
"said paper bears date and was then executed by said Ramsay ,
“who wrote his name opposite the scrawl, at the foot,
“of sd, deed and sd, Ramsay subjoined in his own hand
“to his name ““ all which was done in deponents
“presence who thereupon in said Ramsays presence signed
“the said paper as witness- this Deponent belives that
“Answer Lockhart whose name is also signed as a witness
“signed his nand as witness, to the said paper at the same
"time that this witness did and in presence of said Ramsay ,
“but this deponent has no distinct, recollection on
“the subject- this deponent was formerly acquainted
“with the hand writing of the sd, Andrew Lockhart,, having
“often seen him write, but it is so long since that he
“has forgotten it, he neverthesless, has no doubt whatever
"what the said signature is genuine- the said Andrew
“Lockhart removed to Texas, many years since and this
“deponent has been informed, that he has since died
“there, but this Deponent does not know the fact- On
“further reflection deponent has some recollection of the
"said Andrew Lockhart, having been sent for and coming
"to the house of said Ramsay for the purpose of witnessing
“the said deed or paper. At the time the said
"Deed was executed Delph the plaintiff was present

"and the said deed was thereupon delivered by said Ramsay
"to said Delph , in presence of this Deponent. Deponent
"knows that the said Delph had for many years previous
“to the execution of the said Deed and was at that time
"claimed and possessed, by the said Ramsay as his slave
“and at the time of the execution of the said deed this
“deponent had no doubt whatever of the right and
"power of the said Ramsay to her. This deponent beleives that the said Ramsay at the time of
“the execution of the said deed and until the day of
“his death (which was some three or four years since)
“was of sound mind, and fully competent to attend to
“his own affairs. There was no secrecy, injoined, nor observed,
“ by this deponent in the said transactions and
this deponent frequently heard the said Ramsay ,
“served by state that he intended to set all his negros
“free and, that intention must have been well known
“ in, his neighbourhood at the time of the execution
“of the said deed before and since. As the time of the
“execution of the said deed it was proposed by the said
" Ramsay to sell to the said Delp her freedom and said
" Ramsay declared and acknowledged in presence of Deponent
"that the said Delph had before that time paid
“him money on that account, the amount not recollected,
“but the deed was not drawn in that manner, in consequence
“of the advice of Deponent and it was nevertheless agreed by
"and between the said Ramsay and the said Delph that the
“ballance of the money should be paid by the said Delph
"to the said Ramsay from time to time out of her earnings
“this deponent believed that there was some payment made
"by the said Delph to the said Ramsay on that account
“in his presence (the sum, not recollected probably some