Mary a free woman
of Colour and children, Plaintiff
against Launcelot H Calvert , Defendant State of Missouri
in the Circuit Court
of St. Louis Count

Plaintiff states that she is
a free woman of colour and that she is a
free person and entitled to her freedom for the
reasons herein after stated to wit
That
many years ago when she plaintiff was a
child the exact time she does not know that
she was the slave and belonged to a man
named James Bowd in the State of Kentucky
who was her master and owner and
that her said master and owner removed from
the State of Kentucky to the State of Ohio and
took her the plaintiff with him and there
continued and resided permanently in
said State of Ohio for more than one year
keeping plaintiff in his possession at his aforesaid
residence in the State of Ohio and therefore
Plaintiff Claims that on account of her
said residence in the State of Ohio that she
is entitled to her freedom and that she is a free
person. Plaintiff states further that after
her said residence in the State of Ohio that
she was carried back by the said James Bowd again to
the State of Kentucky and remained a short time
and was put in the possession of one Bryson
Stilwell who brought her to this State where she
had been but a short time when she was sold by
the aforesaid Bowd to one William P Owsley a
negro and slave trader and dealer and she was
immediately shipped by him the said Owsley from
her residence and home at the time of sale, the
city of Hannibal in this State to the city of St .
Louis by & in charge of one A. I. Butler also a negro and slave
trader and dealer plaintiff being then ignorant of
her right to freedom and that she was a free person and
upon its being made known to said Butler that
the plff was a free person he sent immediately
back to Hannibal where she removed sometime
and the contract for her sale having been rescinded
as she was informed, she was again sold by said Bowd
to one George. W. Harris and by Harris again to said
Owsley who sold & sent her to Dr. Bonnett of St. Louis
and since the sale to Dr. Bonnett she the plff
has been put in possession of Lynch and
Tooley & the defendant in this suit who now has
her in possession and holds her as a slave and
various other persons all negro and slave traders
and dealers and to all of whom except the deft
in this suit plff has been informed she had been
sold and pretended sales all being made with a
view as plff believes to annoy and perplex her and
thereby make her abandon her suit for freedom
against the aforesaid Harris who is since the
dead commencement of said suit dead and
the suit has been dismissed by her attorney
at Hannibal in the Court of common pleas of said city by
order of Plff where suit had been commenced
against said Harris as aforesaid and plaintiff having
no certain knowledge of who is now her pretended
owner and master brings her suit against
defendant who now holds her in possession as
a slave as aforesaid.
Plaintiff also states, that

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

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

Mary and children by
their counsel Richmond Major &
Richmond

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

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

Mary a free person of
colour for herself & children
by her attys Richmond Major & Richmond

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

Joel C Richmond
Sworn to & subscribed before me
the 5th day of Nov. 1850.
A. Hamilton Judge 8th Judicial Circuit Mo.

To the Clerk of St Louis Co the Circuit
Court of St. Louis County

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

A. Hamilton , Judge &c

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

Joel C Richmond

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

John H. Watson, Law Commissioner
of St. Louis County - by
Philip C. Mauro. Dpt.

And that the above said woman Mary
and her children Samuel and Edward be brought
before me at on the day of November 1850.

Mary a free
woman of colour
& Children

Against

Launcelot H. Calvert Filed 5th Nov 1850 M. S. Cerre Clk.

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

Saint Louis Circuit Court
April Term 1851

Pet for freedom

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

A. Hamilton Judge &c

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

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

Service$1 00order1 00$ 2 00

Henry B Belt SheriffBy Robt Peyinghaus dpty

County of St. Louis , Ss.The State of Missouri ,To the Sheriff of St. Louis County, Greeting:

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

Witness. Michael S. Cerre , Clerk of said
Court with the seal thereof hereto affixed at
office in the city of St Louis this
5th day of November in the
year of our Lord eighteen hundred and fifty M S Cerre Clerk.
I acknowledge myself bound for all costs that may accrue in the above cause. Witness my hand and seal at St. Louis , this day of 18

In the Circuit Court
April Term AD 1851

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

T. Polk P.D

C. C.Apr. T. 1851

Demurrer to petition

T. Polk P. D

Filed May 24th 1851
M. S. Cerre Clk
withdrawn

In the Circuit Court
April Term AD 1851

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

Polk
Atty for Deft

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

Lancelot H Calvert . Sworn to & subscribed before
me this 19th day of June 1851 Peter W Johnston
Justice of the Peace

Cir . Court - April Term
AD 1851

Answer of Deft

Filed June 20, 1851
M. S. Cerre Clk
withdrawn

In the St .
Louis Circuit
Court
June

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

She also adds to her
petition the following

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

Mary of colour by
R. F. & J C Richmond , Attys

Filed June 20 1851

M. S. Cerre Clk

Depositions

Opened & filed
Oct 6. 1851 M. S. Cerre Clk

In the Circuit Court
of St Louis County
State of Missouri To Lancelot H Calvert
Sir

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

Mary
By her AttorneysR F & J.C. Richmond

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

T. Polk atty for Deft

Notice to take depositions in
case of
Mary
vs Calvert

1st
Depositions of witnesses produced
sworn and examined at the town of
Felicity in the County of Clermont
and State of Ohio before me George
. W. Richards a Justice of the peace
within and for the County and
State aforesaid in a certain
case now pending in the Circuit
Court of Saint Louis County in
the State of Missouri wherein Mary
a woman of color is plaintiff
and Launcelot H Calvert is defendant
and for said plaintiff in pursuance
of a notice hereto attached and at
the time and place therein mentioned.

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

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

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

Answer

I did know a colored girl who lived
in Brown County with James Bowd by the name
of Mary in the State of Ohio .

Question by same----State when
and how state when
and how long said Mary came to the State of Ohio who brought her to Ohio who
she staid with in Ohio & how long she remained in said State.

Answer.

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

Question by same Did said Mary
live with and in the family of said Bowd
during the time reffered to above and as a servant while in Ohio and did
James Bowd live in Ohio during the one
or two years above mentioned.

Answer.

Mary did live within the Family
of James Bowds the time above referd to
as a servant and don the work.
James Bowd
lived in Ohio the one or two years above mentioned.
Question by same.

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

Answer

James Bowd remained in the State of Ohio between one and two years, came to Ohio
from the State of Kentucky .

Question by same ----- When you speak
of the time said Mary lived in the family
of said Bowd do you mean the time
Bowd lived in Ohio .

Answer.

I did

3rd page
Please state how old you think said
Mary was at the time she came with Bowd
to Ohio and what her color was

Answer

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

Question by same - Did you ever see
said Mary after she left Ohio if so where

Answer

I seen said Mary afterwards at
Augusta in the state of Kentucky and in
the family of said James Bowd .

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

Answer

It has been between six and seven years

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

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

Answer

I was not acquainted with James
Bowd before he came to the State of Ohio .

I never had seen him.

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

4

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

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

Answer

I resided on the farm of Samuel
Martins about a mile and half from the
Ohio River opposite Augusta in Brown
County Ohio .
I was farming

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

Answer

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

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

Answer

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

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

By same - What were you doing at the steam

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

Answer

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

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

Answer

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

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

Answer

I seen her frequently

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

Answer

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

I think
I would know her now.

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

6

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

Answer

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

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

Answer

I frequently visited his house while he lived in Kentucky

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

Answer

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

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

Answer

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

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

7

Answer

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

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

Answer

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

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

Answer

She was employed part of the time as
a nurse part of the time in the kitchen.
She was a keen looking girl pleasant looking
(8)
with a smiling countenance She
was of tolerably industrious habits.

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

Answer I suppose she was neither

I think she was of tolerable
industrious habits-

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

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

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

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

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

Answer -

She lived with him about six
or eight months-

(9)

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

Answer

He told me they came from Louis
County Kentucky .

Witness reexamined by plaintiffs counsel

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

Answer

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

Question by same

State what you
suppose the age of Mary was when
living with Bowd in Ohio and
describe her size and appearance.

Answer

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

(10)

Question by same

When you speak of said Mary a colored
woman living with Bowd from
one to two years do you mean
the whole time she staid with Bowd
or only the time she was with
him in Ohio .

Answer

Only the time she was with him
in Ohio .

Question by same

Do you know of said Mary ,
having living with said Bowd after she left Ohio
in the state of Kentucky if so
how long and under what circumstances

Answer

I do know Mary lived with
James Bowd in Augusta Kentucky about
two years after she left Ohio she lived with
him as a servant girl.

Question by same

Did James Bowd take said Mary
with him to the state of Kentucky

Answer

Yes he took her with him to the
state of Kentucky

Question by same

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

Answer

In Brown County

(11)

Question by same

Where were you living
at the time said Bowd lived in Ohio

Answer

I was living on the farm of
Samuel Martin about a mile and a
half from Augusta in Brown
County Ohio

Question by same

Who brought said Mary to the
state of Ohio at the time she came

Answer

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

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

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

Question by plaintiffs council

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

(12)

Answer

I new a colord girl by the name
of Mary in about ten years ago living
in the family of James Bowd as a servant
girl in Ohio Brown County and lived
there about two years.

Question by same

State if you know who bought Mary to Ohio

Answer

She came with the family of
James Bowd

Question by same

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

Answer

He has one colored woman
besides Mary I think her name was Lucy

Question by same

State the size age and color of
said Mary .

Answer

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

Question by same

Where did said Mary come from when she
came to Ohio and under what circumstances

Answer

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

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

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

Answer

She lived in Ohio something near
two years.
She moved with the family of
James Bowd to Augusta Kentucky .
I was frequently at Bowds in Augusta
when she was there some year or two
after she left Ohio .

Question by same - What was the
color of the other colored woman at
said Bowds you call Lucy , also state her age at the time
Bowd first moved to Ohio .

Answer-

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

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

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

Question by same
Was it the two years immediately after said
Bowd moved to Ohio that said Mary lived with him

(14)

Answer-
It was

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

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

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

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

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

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

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

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

(15)

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

Answer

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

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

Answer-

I would supose she was about
sixteen.

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

Answer

He was on the boat when they
landed he came off the boat employed
hands to assist him to move - I do not
know how long he staid with his family
there was. there was a young lady by the name
of Racheal Bell no other strangers to my recollection (16) I do not recollect any others landing - at
that time - I do not know who the
Negro belonged to that were with Bowd .

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

Answer

I do not.

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

Answer-

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

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

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

Answer - I do not know. They were in
his possession after he removed to Kentucky
there was a woman and a small Girl - the
woman was a dark mulatto the Girl was rather
lighter (18)
I was reparing a sellar and boarded with
Mr. Bowd , while I was engaged with Bowd
three days I think.
there was no other
person boarding in the family at that
Miss Rachael Bell was not boarding with
Bowd at that time no other persons
boarding with said Bowd at the that time.

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

Answer-

I had dealings with Bowd frequently

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

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

Answer-

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

reexamined by Plaintiffs Counsel

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

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

Answer-

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

Further this Deponent saith not.

Henry R Hendrickson

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

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

Answer-

I know Mary a woman of colour
who lived with James Bowd but wheather
or not she is the plaintiff in this case I canot
tell Said Mary lived with James Bowd
between one and two years in Brown County
Ohio about the year 1840 1 or 2 3 - or about
that time I never was much about their
house have been passing and reposing
several times and seen said Mary .
I suposed
her to be a servant but do not know have seen
her at work in the kitchen and nursing James Bowds (20)
child.
I know nothing about how she
came there

Question by same

State what you supose the age of Mary
was when living with James Bowd in
Brown County Ohio & describe her size and color
and appearance.

Answer

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

Question by same

Did you ever see said Mary at any
other place than Bowds house

Answer

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

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

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

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

Answer

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

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

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

Answer

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

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

Answer -

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

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

Answer

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

(22)
Further this deponent saith not.

Wm Maxwell.

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

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

Answer

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

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

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

Answer

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

Henry Wise

Opened & filedOct 6th 1851.

M. S. Cerre Clk

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

G W Richards, J P

Justice fees

2 subpoenas 34Constable Simmons fees75 25 123 witness fees1.50writing 5500 words 5.5025$6.212.50$2.50$8.71 Total

The State of Ohio , Clermont County ss.

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

In testimony whereof I have hereunto set
my name and affixed the seal of said Court,
the27th day of September 1851.R. W. Clarke Clerk.

Opened & filed Oct 6th 1851 M. S. Cerre Clk

Deposition Opened &

FiledNov. 15th, 1851 M. S. Cerre Clk

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

S T Glover
for Deft Joel C Richmond
for Plff

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

The negro girl Mary remained in the State of

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

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

Crossexamination by S. T. Glover for defendant

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

answer: about seven or eight years ago.

question: Where you seen her last?

answer: in Auguste Kentucky .

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

answer: it was about one year.

question: what was about a year?

answer: that I saw her in Auguste , Kentucky
the last time.

question: what was you doing in Auguste
Kentucky for about one year?

Answer: I was living on Mr. Bowds farm in Ohio
opposite Auguste , and was doing work for Mr.
Bowds by days in Auguste , Kentucky

Question: You did not live in Auguste that year?

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

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

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

question: can you give the number of days?

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

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

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

question: how do you recognise the girl Mary
here present?

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

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

answer: no other.

question: do you remember any marks?

answer: none

question: had you much conversation
with her?

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

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

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

question: which was the darker of the two?

answer Lucy was the darker.

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

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

question: she was as tall as she is now?

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

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

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

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

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

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

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

question: when you saw her last in Kentucky
in Auguste was she full grown?

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

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

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

question: under what circumstances did you
come?

answer: I was send here for that purpose

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

Adolph Frehr
Not. Public

question: who send you?

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

Objected to this question and answer by the plaintiffs counsel.

Adolph Frehr

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

Answer: the persons was the citizens of the town
of Felicity , in the State of Ohio , in Clairmount
County

Objected to by plaintiffs counsel. Adolph Frehr

Question: What had they to do with it?

answer: I dont know Sir.
Question

Objected to this question
by plaintiffs counsel. Adolph Frehr

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

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

Objected to this question and
answer by plaintiffs counsel.
Adolph Frehr

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

answer: some of them was knowing as anti
slavery men; whether they was formed in a society or not, he deponent cannot
say

Objected to this question and answer
by plaintiffs counsel. Adolph Frehr

Question:

Are you a member of an antislavery society?

Answer: No Sir:

Objected to this question by pltfs
counsel. Adolph Frehr

Question:

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

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

Question: Who furnished the money?

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

Objected to this question by
plaintiffs counsel. Adolph Frehr

Question:

1) How much money?

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

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

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

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

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

od 3. Answer: No Sir, none.

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

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

Question:

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

Answer: I was.

Objected to this question
by plaintiffs counsel.
Adolph Frehr

Question:

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

Answer: Yes Sir.

Question: Are you an abolitionist, my friend?

Answer: No Sir. I never was.

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

Answer: I voted for General Cass.

Question: Who you voted for the time before?

Answer: I always voted the Democratic
Ticket

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

Answer: I voted for Cass.

Question: Did you ever voted for Van Buren

Answer: I did, when he first was elected President

To all these questions, plaintiffs
counsel objected.
Adolph Frehr

Question: Have you been on terms of friendship with Mr. Bowd ?

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

Question: You feel any interest in this suit?

answer: None at all particularly.

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

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

Answer: It will make no more or no less.

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

Answer: yes, she is the same woman.

Objected to this question by
defendant. Adolph Frehr

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

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

Question: Who told you?

Answer: Mr. Richmond told him.

And further deponent says not.

James Hendrickson Adjourned over by consent till the 14th
November, at 8 o'clock in the morning.

State of Missouri
County of St. Louis

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

hereby certify that James Hendrickson , the
deponent, whose place of residence is in the town of
, Clairmont County, in the State of Ohio , was by me sworn
to testify the whole truth of his knowledge touching the
matter in controversy in the cause aforesaid; that deponent
was examined, and his examination reduced to writing
and subscribed by said deponent, in my presence, on
the thirteenth day of November in the year eighteen
hundred and fifty one, between the hours of eighth and
tenth o'clock in the forenoon, and two o'clock and four
o'clock in the afternoon at the office of Joel C. Richmonds
Office in the City and County of St. Louis and State
of Missouri .

Given and certified, the thirteenth day of November 1851.
Adolph Frehr , Notary Public.

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

Question by plaintiff: where you reside?

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

question: how long have you lived there?

answer: about ten months.

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

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

question: state what time you lived in Brown
County ?

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

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

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

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

answer: in Brown County , State of Ohio .

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

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

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

answer: yes, James Bowd did live in the State
of Ohio , in Brown County , two years.

question: where were you present, when James
Bowd landed in the State of Ohio ? with his family

answer: Yes I was.

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

answer: Yes he did.

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

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

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

answer: the womans name was Lucy , the
girls name was Mary .

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

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

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

answer: I would call her a dark mulatto.

Question: how long did the girl Mary remain
in the State of Ohio ?

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

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

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

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

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

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

This question objected to by
defendants counsel. Adolph Frehr

answer: Yes, she was.

question: were you well acquainted with the girl
Mary ?

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

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

answer: He moved to Auguste , State of Kentucky
Bracken County.

question: did he take the girl Mary with him?

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

The last question objected to
by defendants counsel. Adolph Frehr

question: when did you see the girl Mary last?

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

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

answer: I think I would.

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

answer: I have.

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

answer: I think she is the same one.

This question objected to by
defendants counsel.
Adolph Frehr

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

answer: I have not.

Objected to by defendants
counsel. Adolph Frehr

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

answer: I have non.

Crossexamined by defendants counsel:

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

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

question: Had you ever been in his house?

answer: I had not.

question: Had you ever seen his residence?

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

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

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

question: from whom did you get your good
information?

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

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

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

answer: about eight hundred miles.

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

answer: I have not.

question: was you brought here by any process?

Objected to this question by
plaintiffs counsel. Adolph Frehr

answer: I was not.

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

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

question: are you paid for coming?

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

Objected to this question by
plaintiffs counsel.
Adolph Frehr

Question: from whom do you expect pay?

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

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

answer: yes, he is.

question: how much pay you expect to get?

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

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

answer: No Sir.

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

answer: No Sir I dont know.

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

answer: he has.

question: Who is it?

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

objected to all these questions
by plaintiff's counsel Adolph Frehr

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

Objected to this question by
plaintiffs counsel. Adolph Frehr

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

question: how is the word Felicians spelled?

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

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

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

Objected to these questions
by plaintiffs counsel.
Adolph Frehr .

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

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

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

answer: she was much smaller.

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

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

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

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

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

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

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

answer: James Hendrickson .

Reexamined by plaintiffs counsel.

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

Answer: It will not according to contract.

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

Answer: I am not.

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

Objected to his question by
defendants counsel. A Frehr

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

question: did Mary growtmuch as she was
living in Ohio with James Bowd ?

answer: yes she growt very fast.

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

Objected to this question by
defendants counsel. Adolph Frehr

Answer: I did recognize her.

Question by defendant:

What business do you follow at home?

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

H R Hendrickson

State of Missouri
County of St. Louis

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

Nevill, Clermont County , in the State of
Ohio , was by me sworn to testify the whole
truth of his knowledge touching the matter in
controversy in the cause aforesaid; that deponent
was examined, and his examination reduced to writing
and subscribed by said deponent, in my presence
on the fourteenth day of November in the year
eighteen hundred and fifty one, between the hours
of eight and eleventh o'clock in the forenoon
at the office of Joel C. Richmond in the City
and County of St. Louis and State of Missouri

Given and certified, this fourteenth day of
November 1851.

Adolph Frehr Notary public.

These depositions of James Hendrickson
and Henry R Hendrickson
were taken by consent of S T
Glover for defendant Joel C. Richmond
for plff.

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

S T Glover for
Glover & Campbell for Deft
Joel C. Richmond
for Plff.