John Battaile v. Thomas Miller. Defendant's Interrogatories to Charles A. Stokes


Interrogatories to be put to Charles A. Stokes in a suit of Petitioner for freedom by John Battaile a negro against Thomas Miller pending in the Circuit Court of the District of Columbia for the County of Washington; the said Stokes being about to go above 100 miles from the place where said suit is to be heard.

Interrogatory 1. Do you or do you not know any thing concerning the sale of the petitioner by one James R. Miller if you state the time of said sale— the consideration, and the place where the said sale was made and finally consummated?

Interrogatory 2. Do you or do you not know that at the time of said sale there was a distinct understanding between said J.R. Miller that the said slave was to be carried out of the District of Columbia to the State of Georgia?

Interrogatory 3. Do you or do you not know that after the said sale and purchase the petitioner broke jail in the town of Alexandria and was a runaway for a considerable length of time thereafter?

Interrogatory 4th Do you or do you not know that the said J.R. Miller sold said slave with great reluctance and from these[?] [illegible] and that he did it without the knowledge of his father and family and was exceedingly anxious to conceal from his parents the fact that he had sold him?

Interrogatory 5th Do you or do you not know that Thomas Miller the defendant in said suit is the father of the said   J.R. Miller and had raised the petitioner who had been given when a child to said J.R. Miller when he was a child by some of his relations in the State of Virginia? If yea state whether the defendant did not agree to refund to you the purchase money which you had paid to his said son for the purpose of cancelling and annulling said sale so that the petitioner might return to the family and remain as he had been before the said sale.

Interrogatory 6. Do you or do you not know? and if yea state if the petitioner was not a runaway at the time when the defendant agreed to refund as aforesaid; also what appeared to be the motive of the defendant for doing so; and if you did or did not commit to that arrangement

Interrogatory 7th. Have you or have you not any interest in the event of the said suit.

Interrogatory 8th Did you or did you not deliver to the defendant the receipt and bill of sale which said J.R. Miller had given you at the time of the said sale.

Interrogatory 9th
Do you or do you not know whether the negro the Petitioner was in jail in Alexandria? if yea was he there at the time of the agreement for the sale between yourself & J.R. Miller

H M Morfit[?]
atty for deft