Rachel Johnson v. Morris Adler. Affidavit of John Marbury
On this day of November in the year 1852 personally appears in open Court John Marbury & made oath on the Holy Evangely of Almighty God that on the trial of this cause at the term of this Court in Dec 1849, he was ignorant of the existence of the act of assembly of this state of Maryland passed in the year 1833 & entitled an act Chapter 87 & that he was surprised by the introduction of that act on the said trial, & the necessity of showing a compliance by Tho Turner with that the condition thereof on his importation of the petitioner Rachel from the Dist of Cola into Frederick County Maryland; & that he acquired their first knowledge of the necessity of showing such fact & that since the trial of the said cause & within four days afterward, as he verily believes he first came to the knowledge that Mr. Turner on his importation of the said negro Rachel into the state of Maryland as aforesaid did comply with letter & condition of the said act which evidence consisting of a copy of the said record he now produces. & he verily believes that the Defendant admr of the said Turner was equally ignorant as himself in the premises.
Jno Marbury
