Barney Montgomery v. John R. Bronaugh. Affidavit of Barney Montgomery


Barney Montgomery Petitioner for Freedom

March Term 1843
290 Imps

On this second day of June AD 1843, in open court, personally appears the above named petitioner, and being duly sworn deposeth and saith: That since the trial of the above entitled cause, he the petitioner hath discovered new evidence material proper and competent to be used by the said Petitioner in support of the issue on his part [illegible] in the said cause: and that at the time of the trial thereof he the petitioner was ignorant that the said evidence was within the jurisdiction of this court, or could be addressed by him on the said trial. By which said evidence the said petitioner expects to prove that he was in fact hired in the state of Virginia at the time of the removal of his owner Mrs Martha Graham, from the state aforesaid into this County, and that he continued so to be hired, and actually remained in the said state more than twelve   months after such removal: so that he the petitioner was in fact unlawfully imperiled into the said County and is entitled to his freedom. That since the trial of the said cause the said petitioner has accidental become acquainted with the fact that the one of the persons to whom he was so hired in the state of Virginia is now living in the county of Washington and can be produced by him on the new trial of of the said cause, if the same be granted by the Court.

Sworn to in Open Court.
Test. W. Brent, Ck


290 Trials

Barny Montgomery

Petn for Freedom

Affidavit in support of mo. for new trial

file this
Carlisle for Petr

Filed 2d June 1843