Moses Graham v. Richard B. Alexander. Frances Swann's Answers to Interrogatories


Deposition of Mrs Frances Swann, taken by consent of Parties, and duly sworn to, before Clement T Coote a Justice of the peace for the County of Washington, to be used as evidence in a suit now pending in the Circuit Court of said County, in which Moses Graham (slave) is Petitioner for freedom, and Dr. R. B. Alexander Defendant.

Interrogatory 1st Do you know when Milly (the Mother of Moses) was removed from Georgetown to the residence of your Mother in Alexandria County?

Answer. In the month of November 1812 I left Preston the residence of my mother to commence housekeeping at Mt Air in Fairfax County and I have not the slightest recollection of having ever seen Milly at Preston before I left nor do I remember that my mother or Miss Brown had any intention of bringing her there. When I returned to Preston in April 1813, on a visit to my mothers, I saw for the first time Milly and her two small children Ann and Rachel, and was surprised at this addition to the servants of the family, for I had never seen them at Preston before. My impression is that they must have been brought to Preston but a very short time before my arrival for if they had been long in the family I would have been apprised of it, so frequent were the communications between my family and that of my mother's.

Interrogatory 2nd. Were you an inmate of Mrs Alexanders   2 Family, up to the time of your removal to Mt. Air?

Ans. I had lived at Preston all my life, with the exception of a short interval of time. That interval occurred between the months of July & November in the year 1810.

Interrogatory 3rd. Could Milly have been at Preston, at the time of your removal to Mt Air without your knowledge?

Answer. I am confident she could not. I would certainly have known it had she been brought upon the farm.

Interragatory 4th. Did Mrs Alexander purchase Milly and her two children before or after their removal to Alexandria County?

Ans: I do not know:.

Questions on behalf of Petitioner

Interrogatory 1st When did Miss Elizabeth Brown first reside in the family of your mother Mrs Alexander

Answer I am certain she was residing in the family of my mother in the year 1810. I am also certain that she was not residing with my mother in 1806 but am not certain as to the year when she first resided with my mother it might have been as early as 1808 or 1809


Frances Swann

Subscribed and Sworn before me this 20th day April in the year Eighteen hundred and thirty nine.
Clemt: Coote J Peace


Further Questions by the Defendants

Interrogatory 5. Is Moses the son of Milly and was he born whilst Milly belonged to your mother?

Answer. Moses is the son of Milly as I always believed; and was the first child born after Milly came into the possession of my mother. I left Preston about the first of December 1813, and understood that Morses was born some time during that month about Christmas.

Interrogatory 6th. Did you ever hear Miss Brown say that she had sold Milly and her Children to Mrs Alexander if so at what time?

Ans: It was always a received fact in the Family, that Miss Brown had sold these servants to Mrs. Alexander, but I do not remember any particular conversation with Miss Brown on the subject, except on one occasion a short time before her death. She then regretted having sold these servants to Mrs. Alexander for she found that some of the family did not think as she did, and expressed her apprehension lest by having sold these servants she might for a small sum of money have entailed slavery upon them for life

Interrogatory 7th. How long had these servants been in the possession of Mrs. Alexanders claiming them as her property before Miss Brown's death

Ans. I first saw them in the possession of my Mother in April 1813, and was at that time under the impression that my mother had purchased them. They remained in her possession & she exercised every act of ownership, till she died in 1823. Miss Brown died in 1825.

Interrogatory 8th. Did not Miss Brown at one time live in Georgetown & where did she subsequently reside, also state whether she carried her servants with her at each removal.

Ans: She lived at one time in Mr. Magruder's family after in Georgetown, and I understood that she subsequently resided in Mr Magruders family after their removal to Baltimore. I know she resided in Baltimore in 1807 & early in 1808 and or 1809 and believe she remained in Baltimore till she came to live in Alexandria County. Whether she removed her servants, I cannot say. I understood however that Milly lived at one time in Baltimore


Deposition of Mrs Swann


* Further Questions on behalf of Petitioner

Interrogatory 2nd Be pleased to state when your mother Mrs Alexander purchased Milly & her two children and from whom and how much she gave Miss Brown for them

3th Be pleased to state whether the Petitioner Moses is the same Moses that is spoken of in the memorandum at the bottom of a copy of your Mothers will now shewn to you

4th Is the Milly spoken of in your answer to the interrogatories on behalf of Defendant free and if so say how she obtained her freedom and when

Answer to the 21st In I do not know when my mother purchased Milly & her children nor how much she gave for them but she purchased them from Miss Brown

Answer to the 32nd In I have every reason to believe that he is the same from the circumstance that his age corresponds with the Moses in the memorandum & further that at the that time his birth & since there has been no other Moses in the family but of but the Petitioner

Frances Swann

Subscribed & sworn before me this 22d day of April in the year One Thousand Eight Hundred & thirty nine.


Deposition of Mrs F. Swann.


Deposition of Mrs Swann