Thomas Butler v. Gabriel Duvall. Interrogatories to Thomas Gossum & Thomas M. Gossum
Interegotaries upon the part of the plaintiffs
1st Do you or do you not know Thomas Butler and Sarah his wife and whether they were not at one time the slaves of one John Dels or Dales
2 Were you not well acquainted with said Dels during his life time and was he not at one time a resident of the State of Maryland or the District of Columbia; which of those places he raided at, and at what time or times?
3 Do you or do you not know that said Dells moved into the state of Virginia to reside and when & how long he resided there, and whether he and carried with him said Thomas Butler and his wife Sarah and whether they did they not live with him after his removal into said state of Virginia as his slaves, & how long?
4 Do you or do you not know that whether while said Dels was thus a resident of Virginia that he sold said Thomas Butler & his wife Sarah and their child named Sally, to Judge Gabriel Duvall and to whom he sold them and when?
5 Do you or do you not know when the said Dels moved into the state of Virginia, when he took his new slaves Thomas & his wife & child into said state and at what period the sale of said slaves took place?
Cross-Interrogatories on the part of Deft.
1. Do you know Gabriel Duval, the deft in this case, when & where did you ever see him & what do you know of him?
2. Did you know said John Dels or Dales, when he lived in Montgomery County, Maryland, & before he removed to Georgetown, and when he removed to Georgetown?
3. Did you know said Dels or Dales at the time he lived in Georgetown, as bar-keeper to Christian Getzendanner, in the year 1803?
4. Did said Dels or Dales then own said slaves, and had he the slaves with him in Georgetown?
5. Did he then or at any time hire said slaves to Getzendanner?
6. How long had said Dels or Dales removed from Montgomery to Georgetown before he lived with Getzendanner, or acted as bar-keeper?
7. How long after that was it before you knew said Dels or Dales in Virginia if you ever knew him there at all; or was it not before he lived in Montgomery & Georgetown that he lived in Virginia, and did he not remove from Virginia to Montgomery or Georgetown?
8. Did you know said Dels or Dales at the time he kept a grocery store in Georgetown, which he had purchased purchased of Getzendanner, and what year was that; was it not in 1803?
9. Do you know what years & how long said Dels or Dales lived in Montgomery & in Georgetown respectively?
10. Can you say with any certainty that said Dels or Dales removed from Georgetown or Montgomery to Virginia, any time after he so lived in Montgomery & Georgetown & when?
11. Can you be certain that, if he did so remove after living in Georgetown & Montgomery, he brought with him to Virginia the said identical slaves Tom Butler & Sarah his wife, and when he so brought them to Virginia?
12. Do you know when or to whom said Dels or Dales sold the said slaves, and where he was when he sold them: state the particulars? And who was present at such sale?
13. Did you know said Dels or Dales when he lived as tenant to a Mr or Mrs Thompson & how long ago: and where that house was, whether in Georgetown or in the city of Washington: Did you know him when he lived as tenant to Matthew Kennedy, and when was that & where?
14. Did you know him when he lived with one Flaut; or with Christian Getzendanner, or with one William Duval; and when did he so hire with those persons, how long ago, and where; was it in Georgetown or in the city of Washington?
15. Did he own the said slaves during that time, and was he in the custom of hiring them out, and can you recollect what persons hired them?
It is agreed that the foregoing interrogatories & cross interrogatories he respectively put to the following witnesses, on the part & behalf of the petitioner; to wit: Thomas Gossom & Thomas M Gossom
That Dr. Richard C. Mason, a Justice of the Peace for Fairfax County, be authorised to to put the interrogatories to the several witnesses, and take & certify their answers under oath to each interrogatory distinctly: both parties are very desirous that Dr. Mason should undertake & execute this commission; but if it be so inconvenient that he cannot do it, he is authorised to transfer this commission to such other Justice of Fairfax as he thinks competent to execute it: only two of the witnesses, twit, Thomas Gossom and Thomas M Gossom one understood to be in the State; the names of the others are inserted to take the chance of their being returned: the witnesses reside at the Occoquan Mills or the immediate
neighborhood, and can be found on application there. Whoever takes the answers, will please see that each interrogatory is distinctly & completely answered; and where the interrogatory is compounded of several facts & circumstances, such as dates, place &c. &c. will see that the answer embraces all the numbers of the interrogatory. It is further agreed that such witness be examined separately & a part in the presence of the Magistrate, without any attorney or agent, either for the petitioners or the defendants, or for the abolition society being present.
Robert Beale atty for Petrs
W. Jones for Deft.
Tom Butler &c.
vs
Gabriel Duval
Petition for freedom.
Interrogatories to wits. for Petrs.
(Fairfax)
Opened in Court & filed 3d May 1834
Deposns of the two Gossoms.