William Crowner v. George B. Scott. Mary Evans' Answers to Interrogatories


Crowner vs. Scott

Petn for Freedom

D. A. Hall

1 Look at the Petitioner William Crowner, and say whether you know him, and how long you have known him

2. Did you know his mother, and if yea, when, where, and how long did you know her, and whether was she slave or free, white or black, or African or European race: state all you know on these points, and your means of knowledge.

3. Did you know his mother's mother: and if yea, when where and how long did you know her, and whether was she slave or free, white or black, of African or European race: state all you know in there points and your means of knowledge.

4. Was the mother, or maternal grandmother at any time held in slavery by any person or persons whatsoever: if yea by whom, and which of them: or did they or either of them so at large constantly, acting as free persons.

5. Do you know with whom the petitioner's mother was living at the time of his birth: and if yea, do you know how she came to be living with such person, and whether she was living with such person as a slave or free.

6. State generally all you know which may be of advantage of either of the parties, as particularly as if you were specially interrogated thereto?


Deposition of Mrs. Mary Evans.

1 To the first interrogatory written the deponent saith I know William Crowner & have known him ever since he was born.

2d To the second she saith: I did know his mother, her name was Charity, and I knew her when she was a girl, at Mr Harry Talberts: she was a white woman, but you could tell that she had some mixed blood in her: she came to Mr. Talbert's to tend children, her mother put her there as a free woman, as I was always told.

3d To the 3d she saith: I did not know Charity's mother except by sight: I saw her twice at Mr. Talbert's and know that she was white, and I took her to be a white woman of the European race: she appeared to be as white as I am, and no white person is a slave.

4th To the 4th she saith: Charity the mother of Crowner always stayed at   Henry Talbert's and did his marketing for him, but whether she was held, or claimed as a slave, she does not know.

5th To the Fifth, she saith that she was living at Mr. Talbert's, but why, she cannot tell otherwise than as she has before stated.

6th To the 6th she saith she knows nothing more.

To the Hon. the Circuit Court of the District of Columbia for the County of Washington, the undersigned respectfully reports that on this 22d day of Dec. 1841, in pursuance of the annexed order, he [illegible] to the residence of Mrs. Mary Evans the witness named in the said order, being within the said County of Washington, and that she exhibited to her, and propounded the questions, hereto annexed, and appearing on the first page of this sheet: to which she made the answers above written [illegible] the said questions. But the said Mrs. Evans upon being required to sign & make oath to the testimony so by her given, firmly refused so to do: alleging for reason that though she had formerly told the   Petitioner that she would make oath to what she had stated, yet that she had since, and within a few days, promised to her son in law, Mr. Sayers, that she would never again set her hand to paper, or make an oath in any case: she alleged that all she had said, was true but by reason of her promise, she would not swear to it. Her testimony could not therefore be taken, and a return of the fact is made accordingly.

D. A. Hall J. P.

197 Trials


Return of D.A. Hall Esqr under the rule to take this testimony of Mary Evans

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Key & Carlisle for Petr.