William Kennedy v. Clarissa Purnell. Interrogatories for Defendant's Witnesses


Circuit Court of the District of Columbia for the County of Washington

William Kennedy or Candy Petitioner
Clarissa Purnell deft

Petition for freedom

Interogatories for deft's Witnesses

1. Are you acquainted with the parties to the above suit & if yea how long have you known them

2. State fully your knowledge respecting the above petitioner, whether he is free or a slave, & if the latter whose property he is and has been during your knowledge? Where born and raised, and where & under what circumstances he has been

3. Do you know anything of any trip of said petitioner from Maryland to Virginia, or from Virginia to the City of Washington, and of the circumstances attending the same, and the duration of stay, and whether any such trip or stay was with the sanction or assent, or against the will and wish of the defendant, Miss Clarissa Purnell? State all your knowledge on these subjects fully and at large.

4. Do you know anything further material for the defendant: if so state your knowledge fully and precisely.

Clement Cox Atty for the Deft

Cross Interogatories to be propounded on the part of the petitioner to all the Defendant's witnesses

1st What is the age of Miss Clarissa Purnell and who would be her heirs if she should decease   2th State whether or not I. Purnell Pendleton has been or is now a favoured relative of Miss Purnell?

3th State fully the reason & cause of I. Purnell Pendleton's taking with him to Virginia the Petitioner, & whether Miss Purnell did not give the petitioner absolutely to I. Purnell Pendleton?

4th Where has I. Purnell Pendleton resided during the last seven years?

5th Have you never heard either Miss Purnell or I. Purnell Pendleton declare the Petitioner to be the property of the latter & if so when and where?

6th Has I. Purnell Pendleton to your knowledge at any time represented the petitioner to be his property & dealt with him as such & was it with the privity and assent of Miss Purnell?

7th Was any hire stipulated to be paid or paid to Miss Purnell by I. Purnell Pendleton for the use of the Petitioner?

8th State whether the Petitioner was hired in Washington City & if so who hired him, at what wages & whether Miss Purnell at any time received any part of said wages, & the time of her so receiving said wages, and exhibit any receipt of Miss Purnell for the same if any you have, & if not state why you did not take her receipt for money (if any) paid by your to her on account of the Petitioner.

9th State fully any other matter or thing which which would benefit the petitioner on the trial of said cause, the same as if   specially innterrogated thereto.

Brent & Brent for Petitioner

Additional Cross Interrogatories to be propounded to all the Defendant's witnesses

1 When and in what year did I. Purnell Pendleton take the Petitioner to Virginia & where did the Petitioner remain between that time and his being sent to Washington City

2nd Was the Petitioner at any time hired out in the state of Virginia & if so state when & by whom, to whom & who received the hire & whether Miss Purnell received any part & if so at what time she received it & exhibit her receipt if she gave any.

Brent & Brent for Petitioner.


Clarissa Purnell
Negro William

I object to the Court signing any bill of exceptions in this case, because no exceptions were taken or reserved before the cause had been committed to the jury C. Cox for dft. & Petrs prayers were not offered to the Court