O Say Can You See

George T. McGlue a citizen of Washington makes oath according to law:

That he is not in any manner interested in, or to gain or lose anything by the result of the cause pending in this Court in which Lucinda Sumby is Petitioner and Samuel E. Douglass Defendant

That he knows the said Lucinda, knew her mother, Matilda, before at the time of and after the birth of said Lucinda. That the said Matilda at the birth of said Lucinda, and before and after was the slave of said Defendant and his sister. That Lucinda was born about the year 1841 in the City of Washington, and has remained here ever since. That he has seen her from time to time from her birth birth to the time of the filing of the said petition, and never heard any one suggest, nor does he know any fact tending to show that she was free or entitled to her freedom

That at the time of the arrest of said Lucinda in October 1854, and when she was committed to the jail deponent was present at the magistrates office, and at the jail, & there gave evidence to show that she was the slave of said Defendant.

That he went with said Defendant to see David A. Hall Esq petitioners Counsel, and stated to him that he knew her to be the slave of said Defendant and heard the defendant state to Mr Hall that if she has any sort of claim to be free he would afford him every facility to try it but he was afraid to take her out of jail lest she should run away, three of his servants having already escaped or been stolen, but if Mr Hall would give security that she would not run away or be stolen he would take her home treat her   well and give her every chance to have her claim tried, but if he would not do this he must keep her in jail, at a heavy expense, and to her great injury, and he urged him to have the case tried at once. Mr Hall declined to give the security but said he would try the case as soon as he possibly could. This was about the first of the October Term 1854. Afterwards during the same term, and also before, and during March Term 1855, Deponent at the instance of the Defendant repeatedly saw Mr Hall, and urged him to try the case, and offered him to assist in getting his witnesses for him, and to do anything in his power to get the case ready stating to him that the jail was no place for the girl, and besides it was a heavy expense & loss to her Master. Mr Hall always put deponent off with some evasive reply, and never told him of any single witness that he wanted, or said he would see the colored people, or something of that kind. From all that passed deponent was satisfied that Mr Hall was convinced the petitioner had no right to her freedom, & did not intend to bring the case to trial, or at any rate that he could not find any witnesses to support the tale that had been told him, but did not like to dismiss the case, and he so told the Defendant.

He further says he knows Defendant was pressing and anxious with his counsel to get the cause heard, & she instructed him to offer every facility to the petitioner to get her evidence if she had any, for he was present at at least two interviews between them

He was cognizant of the fact of the sale of the   girl in July last, and from what Defendant then said, and during his interviews[?] with him before he is fully satisfied that Defendant was ignorant of any law, or rule, or usage which required him to keep the petitioner here, and she was kept in jail by him for his own security and not for because he understood was required to have her at the trial.

Sworn to in open court this 17 January 1856
Test Jno. A Smith clk