Charlotte v. Henry Clay. James Condon's Answers to Interrogatories


State of Tennessee
Davidson County

Pursuant to the annexed Commission directed to us by John P. Erwin & William Carroll, & having first taken & subscribed the oath thereto annexed, we caused to come before us in the Town of Nashville at the office of John P. Erwin Wilkins Tannehill in said Town, on the 26th day of October 1829. James Condon of lawful age and sound mind, a witness in behalf of the Defendant and having first duly sworn the said James Condon on the Holy Evangelist of Almighty God, the truth to speak touching his knowledge or remembrance of & concerning said cause depending in the Circuit Court for the County of Washington in the district of Columbia, between Negro Lotty for herself & Children petitioner for freedom, and Henry Clay defendant. said James Condon did then & there depose & say. — vz — to the several interrogatories annexed, marked no. 1. 2. 3. 4. 5. 6, said James Condon made the answers appended thereto, with like numbers, his name in his own proper hand writing being thereto signed.

Interrogatories to be put to James Conden a witness to be examined on the part of the Defendant in a cause now pending in the Circuit Court of the United States for the District of Columbia and County of Washington, in which negro Lotty for herself and children is petitioner for freedom, and Henry Clay is Defendant.

1. interrog. Did you sell, and if yea, when and at what price, a negro woman named Lotty or Charlotte to Henry Clay the Defendant in this case.

2. Where was she born, when, from, and to what place was she removed.

3. Was she born a slave, and if so, did she so continue until you sold her.

4. Was her mother free, and if so, when and how did she become free.

5. Have you any interest in the result of this controversy, and if not, how have you become disinterested

6. State all you know concerning Lotty.

Geo: W. Dawson
Defts Atty.

Copy Test. W. Brent, Clk


Answer to 1st Interrogatory.
I did sell a negro woman named Charlotte, or Lotty, to Henry Clay, some time in the year 1806 for $450.

Answer to 2nd. I cannot say positively but think Lotty was born in 1787. I bought her from Daniel Parker of Dorchester County Maryland, in the year 1796 or 7, at which time her master said she was nine years old. I removed her to Lexington Ky. in the year 1805.

Answer 3d. I bought Lotty as a slave & held her as such until 1806, when I sold her to Henry Clay

Answer 4th. Lotty or Charlotte's mother was free at the time I purchased her (Lotty) she was emancipated by her husband one George Stanly who bought her from her master Daniel Parker, for that purpose, as I am informed & believe.

Answer 5th. I am not interested in the event of this suit, because I have in my possession & have accepted from Henry Clay a full discharged from all manner of liability to him on account of said Negro Lotty.

Answer 6. Lotty's mother often called to see her at my home in Maryland, & never pretended that she was or should be free, nor did I ever hear any one else say so, until I heard of this suit. & further deponent saith not

Jas. Condon

We John P. Erwin & William Carroll, the Commissioners named in the annexed Commission, do hereby Certify, that we have taken the deposition of James Condon in the manner stated in the Caption and no other witness being produced on either the part of Plf or defendant, we have proceeded to close[?] sd. commissn[?]


We further Certify, that the deposition of James Codon was taken down by John P. Erwin one of the Commissioners & was distinctly read over to the sd Condon in presence of both of the Commissioners & signed & sworn to in our presence, by said James Condon, and that said Commission under which we acted in taking the same was kept open from day to day for the reception of testimony in behalf of either party & none other being produced, is closed this 6 day of November 1829. Given under one hand & seal, this day above named, vz 6 November 1829.

John P Erwin (seal)
Wm Carroll (seal)



Deposition of J. Condon

The Judges of the Circuit Court of the United States for the District of Columbia & County of Washington
Wm Brent Clk
Washington City

Opened in open Court & filed 17th Decr. 1829

Sealed up & deposited in the post office at Washington after [strikethrough] it was taken without being out of our possession.

Wm Carroll

John P. Erwin