Robert Thomas v. Henry Pile. Walter Hanson's Answers to Interrogatories


Robert Thomas
Henry Pile

Petition for freedom in the General Court.

Petitioners Interrogatories

1. Do you know the parties in this suit, and how long have you known them?

2. Do you know the mother of the petitioner, and how long have you known her?

3. Do you know the grandmother of the petitioner, & how long did you know her?

4. Did you know Betty Mingoe a mulatto woman who formerly lived with Mrs. Pile, mother of the defendant, if yea, when & how long did you know her, and do you know or have you heard, and from whom, and when, that Betty Mingoe was a descended from a white woman or a freewoman? Relate your knowledge fully and freely.

G. Duvall for Pet.


Robert Thomas
Henry Pile

Petition for Freedom in the General Court.

Defendants Interrogatories

1. Have you been acquainted with Thomas Stone Father of David Stone, David Stone and Catherine Stone wife and relict of Thomas Stone - and how Long - and how far have you lived from Pointon Manor.

2 Did David Stone marry your Sister and how long ago and were you and he acquainted before that marriage took place?

3 Did Samuel Stone son of David Stone Marry your Daughter.

4. Have you been well acquainted with the Stone Family and their Neighbours and how long.

5. Do you know that David Stone Gave to his Son Samuel upon his Marriage any Negroes other than those who now Set up a Claim to Freedom - or have you Generally under   that the whole of them now Claim Title to Freedom?

6 Did you Know Betty Mingo - or any of Descendents - and were they held as Slaves and by whom and how long.

7 Do you Know or have you heard and when and from whom why the Negroes in question went by the Name of Mingo and from what Sources they took the Name of Thomas.

8. What is the General Characters of Margaret Reeder Sarah Fowke Mary Stone Mary McCoy Anna Thompson Richard Robin Reeder

9. And of Charles Ray and Thomas Webster?

10 Did you Ever Know or hear of Mary Curtis - Tell her character?

11 Do you Know of Any ancient person Except the above mentioned (to whose charactors you are Depose) who would be likely to Know the Events that hapned in the Stone Family   or their Neighbourhood?


3 sid


Defendants Interrogatories to Walter Hanson

Walter Hanson Esqr

Filed 31st Octobr 1796


Charles County Sct

On this day to wit the 13th day of September 1794 Walter Hanson came before me and was Examined on his oath touching the petition of Robert Thomas against Henry Pile in the General Court of Maryland as to the Interogatories on behalf of the Plaintiff to depose and Say to the first that he knows of no person by the name of Robert Thomas as to Henry Pile: if he be the Gentleman that is a Catholic Priest I have seen him several times but no particular acquaintance with him

As to the 2nd Interogatory he knows nothing of the mother of the Petitioner

In Answer the Third he knows nothing of the mot grand mother of the Petitioner.

In answer to the fourth the Deponent deposes to know nothing at all of Betty Mingo - nor did he ever to his knowledge hear any thing of her until the petition for freedom was preferrd and further this deponent Saith not

In answer to the first Interogatory taken for the Defendant Henry Pile The Deponent Walter Hanson on his oath declares that he was very well acquainted with Thomas Stone Father of David Stone, with David Stone and Catherine Stone relict of Thomas Stone Moreso[?] that Seventy[?] years ago that he has lived within four miles of Pointon Manor since the year Seventeen hundred and thirty Eight

In answer to the Second Interogatory the deponent Says that David Stone did marry his Sister he Remembers they lived in a Married State in the year 1745 when she died but before her death she had three Children that he was well acquainted with David Stone before that marriage took place

To the third Interogatory he Says Samuel Stone did marry his Daughter.

To the fourth he deposes he has been well acquainted with the Stone family ever Since he was fifteen or Sixteen years old he this deponent being now in his Eighty third year

To the fifth he says that he does not Know David Stone gave to his Son Samuel any negroes other than those who he has been told has Set up a Claim to Freedom he Knows not which of them now Claim a Title to Freedom only from Hearsay

To the Sixth he deposes he know nothing of Betty Mingo or any   any of her Descendants nor whether they were held as Slaves by any person whatever nor does he know why the Negroes in Question went by the Name of Mingo or from what Source they took the name of Thomas

To the Eighth Interogatory he says that the Character of Margaret Reeder Sarah Fowke Mary Stone Mary McCoy Anne Thompson Richard Robin Reeder in his oppinion Stands as fair and unblemished as any persons he Ever was acquainted with.

To the Ninth he says that Charles Ray and Thomas Webster are poor free mulattos but reckond very Honest and Inoffensive persons

To the tenth he says he thinks he has heard of Mary Curtis but knows nothing of her Character

To the Eleventh he says he apprehends that Mr. Richard Barnes William Maconchie and James Mancaster are likely to know the Events that happened in the Stone Family as they are of Long standing and near neighbours and acquaintance And further this deponent Saith not

Walter Hanson

I Certifie that the above deposition of Walter Hanson was taken by me the day and years first above written

James Freeman.


6 sid

Walter Hanson's Deposition

Filed 31st. October 1794


10½ sid

Walter Hanson's. Interrogatories and Deposition.

No. 30


Filed 31st October 1794.