Robert Thomas v. Henry Pile. Deposition of William Swann


Charles County Sct.

William Swann, of Allen's fresh, aged about fifty four or fifty five years Th having being sworn on the holy Evangels of Almighty God deposed. That as near as he can recollect about forty four or forty five years ago, a certain Mary Curtis, whom he supposed to be then near fifty years of age, told him, this deponent "that Charles Mingo and Betty Mingo had as much right to their freedom as she (the said Mary, meaning) had herself; for their mother was as white a woman "as she was" meaning, as this deponent supposes, herself. And this deponent adds that she said Mary Curtis was a very fair woman and had a remarkable good skin[?]. That the said Mary Curtis died about twenty years ago. That she has Known Robert Thomas, the petitioner in the general Court, against Henry Pile, for about five or six years, and that he has also Known Henry Pile for the about same span of time. That the said Robert was reputed to be the slave of the said Henry, and was by him the said Henry held in slavery ever since he has known them the said Henry and the said Robert.

The said William Swann being severally interrogated on the various questions numbered from 1 a 9 both inclusive and contained in a certain paper intitled "The Petitioner's Interrogatories, signed, G Duvall for Petr. and being also examined on each and every of the interrogatories contained in a paper, numbered 1 a 23, inclusive, and signed Philip B. Key for defdts. answered that he knew nothing relative to or concerning the contents of said papers respectively, nor of Robert Thomas or this case, more than is expressed in the above deposition. in confirmation of all which he hath hereunto subscribed his name
W Swan

I do certify that the above deposition was sworn to before me, and that the William Swann the deponent therein named attentively perused[?] it before he subscribed his name and made oath therto. given under my hand at Allen's fresh this twenty first Day of May seventeen hundred and ninety two.

Ben: Contee

And the said William Swann being further sworn on the holy evangily of Almighty God on the twenty fourth day of October seventeen hundred and ninety two, and being asked if he knew Charles and Betty Mingo above mentioned   answers he knew Charles very well, but did not know Betty that he recollects and he saith that the said Mary Curtis knew them very well and he has often heard her talk of them; and he further saith that Charles was a mulatto with long black hair, and he has heard it often said in the neighbourhood that the father of Charles was a Mingo Indian. And he further saith that the said Mary Curtis lived at the house of the deponent's father about fourteen years and was nurse to the deponent. Being asked what was the general Character of Mary Curtis for veracity, answers, he never heard anything against her.

Sworn to before me this 24h Octr. 1792
Jno. Brice

Admitted to be read in evidence.
G. Duvall for petr.
Philip B Key for defdt.

Robert Thomas
Henry Pile

W. Swann.

filed 31. Octo 1794

Wm Swann