Robert Thomas v. Henry Pile. Deposition of William Simms


Charles County Sct. 21 July 1792.

At the Request of Robert Thomas Petitioner for his freedom in the General Court a Revd. Henry Pile, The following Deposition of William Simms, aged aged about Eighty Three years. was Taken. The questions put to him for Plaintiff and Defendant, as Suggested by the Council

and all he knows in the matter

That he knows nothing of the Petitioner or from whom he descended. he has heard by many persons that the Black People Called Mingo had a Right to their freedom and this talk was about the time the Butlers first Contended for their freedom, and have often heard it spoke of since but by What Right they Claimed it so I can't say.

he has seen a black Woman called Peg, belonging John Sewmple in Portobacco, and commonly called Semples Cook.

and further saith not

Willim Sims
his W mark

Charles County Ss. 21 July 1792. I do hereby certifie that William Simms being sworn on the Holy Evangels of Almighty God, that the above deposition contains the Whole Truth, to best of his Knowledge

Sworn Before
Alexr. McPherson

Admitted to be read in Evidence
G. Duvall for Petrs.
Philip B Key for defdt.



William Simms Deposition

18. Entered

filed 31. Octo 1794.