Robert Thomas v. Henry Pile. Henry Smith's Answers to Interrogatories


Washington County & State of Maryland.

April 9th 1794.

This day came before me Henry Smith about forty four years of age after being duly sworn on the holy Evangelist of Almighty God, deposeth & saith as follows.

in answer to the 1st Interrogatory.

I know not the petitioner by the name of Robert Thomas; nor do I know of the petitioning family by the name of Thomas, nor have I heard it untill I received Mr. Raphel Boarman's letter bearing date the 7th day of November 1792. I knew Henry Pile (son of Elizabeth Pile late of Charles County deceased) when we were children, previous to his going to the Colledge; but have never seen him since to the best of my knowledge.

2. I knew Judah when she belonged to the aforsd. Elizabeth Pile, ever since I can remember going to see my Aunt, the aforesd. Elizabeth Pile, when I was a child. The above said Judah I believe to be a daughter of Sophia.

3. I knew Sophia, ever since I can remember going to see the aforesd. Elizabeth Pile, whome she belonged to.

4. I knew Betty Mingo the mother of Sophia ever since I can remember going to see the aforesd. Elizabeth Pile, whome she belonged to; her complexion was a lite yellow; I believe she died within these twenty four years; but How long, I can't justly remember, as she died within the life time of the aforesd. Elizabeth Pile; as too the descent of the aforesd. Betty Mingo the mother of Sophia, I know nothing of whether white or black.


5. I have heard my father Basil Smith (late of Charles County deceased to the best of my knowledges say, that if the Butler breed got free, the Mingo's would of course, as they were upon the same footing. I know nothing of any such Elizabeth Thomas; being I suppose long before my time, if she was the mother of Betty Mingo aforesaid.

6. Nothing more have I any knowledges of, than what's contained in my fifth answer.

7. I never heard of any of the above family, known or called by the Sir name of Thomas to my knowledge, till the aforesd. letter from Mr Raphael Boarman.

8. I know nor heard of nothing more that I can recollect to the best of my knowledges to the benifit of the petitioner in the present suit.

And further this deponant saith not.

Sworn before Wm Good

5: sed

Henry Smith

No. 23


Filed 31. Oct. 1794