Robert Thomas v. Henry Pile. John Swann's Answers to Defendant's Interrogatories
Robert Thomas
vs
Henry Pile.
The deposition of John Swann aged about seventy years being summoned & sworn deposeth and sayeth, and made the following answers to the Several Interrogatories
Petition for freedom in the General Court Defendants Interrogatories
1st. Do you know the parties, the Petitioner and the defendant in this cause, and how long have you known them.
Answer. He has known the defendant Henry Pile three or four years, and the Plaintiff only about two years
2nd. Do you know, or have you heard, and from whom, that the Petitioner is a descended from a free person, and from what free person was her name Elisabeth Thomas, or what other name had she.
Answer. That he never did know any person by the name of Elisabeth Thomas, and says he does not know that the petitioner descended from a free person
3rd. Did you know Elisabeth Thomas Great Great Grandmother to the petitioner
Answer He did not
4th. Did you know Elisabeth Eden late of St. Marys County, deceased, if so can you recollect ever to have heard her speak of the petitioner, or any, and which of the family of which he is one, relate any Conversation you may have had, or heard from her on the subject fully & freely
Answer He knew Elisabeth Eden but never had any Conversation with her as the Subject
5th Has the Petitioner been held in slavery and reputed a slave were his ancestors reputed to be slaves, and held as such and for what length of time past
Answer. Ever since he knew them which is about forty years
6th. Did you know Mary Curtis and of what Country was she and what was her general Character
Answer He knew Mary Curtis, and that she was as he believes of native of Ireland, & her general character was bad.
7th. Did you know that Mary Curtis had a Mullatto Child and who was the reputed father
Answer. He knew Mary Curtis had a Mulatto Bastard child, and that she was sold by St. Marys County Court to this deponants father, James Swann for bringing it and that Charles Mingo was the reputed father of who was the property of Thomas Jemison of Charles County
Jno Swann (seal)
St. Marys County Sct. October the 5th 1793
I hereby certifie the aforegoing deposition was this day taken before me the Subscriber one of the Justices of the Peace for the County aforesaid in the presence of the Petitioner Robert Thomas
John Cartwright
Jno Swann's Depn.
Thomas
vs
Pile
[illegible]
filed 31. Octo. 1794
4
[strikethrough]
John Swann's [strikethrough] Deposition
No. 24
Entered
