Robert Thomas v. Henry Pile. John Swann's Answers to Defendant's Interrogatories


Robert Thomas
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.



filed 31. Octo. 1794



John Swann's [strikethrough] Deposition

No. 24