Robert Thomas v. Henry Pile. Cornelius Barber's Answers to Defendant's Interrogatories


The Deposition of Cornelius Barber aged Seventy Eight years being duly summoned and sworn, deposeth & sayeth, and made the following Answers to the several Interrogaries

Robert Thomas
Henry Pile

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 ever since he was a boy, and the Plaintiff also.

2nd. Do you know, or have you heard, and from whom that the Petitioner is descended from a free person & from what Free person, was her name Elisabeth Thomas, or what other name had she.

Answer: That he answer 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 Elizabeth Thomas Great great Grand Mother to the Petitioner

Answer: He did not know her.

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 and freely.

Answer: He knew Elisabeth Eden but never had any Conversation with her on that subject

5th. Has the Petitioner been held in Slavery & 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 sixty years.

6th. Did you know Mary Curtise & of what Country was she and what was her General Character.

Answer. He knew Mary Curtise, and that he only knew she was a foreigner as to her Country, and her Character was that of a bold impudent woman

Turn Over


7th. Did you know that Mary Curtise had a Mullatto Child, and who was the reputed father

Answer, yes he knew Mary Curtise had a Mulatto bastard Child, and that she was sold by St Marys County Court to a Mr. Swann for bringing it, and that Charles Mingo was the Reputed father a Slave to Thomas Jamison of Charles County

Cornelius Barber (seal)

St. Marys County Sct. October the 5th 1793.

I hereby Certifie that 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



Barbers Depn.


filed 31 Octo 1794


Cornelius Barber's Deposition

No. 26.