O Say Can You See

Petitioners Interrogatories to William Swann (on oath) aged sixty years viz., signed G. Duvall for Petitioner

1st. Do you know the parties to this Suit and how long have you known them?

Answer, I know Robert one of the parties to this Suit, and have known him for these four or five years past.

2nd Do you know the Mother of the petitioner, and how long have you known her?

Answer, I know the Mother of the petitioner, whose name is Judah and have known her about ten or twelve months.

3rd. Do you know the grand mother of the petitioner, and how long did you know her?

Answer, I have never known her until within these five days past.

4th Did you know Betty Mingoe a mulatto woman, who formerly lived with Mrs Pile mother of the Defendant, if yea, when & how long did you know her; and did you know, or have you known, and from where, that Betty Mingoe was descended from a white woman or a free woman? relate your knowledge fully and truly.

Answer, I never knew Betty Mingoe, last I have hear from Mary Curtis when she lived with my father in the capacity of a white servant, that said Betty Mingoe was the Daughter of a white woman.

W Swann

Charles County Sst: October 15th 1794 personally appeared before me one of the Justices of the Peace for said County William Swann, and on oath gave the several answers annexd to the above Interrogatories

Walter Dyson

William Swann, aged sixty years, being duly sworn made the several answers annexed to the following Interrogatories

1t. Do you know the petitioner in this suit & how long, and did you know his ancestors and how long & have they & each of them always been held and reputed as slaves?

Answer. I know the petitioner in this suit and have known him about four or five years, I also know his mother and have known her about the same length of time & they & each of them have always been held & reputed as slaves.

2nd Did you know or have you generally understood that Mary Curtis had a Mulatto Bastard, and who was the reputed father?

Ansr. I have generally understood that Mary Curtis had a Mulatto Bastard, and that a certain mulatto man commonly called Charles Mingo was said to be the father of said Bastard.

3rd Was Charles Mingo the reputed father of said Bastard a slave, to whom, and was he the son of a woman called Betty Mingo, or generally so reputed to be? or was he reputed to be of the same family with the petitioner?

Ansr. Charles Mingo the reputed father of said Bastard was held as a slave by a certain Thomas Jameson of Charles County and I have always understood that he was Brother to the woman called Betty Mingo

4th. Was Mary Curtis sold as a Servant, and to whom, for being the Mother of a Bastard Child? was the said Mary Curtis of a good or bad general Character & reputation?

Ansr. Mary Curtis was sold as a servant by St. Mary's County towit to a certain James Swann of St. Mary's County for bringing a Mulatto Bastard child, and that she served him faithfully; but she was reputed to be a lewd loose woman.

5th. Was Mary Curtis a woman of general good or bad moral character, conduct in life, veracity & integrity, or was she a lewd woman who connected herself with negroes and slaves?

Ansr. Mary Curtis was a woman of general bad moral conduct in life & connected herself with negroes and slaves.

Turn over.

6th. When was Mrs Pile the mother of the defendant born, when did she live at what time did she die & what was her age?

Ansr. Mrs Pile lived and died where the defendant now lives.

7th Where did Mary Curtis reside? did she ever reside in Durham Parish in Charles County; or was she acquainted with the Stone family of Durham Parish as their neighbour?

Ansr. Mary Curtis lived with a certain James Swann of St. Marys County she never lived in Durham Parish in Charles County as I know of or ever heard.

8th. Did Mrs Pile ever live in or was she acquainted with the people of Durham Parish in Charles County? Did she know David Stone or his father Thomas Stone or their Neighbours?

Ansr. Not as I know of

W Swan

Charles County Sst. Septr. 30th 1794.

Personally appeared before me the subscriber a Justice of the peace for said County William Swann and, on oath, gave the several answers to the within Interrogatories thereto annexed.

Walter Dyson

Charles County Sst. Septr. 30th 1794. I do hereby certify that both the petitioner and defendant were present when the within Interrogatories were put and the answers made thereto, and that the same was done between the hours of nine and five oClock agreeably to Mr. Pile's notice to the petitioners. In witness whereof I have hereunto set my hand.

Walter Dyson