Robert Thomas v. Henry Pile. Sarah Boarman's Answers to Interrogatories
Petitioners Interrogatories to Sarah Boarman aged forty one years who on oath gave the following answers annexed thereto. These Interrogatories are signed by G. Duvall for Complainant, viz.
1st Do you know the parties to this Suit, and how long have you known them?
Answer, I know Mr Pile one of the parties to this Suit and have known him about ten years; I also know Robert the petitioner, and have known him from his childhood.
2nd Do you know the Mother of the petitioner, and how long have you known her?
Answer, I know the Mother of the petitioner, and have known her about thirty years.
3rd Do you know the grandmother of the petitioner, and how long have you known her?
Answer, I know the grandmother of the petitioner, and have known her about thirty years.
4th Did you know Betty Mingoe a mulatto woman, who formerly lived with Mrs Pile mother to the Defendant; if yea, when and how long did you know her: and did you know or have you heard, and from whom and when, that Betty Mingo was descended from a White Woman? relate your knowledge freely & fully.
Answer, I knew her about thirty years ago when I lived with Aunt Pile. and during the time I lived there I one day asked her Aunt Pile whether Betty Mingoes mother was a White woman and her answer was "Betty says so."
Sarah Boarman
Charles County Ss. October 15th 1794 personally appeared before me one of the Justices of the Peace for said County Sarah Boarman, and on oath, gave the several answers annexed to the above Interrogatories.
Walter Dyson
Sarah Boarman aged forty one years being duly sworn, made the several answers annexed to the following interrogatories, vizt.
1st Mr Pile asked Mrs Boarman how long she had known him the said defendant?
Ansrs about then years.
2nd How long have you known the petitioner?
Ansrs I have known him ever sine he was a child.
3rd Were he and his ancestors always held and reputed as slaves?
Anrs They were.
4th Did you ever know or hear that they were entitled to their freedom and from whom have you heard?
Ansrs I do not know that they are entitled to their freedom but I have been told so by Leonard Boarman Senr since the institution of the suit.
5th Did you know the defendants mother?
Ansrs I have known her from my infancy.
6th Did you ever hear her say that the petitioners relations were entitled to their freedom?
Ansr I did not.
7th Do you know whether Betty Mingos Mother was a free or white woman or did you ever hear Mrs Pile say that she was?
Ansrs during the time I lived with Mrs Pile I one day asked her whether Betty Mingoes Moether was a white woman "her answer was" "Betty says so."
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8th Did you ever hear Mrs Smith or her Daughter Mrs Dorothy Boarman say that the petitioners family were entitled to their freedom?
Ansrs I never did.
Sarah Boarman
Charles County Sst. Sepr 30th 1794.
Personally appearaed before me the subscriber one of the Justices of the Peace for said County Sarah Boarman, and on oath, gave the several answers to the within Interrogtories therto annex'd.
Walter Dyson
Charles County Sst. Sepr 30th 1794 I do hereby certify that both the petitioner and the 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 agreeably to Mr Pile's Notice to the petitioner. In witness whereof I have hereunto set my hand.
Walter Dyson
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Sarah Boarman's Interrogatories and Deposition
No. 31.
Entered
Filed 31s October 1794