Negress Sarah vs George Kirby Executor of John B Kirby

Petition for Freedom in the Circuit Court of the District of Columbia for Washington County

The Deposition of Hanson Harding witness of full age named and produced on the part of the above named Defendant taken upon the following Interrogatories also furnished by the sd Defendant

1st Interrogatory - Are you or not interested in the event of the suit depending between the above named parties

2nd Interrogatory - Did you know Mrs Kirby of Kentucky late of the State of Maryland, wife of John Baptist Kirby of the District of Columbia, did you attend her during her last illness is she dead and when did she die

3rd Interrogatory. Do you know any thing material to either party in the above if you do state it

The answer of Hanson Harding the witness before named to the foregoing interrogatories

To the first Interrogatory he answers & says I am not

To the second Interogatory he answers & says I did know her and and was with her during her last ilness and saw her die she died on the 1st day of June Eighteen hundred and twenty eight

To the 3rd Interrogatory answers and says I know nothing

H Harding

Negress Sarah vs George Kirby Executor of John B Kirby

Circuit Court of the District of Columbia Washington County

I James C Burnett, Judge of the County Court for the County of Shelby in the State of Kentucky. The same being a court of Law & Record not being of Counsel or Attorney for either of the parties mentioned in the proceeding caption, nor in any manner interested in the event of the suit depending between them, do certify that I did cause Hanson Harding, a witness named and produced to me on the part of the above named Defendant to come before me at the office of James M Bullock in the Town of Shelbyville in the County of Shelby & State of Kentucky on the 19th day of october in the year eighteen hundred & thirty six, and have taken the Deposition of said Witness on Interrogatories furnished by the said Defendant which said Interrogatories and the Answers of the said Witness to the same are hereunto annexed and enclosed. I certify that before the taking of the said Depositions the said Witness was by me duly examined cautioned & sworn to testify the whole truth in the matter depending between the sd parties in the said suit or action that at the time of taking said deposition the said Witness was in Shelbyville in the State of Kentucky and miles from the City of Washington in the District of Columbia & that there so being at the Distance of more than one hundred miles from the said place of trial was the cause and reason of taking this said Deposition. I further certify that the said Deposition was reduced to writing by the person whose Deposition it purports to be in my presence and the same having been reduced to writing was subscribed in my presence by the said Witness. That I did not give or serve or cause to be given or served on the said Plaintiff or any attorney or Agent of hers any notice of the time and place of taking the said Deposition & to be present & to put Interrogatories if she should see fit, because the said Plantiff or any Attorney or Agent of hers was not within one hundred miles of the Town of Shelbyville the place where said Deposition was taken to my knowledge.

In Testimony whereupon I have hereunto set my hand & affixed my seal this the 19th day of October in the year 1836 & do return the said Deposition & Interrogatories with this my certificate to the Honorable the Judges of the Circuit Court of the District of Columbia for Washington County

Ja C Burnett (seal P J S Cy)

Fee 3.00 5.00 paid

State of Kentucky Shelby County Sct.

I James S Whitaker clerk of the County Court for said County do certify that James C Burnett Esquire before whom the foregoing Deposition was taken and who hath Subscribed his name to the Certificate thereof now is and was at the time of dating the same the Senior and presiding Justice of the Shelby County Court And that full faith is and ought to be given to all his acts as such In Testimony whereof I have hereunto Subscribed my name and affixed the Seal of my said County this 19th day of October 1836

Ja S. Whitaker Clerk Shelby County

Fee paid $2 J S Whitaker Ck & C

My Fee for attending to the taking of all the Depositions $20 has been received.

Jas M Bullock atty