The answers of Matthew Kennedy, of Harrison county Ohio, to the annexed interrogatories, taken and reduced to writing in presence of Samuel Skinner a justice of the peace in & for the county of Harrison & state of Ohio at his office in Moorefield in said county of Harrison on the 17th day of April A.D. 1830.

To the first interrogatory of Defendant, Deponent answers, that, as early as the year 1801, or 1802, and from that time, until they were sold to one Gabriel Duvall, which he thinks was in 1805, he knew a black colored man by the name of Thomas Butler, and his wife Sarah, and he understood they were owned by one John Dells, as slaves for life. That he knew a man by the name of Gabriel Duvall, who deponent thinks, was comptroller in some of the departments of the General Government, in the years 1802, 1803, 1804 & 1805

To the second interrogatory of Defendant, deponent answers that, he knew one John Dells, first in the year 1799, who then lived in Montgomery County Maryland, that he afterwards lived in Georgetown, as said deponent thinks from the year 1801 to 1805, that he had Thomas Butler and Sarah his wife under his control as slaves during that time, untill he sold them in the year 1805.

To the third interrogatory of Defendant, Deponent answers, that, when said Dells moved to Georgetown, he was a single man, and boarded at different places. While said deponent knew him in Georgetown, Deponent understood that said Thomas and Sarah were hired out by said Dells in the vicinity of Georgetown. That he frequently saw said Thomas & Sarah with said Dells, and he always treated them at such times, as their master, and they treated him as such.

To the fourth interrogatory of Defendant, Deponant answers, that said Dells lived in Georgetown about four years, from sometime in the year 1801, until sometime in the year 1805. During the time said Deponent knew said Dells in Georgetown, said Dells was in bad health, and was occasionally and alternately employed, except for a part of the years 1802 & 1803, when he kept a Grocery in Deponents house, by one Flout, one Gitzedurner and one William Duvall as a bar-tender and in posting books.

To the fifth interrogatory of Defendant, Deponent answers, that, he knew said Dells when he was a tenant of Mrs Thompson, and when he lived with one Flout, and when he lived with one Christian Gitzedurner. That he was a tenant of this deponent, that he took possession of deponents house, as this deponent understood, when deponent was absent from home in the fall of 1802, Dells was in possession of said house when deponent came home, in the spring of 1803. That this deponent knew said Dells when he lived with William Duvall in the year 1805. Deponent does not recollect of said Dells being engaged with Gitzedurner in a Grocery Store. But that when this deponent settled with Gitzedurner, Dells assisted as this deponent supposed, as Gitzedurner's clerk.

To the sixth interrogatory of Defendant, deponent answers, that, during the years 1801, 1802, 1803 1804 & a part of the year 1805, he frequently saw Thomas & Sarah with said Dells. That they appeared to regard him as their master, and he treated them as his slaves, and Deponent always understood, and believed that said Thomas & Sarah were the slaves for life of said Dells. That Deponent understood said Thomas & Sarah were hired out by said Dells as his slaves in the vicinity of Georgetown, and while deponent knew them appeared to be under the control of Dells. That this deponent was present, with said Dells and said Gabriel Duvall, in the said Gabriel's office in Washington City, which he thinks was in the spring of 1805. Said Dells then proposed in said Deponents presence to sell said Thomas and Sarah and their children, to said Gabriel. Said Dells & Gabriel then agreed upon the terms of sale, if the said Thomas & Sarah, on being consulted should be agreed to the transfer, as both Dells & G. Duvall would not as they said conclude the bargain without the said Thomas & Sarah were willing to be sold to said Gabriel. A short time afterwards said Gabriel came to William Duvall's in Georgetown, where said Dells & Thomas & Sarah were, and in Deponent's presence, asked said Thomas & Sarah if they were willing to be sold to said Gabriel, and the said Thomas & Sarah appeared well agreed to it, and gave their assent with apparent cheerfulness. Whereupon the said Dells & Gabriel concluded the contract, and the said Dells sold the said Thomas & Sarah and their children, most if not all of which were present, to the said Gabriel, as slaves for life. And Deponent has not since, to his knowledge, seen the said Thomas or Sarah or any of their children. And he was afterwards told by said Dells that said Gabriel had paid him the price agreed upon for the said slaves.

To the seventh interrogatory of Defendant, Deponent answers, that, he does not recollect of any thing further than what he has stated in answer to the foregoing interrogatories that he thinks would be of any use to the Defendant. That it is so long since the matters about which he is interrogated happened he may be mistaken as to dates, and the places and order in which the events happened in some instances, but he thinks in no point material, but that he is indifferently situated between the parties, and has endeavored to recollect all that he could, of the facts enquired about, and could any thing further be revived in his memory he would state it without hesitation.

To the first interrogatory of the plaintiffs, Deponent states answers, that he does not know that said Dells moved to the State of Virginia. In the latter part of the year 1805 this deponent was absent from home, and when he returned, said Dells had gone to live in the city of Alexandria. And deponent thinks in that part of the city which is in the District of Columbia. That this deponent was in company with said Dells once for a few hours in Alexandria, while he lived there, that he did not then see said Thomas & Sarah, and did not know of his taking them there with him, and has no recollection of ever seeing said Dells since.

To the second Interrogatory of Plaintiffs, deponent answers, that, his recollection is that at the time said Dells sold said Thomas & Sarah & their children to the said Gabriel Duvall, said Dells was boarding with William Duvall in Georgetown.

To the third interrogatory of Plaintiffs, deponent answers, that, he can state nothing more or further than he has stated in his answers to the sixth interrogatory of the Defendant, and to the second interrogatory of the plaintiffs.

Matthew Kennedy

The State of Ohio Harrison County Ss

(SS) before me Samuel Skinner a justice of the peace in and for said County personally appeared the above named deponent Mathew Kennedy who was examined and made the above answers before me, was by me Sworn to the truth of the same and Subscribed by him in my presence.

Given under my hand and Seal this 17th day of April A.D. 1830

Samuel Skinner Justice of the Peace

Justices fees for taking Deposition 10 cents per hundred for 1080 words $100 Certificate .10 Mathew Kennedy Witness fees $1.68 Clerks fees for certificate & seal .50 $2.18

Kennedy's deposn