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Hannah: Freedom Suit, Arlington County (Part 3 of 3)

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Benjamin Swann a witness for the Deft being duty sworn deposes and saith as follows in his answers to interrogatories proposed to him. 1st. Were you well acquainted with the late Stephen West of this County and also with a mulatto man in his service named Charles Jackson? Ans. I was. and have lived in S West's neighborhood since I was seven years old until this time. I am now forty five years old. 2d. Have you ever heard any thing of a contract between S West & Jackson for the freedom of Jackson's wife or children? Ans. I never did. 3d. Do you or not know what were the terms of Jackson's service with Stephen West? Ans. All I know is that Charles Jackson told me in the year eighteen hundred and seventeen that Stephen West had always hired him from the first time of his service with him for sixty dollars wages a year that he had always been a hireling to Genl West for sixty dollars a year. 4th. [4th question marked out: Have you or not heard Jackson ever say that Stephen West had always paid him wages for his services] 5th. State whatever you have ever heard Jackson say about payments for wages made to him by S West? In ans. I never heard Jackson say any thing about it. 6th. Do you know whether or not the children of Jackson & Rebecca ever were in S West's possession? Ans. Yes they were all the time, from my first recollection of them up to the time of Jackson's death. 7th. Did you know the children of Hannah and Peggy & state whether they were or not always in S West possession up to the

time when he sold them to A P West. Ans. I know them all. they were always S West's possession until he sold them. 8th. Do you or not know whether Hannah & Peggy or their children ever went at large hiring themselves out as free persons. and whether they were or not reported in the neighborhood to be free? Ans. I never knew them to do so. and never heard that any of them were free, but that they were always S West's slaves. Cross examined by Comp'lts 1. Was not Charles Jackson a very great drunkard during the latter years of his life and was he not such about the year eighteen hundred and seventeen? Answer. He was always a drunkard from the time I knew him till the time of his death. Whenever he had money he would always drink. 2. Did not Jackson live on Mr West's farm up to the time of his death. did he not have a house separate from the other negroes and did not his children live with him? Answer. He lived on the place and can say nothing further. 3. Were Jackson's children or his grandchildren ever in Arthur P. West's possession before the death of Stephen West? Answer. By no means - not till after Stephen West's death, to the best of my knowledge. 4. Did Rebecca wife of Jackson die before your recollection? Answer. Yes. Re-examined by Deft. 1st. How often have you heard Jackson say what you state to have heard from him in your answer to the third question put to you by the