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please to take notice that on the twenty second day of this instant ([court] October) at the house of James Sydner in Richmond County Virginia I shall proceed to take the deposition of Elizabeth Daniel Richard Jasper and others to be read as evidence in a [suit] now depending in Montgomery County Court in which Rachel Viney & her children [paupen] are plaintiffs and I am Defendant which [suit] is brought to recover their freedom and if all the said depositions be not taken on that day I shall continue on taking from day to day until all are taken when and where you may attend to cross examine the witness if you think proper

To Mr John Chapman attorney for said Rachel Viney & her children & to Rachel Viney & to Hannah [Mark] Jupiter & Santy [afin] Abby Solomon & Joe her children

Isaac Patton for Henry Patton [seu] October the 9th 1813