Affidavit, 30 November 1840 [Miller et al. v. B. Holladay and W. Holladay]
Samuel Hicks, Affidavit, before S. Otho Williams, , Hancock Co., IL, 30 Nov. 1840, Miller et al. v. B. Holladay and W. Holladay (Hancock Co., IL, Circuit Court 1841); handwriting of S. Otho Williams; signature of Samuel Hicks by his mark; docket and notation by S. Otho Williams, [, Hancock Co., IL], 30 Nov. 1840; three pages; microfilm in Circuit Court case files, 1830–1900, CHL.
Samuel Hicks being first duly sworn deposeth and says that , Joseph Smith Jr and the owners of Steam Boat Nauvoo employed Benjamin Holladay and William Holladay as pilots of said boat to navigate her and that said Benjamin and William agreed to navigate said boat in a skilfull manner and professed to be acquainted with the the Streem said boat was running t◊◊e that said Benjamin and William did not navigate and manage said boat in a Skilfull and pilot like manner but on the Contrary run said boat on Sand bars and rocks out of the usual Channel of the <Said> and as this affiant hereby believes intentionally and with a will to destroy said boat and that said said boat by the unskilfulness and willfull mismanagement thereof is injuredasthisaffiantherebybelieves greatly injured in her hul[l] to wit twelve or thirteen of the bottom timbers of said boat are cracked or split and that said and Joseph Smith Jr and are damaged in this affiant believes in injuries done to said boat in <and> in loss of time in her running the sum of two thousand dollars and that this affiant believes that the benefit of whatever judgement said , Joseph Smith Jr and [p. ]