Affidavit, 30 November 1840 [Miller et al. v. B. Holladay and W. Holladay]

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Document Transcript

State of Illinois) ss [scilicet]
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 injured as this affiant hereby believes 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. [1]] may recover against said Benjamin and William will be lost unless they are held to special bail affiant further states that said Benjamin and William were thirty two day in making a trip from in the State of to St Peters and back to in this when the trip should have been performed in eleven or twelve days and that said Joseph Smith Jr and are about to Commence an action on the case to recover damages for the above causes
X <​his mark​> Samuel Hicks
Sworn to & Subscribed before me at my office in this 30th Day of November AD 1840
S Otho Williams Clerk [p. [2]]
Joseph Smith Jr et al vs Benjamin Holladay & William Holladay
Filed Nov 30th 1840
S Otho Williams Clerk
285 [p. [3]]


  1. new scribe logo

    Mark of Samuel Hicks.  

  2. new scribe logo

    Docket and notation in handwriting of S. Otho Williams.