Summary: Samuel M. Williams's deposition concerning loss of horses and responsibility therefore. Judicial procedure.
In the month of August 1822 I was employed by Mr Jn° Hanna
and Israel Massey in La Bahia as an interpreter to assist them in
their business during the time of my being with them Mr Freeman
Pettus came there on business with Mr. Hanna, and previous to his
departure Mr. Hanna requested him to call (on his way home) at
Judge Cummins's and take possession of a number of Horses and
Mules that were there belonging to sd Hanna, employ a person to
assist him and drive them from there to Mr. Pettus's Brother on the
San Jasinto w[h]ere they were to be taken care of until Mr. Hanna
would call for them on his way to the United States: I never heard
Mr Hanna say to the contrary and believed of course the Horses and
mules were considered at his risk Mr Pettus acting only as the
friend of Mr Hanna and Mr H paying all expenses, on the way as
I was afterwards informed the Cavellada Stampeded and a part of
the horses and mules were not recovered, still I heard nothing said
of Mr Pettus being considered liable for the accident until I was
informed by Mr Hanna that he had received a letter from Mr Pettus
informing him of the accident and that Mr H. should loose nothing
by it, (or words to that amount) Of the number of those Horses
and Mules their were ten that had been allotted by Mr Hanna for
the payment of some Coffee sugar and rice that belonged to Mr
Manifee of Alabama which property Hanna and Massey had in
their possession and sold for their benefit previous to the departure
of Mr Hanna for United States he requested me as I was
knowing to the circumstances of the stampede etc. to give him a certificate
that to the best of my knowledge the mules allotted for Mr Manifee
were in the Cavellada that stampeded and that the whole of the
Cavellada had never been recovered and that Mr Manifee as part
owner must bear part of the loss. Mr Pettus while in Labahia was
at some expense for board provisions for his return and I believe some
little money Mr Hanna let him have the amt of the whole was to the
best of my recollection between forty and forty five Dollars which
sum was considered as to appear against Mr Pettus's charge for
attending to the transportation of the Cavellada. The
aforementioned Horses and Mules I know were considered by Mr Hanna
(with the exception of three or four mules) of an indifferent
quality. Mr Hanna having told me that the person with whom he
traded Mr David Price of Labahia had cheated him in the quality
of the animals having delivered those of an indifferent quality: I
was afterwards informed by Mr Price that he had not given Horses
and Mules of good quality owing to Mr Hanna's taking him in, in
the price of the goods given in payment for them.
In the month of February I was at Mr Groces' place on the Brasos
when Mr Massey came there and informed Mr G. he was in possession
of a note given by Mr William Pettus which he wished him to buy or
he Massey would attach a Negro and sell it to Mr Groce, Mr G.
informed Mr Massey that he had once had a Brother of Mr Pettus's
living with him and that there had been a difference between them
and he was fearful that Mr William Pettus would think that Mr
Groce in purchasing the note or negro acted from feelings of
private animosity and declined having anything to do with it. Mr
Massey staid at Mr Groce's two days and nights endeavoring to
induce Mr G. to trade with him. Mr Groce declined and Massey then
said he would go to the alcalde and get out an attachment. Mr
Groce advised him not and told [him] he believed he would be able to
arrange it without sueing.