Seth E. Beedy Deposition

Catharine Brown's attorneys deposed two white men who were on the train with Brown and witnessed her expulsion from the cars in Alexandria. Both lived in Maine and were deposed in December 1869. Seth Beedy was traveling with Benjamin Hinds, who knew and recognized "Kate" Brown. Beedy testified, "she was ejected by violence and that alone."

In the Supreme Court of the District of Columbia
Catharine Brown
vs
The Washington, Alexandria and Georgetown Railroad Company
At Law No. 4582

Interrogatories to be administered to Seth E. Beedy of Augusta in the state of Maine, a witness to be produced, sworn and examined as a witness on the part and behalf of the plaintiff in the above entitled action, by virtue of a commission to be hereto annexed before Gardiner C. Vose, Esq. of Augusta, state of Maine, the Commissioner therein named:

First Interrogatory. — What is your name, age, occupation and place of residence?

Second Interrogatory. — Where were you residing or staying, during the month of February, 1868? and what was your occupation or employment?

Third Interrogatory. — Do you know the plaintiff, Catharine Brown and if so how long have you known her; and do you know the location of the Washington, Alexandria and Georgetown railroad?

Fourth Interrogatory. — Did you or not pass over said railroad in February, 1868, and if so on what day or days, and where from and where to, and did you see the plaintiff

on or near the train of said road?

Fifth Interrogatory. — If in answer to the last interrogatory you say you did see the plaintiff on or near the train of said road, state when, where, and whether you witnessed any difficulty or occurrence between her and any other person or persons, and if so, what the difficulty or occurrence was, who were parties thereto, besides the plaintiff, and in what capacity they were acting? State fully and particularly.

Sixth Interrogatory. — If you state that you witnessed any such difficulty as is required of in the last above interrogatory, state whether or not the plaintiff was injured thereby, if you know, and in what manner and to what extent?

Seventh Interrogatory. — State if you know, whether the plaintiff had a ticket over the road of the defendant, and if so what was its character and contents or purport?

Lastly Do you know any other matter or thing touching the matter for which this action is brought? If yea, state the same fully as if particularly interrogated thereto.

Geo. Burgess and S. R. Bond Pltffs attys

I Seth E. Beedy of the City of Augusta in the County of Kennebec and State of Maine of lawful age on oath depose and say in answer to the following interrogatories' as follows — viz —

In answer to the first interrogatory said Deponent says — My name is Seth E. Beedy — I am thirty—one years of age — I reside in Augusta, Maine.

In answer to the second interrogatory said Deponent says — In the month of February AD 1868 I was residing in Washington in the District of Columbia.

In answer to the third interrogatory said Deponent says I am acquainted with the Ptaff Catharine Brown and have known her since February AD 1868 — I do know the location of the Washington Alexandria and Georgetown Railroad —

In answer to the fourth interrogatory said Deponent says — I did pass over said road on Feby 8th AD 1868 — I am going from Washington to

Alexandria and return — Saw the Plaintiff Catharine Brown on said train on said eighth day of February AD 1868 and saw her forcibly put off said train by the conductor and a person wearing the badge of a policeman — this policeman was at this time acting as an employee of said road —

In answer to the fifth interrogatory said Deponent says — I saw the Plaintiff on Feby 8th AD 1868 at Alexandria, Virginia — I was present and witnessed the difficulty between her and the conductor and policeman before referred to —

While seated in the car at Alexandria and going to Washington I noticed a disturbance in the car next back of the one in which I was — I saw opposition made by the conductor of said train to the Plaintiff entering said train —

In answer to the sixth question said Deponent says — I don't know how much the Ptff

was injured but she was violently pulled from the train by the conductor who was the man who took the tickets —

In answer to the seventh question said Deponent says — When the Plaintiff Catharine Brown was ejected from the cars she had a ticket Washington to Alexandria and return —

In answer to the last interrogatory said Deponent says —

On the eight day of February AD 1868 I went to Alexandria, Virginia. After I had taken my seat in the cars for Washington on my return from Alexandria I noticed a disturbance and stepped to the end of the car next to the one in which I was — I then saw a lady and a policeman or a person having a badge on his coat having hold of the Ptff and he seemed to be trying to prevent her from entering the cars —

The Plaintiff at the time of the trouble was inside the car about two feet from the door — The policeman was on the threshold of the door and the Ptff beyond him in the car — Then another person came up and they took hold of her and forcibly brought her from the car where she was standing onto the platform and from said platform to the sidewalk —

I then saw the plaintiff point to the Policeman and say I will have satisfaction for this abuse —

Mr. Hinds who was with me then took the lady and went with her to the forward car —

I cannot state exactly the force used in ejecting Ptff from the cars but she was ejected by violence and that done — As she was put out of the door she came against the railing of the car and the policeman had his arms around her and the conductor was pushing her forward and breaking her hands from the railing — finally she was thrust from the platform.

When we got out of the cars on Madison Avenue I noticed that the Plaintiff had her arm bandaged and that she was walking lame —

Mr. Hinds was present at that time— After the Plaintiff had been ejected from the car I stepped forward to the man who wore the badge and asked him if she had paid her fare —

He said she had a ticket — I heard persons on the sidewalk saying that car was for white persons and niggers had no right there — that they should go forward —

I know of no facts in relation to the matter except those already stated —

Dcked at Augusta this thirty—first day of December AD 1869
Seth E. Beedy