Benjamin H. Hinds 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. Benjamin Hinds' testimony was particularly significant because he described in detail the violence he witnessed, and because he knew Brown "since January 1866," perhaps from her work in the U.S. Capitol, and tried to intervene on her behalf.
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 Benjamin H. Hinds, of Augusta in the State of Maine, a witness to be produced, sworn and examined under and by virtue of the annexed commission, before Gardiner C. Vose, Esq., residing in said Augusta, the Commissioner therein named, in a certain action now pending and at issue in the Supreme Court of the District of Columbia, wherein Catharine BrownCatharine Brown is plaintiff and The Washington, Alexandria and Georgetown Railroad Company is defendant, on the part and behalf of said plaintiff.
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 pass over the railroad of the defendant on or about the 8th day of February, 1868, and if yea, from and to which place, and did you see the plaintiff on our near the train of said road; and if so where, under what circumstances, and what called your attention to her? and state whether you witnessed any occurrences or difficulty between her and any other person or persons, at that time, and if so where, who were they and in what capacity were they acting, and what was the difficutly? state fully.
Fifth Interrogatory. — Who was acting as the agent of the defendant on the train at the time, if anyone, and in what capacity, and have you seen him acting in the same capacity since? and what did he do or say in reference to the difficulty, if any?
Sixth Interrogatory. — If you state, in answer to the fourth interrogatory, that you witnessed a difficulty between the defendant, its agents or employees, and the plaintiff, state whether she was injured thereby, and if yea, in what way, to what extent, and what opportunity had you, or have you since had, to judge thereof?
Seventh Interrogatory. — State, if you know, whether or not the plaintiff had a ticket over the road of the defendant, and if so, what was its character and purport?
Lastly. — Do you know any other
matter or thing touching the matters for which this action is brought? if so declare the same fully and at large as if you had been particularly inerrogated thereto.
George Burgess & S R Bond
Pltff's attys
Benj. H. Hinds of Augusta in the County of Kennebec and State of Maine of lawful age having first been sworn to testify to the truth the whole truth and nothing but the truth in relation to the matter for which this Deposition is taken in answer to the foregoing interrogatories deposes and says—
In answer to first interrogatory Deponent says my name is Benj. H. Hinds. I reside in Augusta, Maine. My age is twenty nine years my occupation is Special Agent of the Treasury Department of the United States — In answer to second interrogatory said Deponent says During the month of February 1868 I was residing in Washington.
D. C. I was clerk to the Senate Committee on Public Buildings and Grounds — In answer to third interrogatory said Deponent says I know Catherine Brown the Ptff in the action in which this Deposition is taken and have known her since January 1866.
I do know the location of the Washington Alexandria and Georgetown Rail Road.
In answer to fourth interrogatory said Deponent says I did pass over the Defts road on the eight day of February 1868. I went from Washington to Alexandria - I first saw the Ptff near the train at the Depot at Alexandria as I arrived at the Depot at
Alexandria to take the three o clock train to Washington I observed quite a commotion in and near the cars but paid no particular attention to it at the time but entered the cars and sat down. A gentleman sitting near me remarked that "it was the greatest outrage he had ever seen" or some such expression.
I inquired what the trouble was. He replied that they had just put a colored woman off the train and had injured her in so doing. I then went out of the car and saw the Ptff standing near the train crying. I recognized her and asked her what the trouble was. She answered that they had put her out of the car and injured her severley
I went to the Conductor and asked what it meant. He replied that there was a car in front for colored people and she must go in there if she wanted to ride to Washington. I tried to persuade him to allow her to go in the rear car but without effect. She gave as a reason for not wishing to enter the front car that there were disorderly persons in it and she feared to go in and of my own knowledge I know that there were such disorderly persons in said car.
In answer to the fifth interrogatory said Deponent says. Mr Williams whose name I afterward learned was at the time the Ptff was removed from the train the agent of the Deft's and was then acting
as their conductor upon the train. I have repeatedly seen him since acting in the same capacity.
When I called his attention to the fact of the Ptff having been put off the train he appeared to know all about it and remarked without further explanation on my part as to the difficulty that the front car was for colored people and she must take that if she wished to go to Washington.
In answer to sixth interrogatory said Deponent sayd — I did not witness the ejectment of the Ptff from the cars but saw her immediatley after. She was injured to what extent I do not know
but I do know that she suffered from her injury and was confined to her bed for several weeks.
In answer to seventh interrogatory the Deponent says — I do know that the Ptff had a ticket over the Deft's road from Alexandria to Washington for she showed it to me at the time. Her ticket was what is known as the return ticket.
In answer to the last question the Deponent said I called the attention of the Conductor of Defts road to the condition of the Ptff immediately after I knew the trouble. This man was then acting as Conductor on the train. The Ptff was injured so badly
that I was obliged to assist her in getting into the car at Alexandria and again in getting out at Washington — She was very lame and could only walk with difficulty. Her shoulder was also injured.
