and to fulfill, perfect and bring the same to effect, he the said Richard Thomas as such traitor as aforesaid during the said war, insurrection and rebellion to with, on the day and yer aforesaid at the district aforesaid, and within the jurisdiction of this court and of the circuit court of the United States for the fourth circuit in and for the Maryland district, with a great multitude of persons (whose names to the jurors aforesaid are at present unknown) to the number of thirty persons and upward, armed and arrayed in a warlike manner- that is to say with guns, pistols, swords, bowie knives and other warlike weapons-being then and there maliciously, unlawfully and traitorously assembled and gathered together, did falsely and traitorously join and assemble themselves together against the United States of America, and then and there with force and arms did falsely and traitorously and in a hostile and warlike manner array and dispose themselves against the United States of America; and on the said 28th day of June, in the year of our Lord 1861, at the district aforesaid and within the jurisdiction of this court and of the circuit court of the United States for the fourth circuit in and for the Maryland district and in pursuance of such their traitorous intentions aforesaid, he the said Richard Thomas, with the said persons so as aforesaid traitorously assembled, armed and arrayed in manner aforesaid, most wickedly, maliciously and traitorously did ordain, prepare and levy war against the United States of America.

And further to perfect, fulfil and bring to effect the said treason of him the said Richard Thomas, he the said Richard Thomas being such false traitors as aforesaid, with divers other false traitors to the number of twenty and upward (whose names to the jurors aforesaid are unknown), on the day and year aforesaid at the district aforesaid, with force and arms seize, take, capture and convey away a certain steamboat then and there being called the Saint Nicholas, together with a valuable cargo of merchandise then and there being on board of the said steam-boat, said cargo being then and there the property of loyal citizens of the United States (whose names to the jurors aforesaid are unknown), with the intent that the said steamer and cargo should be used and appropriated toward carrying on the war, insurrection and rebellion so as aforesaid levied and carried on against the United States of America, and did carry and deliver said steam-boat and cargo to the said evil-disposed persons and bodies of men so as aforesaid levying war and exciting insurrection and rebellion against the United States of America contrary to the duty of the allegiance and fidelity of the said Richard Thomas against the form of the statue in such case made and provided and against the peace, government and dignity of the United States of America.

And the jurors aforesaid upon their oath and affirmation aforesaid do further present that on the 28th day of June, in the year of our Lord 1861, and long before and continually thence hitherto an open and public insurrection, rebellion and war was and yet is prosecuted, levied and carried on against the United States of America by divers large bodies of evil-disposed persons, citizens of the United States of America and residing therein, and owing allegiance to the United States of America, contriving and with all their strength intending traitorously to break and disturb the peace and common tranquality of the United States of America, and to stir up, move and excite insurrection and rebellion and to levy war against the United States of America, and to subvert, alter and overthrow by force of arms the Government established in the United States of America.