1. This note of referral was almost certainly written in 1780, not only because it was so docketed but also because that year was the only one during Jefferson’s governorship of Virginia when Griffin and JM were together in Congress.

2. Possibly the letter of 19 March from Jefferson to Washington (Boyd, Papers of Jefferson description begins Julian P. Boyd et al., eds., The Papers of Thomas Jefferson (16 vols. to date; Princeton, N.J., 1950——). description ends , III, 321).

3. Cyrus Griffin (1748–1810), a delegate of Virginia in Congress, 1778–1780; a member of Congress’ Court of Appeals in Cases of Capture, 1780–1787; president of Congress, 1788–1789; and judge of the United States District Court of Virginia, 1789–1810.