Winny vs. Phebe Whitesides (alias Pruitt)
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[missing figure]
Phebe Pruit alias

And the said Defendant by
PettibonePettibone her attorney comes & defends the
wrong & injury when &c and as to the
assaulting, beating, bruising, illtreating
& imprisoning the said plaintiff as in her
said declaration mentioned the said
defendant says that the said plaintiff
ought not to have or maintain her afore-
said action thereof against her because
she says that before and at the said
time when go in the said declaration
mentioned to wit at the place & within
the jurisdiction aforesaid the said plaintiff
was & still is the slave of her the said
Defendant. Whereupon the said Defendant
did beat imprison the said plaintiff so
being the slave of her the said defendant
so she lawfully might do; which on the
said said several supposed trespasses whereof the
said plaintiff hath above thereof complained
against her and this she is ready to verify
whereupon he prays judgment -

R PettiboneR Pettibone atty

for deft-