Sarah v. Michael Halton
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Superior CourtSuperior Court
Northern Circuit
Michael Hattan

SarahSarah

And the said Defendant by
RR Pettibone PettiboneR Pettibone his Attorney comes and defends
the wrong of injury when and as
to the assaulting beating bruising ill
treating and imprisoning and keeping
in prison the said Plaintiff as in her
said declaration mentioned the said
Defendant saith that the said Plaintiff
ought not to have or maintain her
aforesaid action thereof against him
because he says that before and at the
said time when in the said
mentioned, to wit, at the plan of within
the jurisdiction aforesaid the said Plain-
tiff was and still is the slave of him the said
Defendant whereupon the said Defendant
at the said time when he did beat
imprison & retain in prison the said
Plaintiff so being the slave of him the
said Defendant as he lawfully might
do which are the same
trespass whereof the said Plaintiff
hath above thereof complained against
him and this he is ready to verify-
whereupon he prays Judgement

RR Pettibone PettiboneR Pettibone atty


for Deft.