Jenny vs. Charles Halton
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Superior CourtSuperior Court
Northern Circuit

April Term 1879.

Charles HattonCharles Hatton

And the said defendant by the
PettibonePettibone his attorney comes & defends the
wrong & injury when and as to the
assaulting, beating, bruising, ill treating,
and imprisoning and keeping in prison
the said plaintiffs, as in his said declaration
mentioned, the said defendant says that
the said plaintiff ought not to have & main
tain his aforesaid action thereof against
him because he says, that before and at
the said him when & in the said decla-
ration mentioned, to writ, at the place &
within the jurisdiction aforesaid the said
plaintiff was and still is the slave of him
the said defendant wherefore the said defen
dant at the said time when did beat, in
prison & detain in prison, the said plaintiff
so being the slaves of him the said defen
dant, as the lawfully might do which
are the same several supposed trespasses
whereof the said plaintiff hath above
thereof complained against him. And
this he is ready to verify. Wherefore
he prays judgment go.

R PettiboneR Pettibone atty
for Deft