Lydia vs. John Butler
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Superior CourtSuperior Court

John Butter

And the said Defendant
by RR Pettibone PettiboneR Pettibone his attorney comes
and defends the wrong of injury when
and as to the assaultingbeatingbruising
ill treating, and
ing in prison, the said Plaintiff, as in her
said declaration mentioned, the said Defen-
dant saith that the said Plaintiff ought
not to have or maintain her aforesaid
thereof against him because
he says that before and at the said time
when in the said declaration mention
ed, to writ, at the place of within the
Jurisdiction aforesaid, the said Plaintiff
was and still is the slave of him the said
Defendant - wherefore the said Defendant
at the said time when he did beat
imprison and obtain in prison the said
Plaintiff so being the slave of him the
said Defendant as helawfully 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 -

R PettiboneR Pettibone Atty for Deft