Milly, a black woman, for herself and her two infant children, Eliza and Bob v. Mathias Rose
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MillyMilly vs Mathias RoseRose

And the Said MillyMilly by PettibonePettibone Attorney saith that the Said pleas of the
Said MathiasRoseRose by him above
and the matters & things therein contained in manner & form as the
same one above pleaded & set forth, are
not sufficient in law to bar or preclude her the said MillyMilly from having or main
taining aforesaid action thereof against
him and that she is not bound by the
law of the land to answer the same and
this she is ready to verify Wherefor
for want of a suficient plea in this behalf
she prays judgement

RR Pettibone . PettiboneR Pettibone atty

for plff