Dorinda, a free woman of Colour vs. John Simonds, Jr.
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And for further plea in this behalf the
said defendant says that the said plaintiffs
to have or maintain her action
aforesaid thereof against him because
he says that she the said plaintiff
before and at the time of the commence
ment of this was and is

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a slave and this he is ready to verify
wherefore he prays judgment &c

GeyerGeyer for defs