And for a further plea in this behalf the
said John WJohn W Honey and JohnJohn H Gay H GayJohn H Gay against the said plaintiff ought to be
banned from having his action aforesaid against
them herewith they say that at the time when
the said supposed wrongs and trespass above
complained of, are alleged to have him committed,
by the said defendants, the said plaintiff was,
and still is a slave, to wit at the CountyCounty of St Louis ofCounty of St Louis StCounty of St Louis.
LouisCounty of St Louis aforesaid, without this, that the said
plaintiff, at the said time when hereby a
freeman, as in and by his said declaration
is above supposed, and of this they put themselves
upon the Country.
Archibald GambleArchibald Gamble Clerk
E. BatesEdward Bates