And for a further plea in this behalf the said
defendant says that the said Lemman ought
not to have & maintain her action aforesaid against
him, because he says that at the said time when
&c, the said Lemman was a slave, without
that she Lemman was at the said time a
free person, in mannerand form as the said
Lemman has above in her declaration
supposed, and of this he puts himself upon the
county