Jonathan and Gilbert, men of color v. Coleman Duncan, Edward Tract, and Charles Wahrendorff
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on the twenty eighth of June in the same year
James DuncanJames Duncan the brother of ColemanColeman , called on
saidWahrendorffWahrendorff & borrowed on the the faith of said
instrument a sum of money & pledged the said
instrument or bond of Jonathan & Gilbert for the
repayment of the same & that there is now due
from said DuncanDuncan to these defendants for which said bond is
pledged, the sum of one hundred dollars: and that said defendants have been notified that the balance
due on said Bond, has been transferred to James
S. Thomas and these defendants charge that there
was no nor fraud in said transactions, alledging that they were not of any that the
purchase of Gilbert's freedom was in their belief
the result of a a dispute between the master and
his have, which was compromised fairly at what
they understand to be an underprice for the slave
the saidGilbert & Jonathan his brother choosing rath-
er to pay the sum of four hundred dollars, than
to abide the result, & pay the expenses, of a tedious
suit: and to that purport, the said JonathanJonathan
expressed himself to the defendant WahrendorffWahrendorff .
The defendants further say that within a week
after said bond was put into the defendant's
hands to secure said hundred dollars, said Jona-
than was notified of such fact & transfer at
which time be made no objection to paying the
same. The defendants further say that said Tracy during all said transactions was absent from
St. LouisSt Louis & knows nothing except from hearsay
& so makes the above statements. And they suppose that
the instruments copies of which are made exhibits in the Bill
of complaint were executed & that said copies are correct
but do not know & therefore do not admit it They

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believe said ColemanColeman is not a resident of MissouriMissouri, but
do not know whether he is insolvent or not but be-
lieve & charge the the fact so to be that he is not in-
solvent.Nor do these defendants know whether said
GilbertGilbert could have obtained his freedom from said Cole-
man by suit, but believe & charge that both Jona-
than & GilbertGilbert were doubtful of the event, & chose
rather than try the experiment of a suit & pay the
expense & submit to the delay, to compromise the claim
to freedom in the manner aforesaid: and then de--
fendants deny any participation in the transactions
detailed in said Bill of Complaint other than as
above stated: without that that there is any other
matter or thing material or necessary for this defendant
to make answer unto and not herein and hereby
will and sufficiently answered unto, confessed or avoided
traversed or denied, is true,, all which matters and things
these defendants Tracy & Wahrendorff are ready to aver
and prove as this honorable Court shall direct and
award & humbly prays to be hence with their
reasonable costs & changes in their behalf most wrongfully sustained

J SpaldingJ Spalding


for Tracy &

Wahrendorff