Dunky v. Andrew Hay
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And for replication to the plea of the defendant by
him secondly above pleaded she says that by reason of
any thing in that plea alleged she ought not to be barred â
precluded from having â maintaining her action aforesaid,
because she says that at the said time, she was not a
slave, but on the contrary thereof she then was â still is
a free person as in her said declaration is above supposed
and this she of the Country

J. W Foreman