Dunky v. Andrew Hay
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AndrewAndrew HayHay
ads
DunkyDunky a woman of color

And the saidAndrewAndrew HayHay by GambleArchibald Gamble his
attorney comes and defends the force and injury
when and says he is not guilty of the said supposed
trespass and injury in the declaration mentioned in
manner and form as the said plaintiff hath
above thereof complained against him and of
this he puts himself upon the Country

And for further plea in this behalf the
said defendant says that the said plaintiff
ought not to have and maintain her aforesaid
action against him because he says that the said
plaintiff is a slave without this that she is free
as in her said declaration is above supposed and
this he is ready to verify wherefore he prays Judgement

And for futher plea in this behalf the said
Defendant says that the said plaintiff ought not to maintain her said action against him because
at the
time of the committing the said supposed griev
ances in the declaration mentioned the said plaintiff was held to
labour in the State of IllinoisIllinois under the laws of said
State of IllinoisIllinois and had escaped into the CountyCounty of Saint Louis
of Saint LouisCounty of Saint Louis aforesaid without this that at the
said time when when the said plaintiff was free as in

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her said declaration is above supposed and this he
is ready to verify wherefore he prays Judgement

H R GambleH R Gamble atto
for Dft

filed August 10th 1831

A GambleArchibald Gamble Clk