And the said Green CrowderGreen Crowder by GambleArchibald Gamble his attor
ney comes and defends the force and injury when and
says he is not guilty of the said supposed wrongs in
the said declaration mentioned in mannerand 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 a action
thereof against him because he says that the
said plaintiff at the time when to the the said
plaintiff was a slave without this that at the time
when he was free as in her said declaration
is above supposed and this he is ready to verify
wherefore he pays judgement &c