Coleman Duncan vs. Jonathan Duncan
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GilbertGilbert mentioned in the declaration, a black man, who
had always, until at and after said sale been claimed
as a slave and actually held in bondage as a slave
and said plaintiff saith that at the time of said sale he said
plaintiff there so claiming & possessing said GilbertGilbert , the said defendant
offered to purchase said plaintiffs controverted right &
interest in said GilbertGilbert , for the purpose of securing the
freedom of said GilbertGilbert , who claimed then & before to be en-
titled to his freedom: and that thereupon said plaintiff
sold to said defendant all his right and interest in
said GilbertGilbert as he lawfully might do: & this he is
ready to verify; wherefore he prays judgment & c.

And as to the plea of said defendant fourthly
above pleaded said plaintiff saith that said GilbertGilbert in
the plea mentioned who was a black man had always been claimed as a slave
and had always been actually held in bondage as a slave
until at and after the sale of all plaintiffs right in him
as herein stated: and that the said plaintiff at the time of
said sale, claiming & possessing said GilbertGilbert as his slave, and the
said GilbertGilbert then claiming to be entitled to his freedom,
he the said defendant then & there, to wit at the time of
said sale, at said County of St. LouisCounty of St Louis, offered to purchase
from the said plaintiff, his said plaintiffs, controverted
interest in said GilbertGilbert ; whereupon said plaintiff
in of a hundred dollars and of the ma-
king of said did declaration, did sell & transfer to
said defendant, the purpose of securing the freedom
of said GilbertGilbert , all such right and interest as he
said plaintiff had in said GilbertGilbert as he lawfully
might do. And this he is ready to verify, wherefore
he pray, judgement &c.

J SpaldingJ Spalding
atty for plff