Coleman Duncan vs. Jonathan Duncan
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And for further plea in this behalf said
defendant says said plaintiff ought not to have
& maintain his said action against him because
he says that said supposed writing obligatory declared on was
made & offered delivered by said defendant to said
plaintiff for & in consideration of the sale of a free
man as a slave made by said plaintiff to said
defendant & for no other consideration whatsoever -
to wit at the time & plan of expecting Said Supposed writing
obligatory and said defendant further says that
said plaintiff at the time of making the sale of
said free man as a slave as aforesaid
that said man which he sold as a
slave as aforesaid was a free man & this
the said defendant is ready to verify wherefore
he prays Judgement to

Bird & Gamble Attys for
Deft