Andrew Dutton, a boy of color, by and through his next friend, Grace Dutton v. John Paca
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And for a further plea in this
behalf the said defendantsays that the plaintiff
ought to be barred from having his
action aforesaid against this defendant
because he says that at the time, in the declaration
mentioned the said plaintiff was a slave without
this that the said plaintiff at the said time
was a freeperson in manner & form as in
the declaration is above supposed and
this &c.

E. BatesEdward Bates