Abraham 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
John PacaJohn Paca says that the said Abraham DuttonAbraham Dutton ought
not to have & maintain his action aforesaid against him, because
he says that at the said time when &c the said AbrahamAbraham Dutton
DuttonAbraham Dutton was a slave, without that the said AbrahamAbraham , was,
at the said time, a free person, in manner & form as
he the said AbrahamAbraham has in his declaration above
supposed, and of this he puts himself upon the

filedJuly 30 1834