Mary Ann Steel vs. Curtis Skinner
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St. Louis Circuit CourtCircuit Court
July Term 1835

Mary AnnMary Ann Steel
vs
CurtisCurtis SkinnerSkinner

And the said defendant by
JJ Spalding SpaldingJ Spalding his attonrey comes & defends the force & injury
when, &.C & says that he is not guitly of the said
supposed trespasses in the declaration mentioned in
manner and form as the plaintiff hath above there
of complained against him, & of this he puts him
self upon the country & c.

and for a further plea this defendant says that
said plaitiff ought not to have and maintain
his said action thereof against him because he
says that at and during the time when said several
supposed tresasses were committed, she the plaitiff
was a slave and not a free person to but at said
County and this he is ready to verify where-
fore he prays judgment & C.

and for a further plea this defendant says that
the plaintiff ought not to have and maintain
her said action thereof against him as to said subjecting her to slavery & imprisoning her & keeping & detaining her in prison because he
says that said plaintiff is a colored person &
was born a slave and has always remained
in the condition of a slave then held and treated
as such: and that before the said supposed tres
passes were committed, she was sold and delivered
to this defendant as a slave, he not knowing or having notice that
she was entitled to her freedom: wherefore the com-
mitted the several acts alleged in said declaration
as trespasses and in this plea justified as he will might do, he not knowing
then of her right to freedom or having had notice of
the same and this he is ready to verify and as
to the assaulting heating & her &

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as to the force and arms &.C, he says he is not
guilty & of that he puts himself upon the county

filed July 14th 1835

AG

JJ Spalding SpaldingJ Spalding atty
for deft