Phillis, alias Susan, a free woman of color, v. Reddin B. Herring
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PhillisPhillis alias SusanSusan
Reding B Herring

And said plaintiff for
replication the second plea
of said defendant says she ought not
to or mantaining
her said by reason of any thing
by him in that plea alleged because the
says that immedately after the said
defendant took and imprisoned her as
in her declaration is he took her
to the state of LouisianaLouisiana and there sold
her as a slave, where she was held in slavery
untill the than two years previous to the
commencement of her said suit and that
during the time she was held in slavery as
aforesaid the defendant was not at
any time a resident of the state of
LouisianaLouisiana but his place of was
unknown to said plaintiff and so
the plaintiff that said defendantly
the means aforesaid did obstruct the
or maintaining her said action
against him during all the time she was
held in slavery as aforesaid & this she as
ready to wherefore the prays

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