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

In St. Louis Circuit CourtCircuit Court

And the said defendant
as to the said replication of the said plaintiff
to the record plea of the defendant says
that by reason of anything is that after
alleged the plaintiff ought not to
have or maintain her a aforesaid
because he says that he did not
any time years next
before the of the suit
hold the said plaintiff is slavery nor
did the said defendant obstructed the
or maintaining the said active by
any of the means in the
replication in manner and form as the
hall in her said replication alleged
and this the defendant prays may
he enquired of by the county