Samuel, a man of color vs. John Howdershell
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[missing figure]
Sam (a man of Color)
JohnJohn Howdershell [ John HowdershellHowdershell ]

In St Louis Circuit CourtCircuit Court

The plaintiff by his attorneys comes and moves
the court to set aside the verdict and grant
a new trial in this case for the following.


1st The count improperly gave the instructions
asked by the defendant

2nd The Count improperly and erroneously refused
to give the instructions and each of them asked
for by the plaintiff.

3rd The count excluded proper evidence offered
by the plaintiff.

4th The count admitted improper evidence
offered by the defendant and objected to by
the plaintiff.

5th. The jury found their verdict contrary to the law & evidence

BeattyBeatty & CarrCarr Atts for Pltf.