William Stubs, a man of color v. William Bard
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WilliamWilliam Stubs BurdBurd

WilliamWilliam StubsWilliam Stubs

And the said defendant by GambleArchibald Gamble his attorney
comes and defends the force and injury when and says he
is not guilty of the said supposed wrongs and injuries
above laid to his charge in manner and form as the said
plaintiff hath above thereof complained against him
and of this he puts himself upon the country

And for further plea in this behalf the said defendant
says that the said plaintiff ought not to have or main

tain his aforesaid action against him because he says
that at the time of the committing of the grievancestres
pass in the declaration mentioned he the said plaintiff
was a slave without that that at the said time the
said plaintiff was a free person as he has in his said
declaration alledged and this the said defendant is ready
to verify wherefore he prays judgment &

HH R Gamble RH R Gamble GambleH R Gamble for