Louis Stubbs, a man of color v. William Burd
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WilliamWilliam Burd BurdWilliam Burd


And the said defendant by gamble his attorney
comes and defends the force, and injury when and says
he is not guilty ofthe said wrongs and injuries above said
This charge in manner and form as the said plaintiff hath
above thereof against him and ofthis he puts
himselfupon the County

And for further plea in this behalf the said defendant
says that the said plaintiff ought not to have or maintain
his aforesaid action against him because he says that at the
time of the committing ofthe said supposed grievances
in the declaration mentioned the said plaintiff was a
slave without that that at the said time the said plaintiff
was a free person in manner and form as he has in his said
declaration alledged and this the said defendant is ready
to verify wherefore heprays judgment on.

Filed 13th July 1837

John RulandJohn Ruland Clerk

for Dft