Celeste, a woman of color v. Alexander Papin
View original image: Page  009
[missing figure]

CelesteCeleste (of Color)
vs
AlexAlex Papin . PapinAlex Papin

In CirCircut Court .CourtCircut Court
St Louis County

And the said plaintiff as to the
first plea of the said deft, and whereof he puts
himself upon the Country, doth the like

And as to the secondplea of the said
defendant, the said plaintiff says, that by
of any matter or thing therein contained,
she ought not to be precluded or barred from
having or maintaining her aforesaid action
against the said defendant because she says
that the said wrongs and grievances in the said
declaration mentioned, were not, nor was any
or either of them, any of, or any one of the same
identical wrongs and grievances as those or
any of them in said plea mentioned, and for and
in respect whereof the said supposed judgement
in the said plea mentioned was , in
manner and form as the said defendant hath
above in his plea aforesaid alleged. And this
the said plaintiff prays may be wnquired of by
the County &c.

RisqueMurdoch& King
Attys for Plff