Brunetta Barnes, an infant of color, by and through her next friend, Peter Charleville v. John Berry Meachum
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BrunettaBrunetta Barnes BarnesBrunetta Barnes
(by her next friend)
vs
John BerryBerry Meachum MeachumBerry Meachum

In the St Louis Circuit CourtCircuit Court
March Term 1841

Replication

And the said plaintiff as to
the first plea of the said de
fendant by him in this behalf pleaded & whereof he
hath put himself upon the Country doth the like

And as to the second plea of said defendant
the plaintiff says that the by reason of any
thing in the said plea contained ought not to he
barred from having and maintaining her said
action thereof against said defendant, because
She says that at the time of the commit
ting of the trespass in the said declaration men
tioned, plaintiff was and still is a free person
and not the slave of defendant as in the said
plea is alleged, and this the said plaintiff
prays may be enquired of by the country.

ThomasThomas
Atty for plff