Nathaniel, a man of color v. George W. Coons
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[missing figure]

A Person of color
Geo W CoonsGeorge W Coons adm of
MiltonMilton Duty Decd

In St Louis Circuit CourtCircuit Court
April Term 1845

And the said deft by his
attys comes and moves the Court to dismiss
and cause for the following reasons

1 Because the process issued in this cause
was illegal and granted withoutauthority of law

2 Because the said plff had no right to
institute an action without firstfinding an affidavit
according to the provisions of the statute
in such case made & provided

3 Because there is no sufficient affidavit filedherein

4 Because said supposed affidavit
is informal & insufficient & illegal

5 Because said plaintiff being a negro
he could not make an affidavit against
the deft who is a white man

6 Because the said complaint & affidavit
are in other respects informal & insufficient

7 Because the Clerk acted without legal
authority in permitting the plaintiff to sue
in manner aforesaid

WalkerWalker Hudson & HudsonWalker Hudson atty for