John F. DarlyJohn F Darly Admr., Defendant
Circuit CourtCircuit Court
St. Louis County
April Term 1850
Defendant states that it is true plaintiff
is now and has been held in slavery by de
fendant as stated in plaintiffs petition.
But, defendant denies that said plaintiff is now
or has been at any time previous hereto a
And defendnat says that said
plaintiff is now and always have been
a slave; and as such she now belongs
to the Estate of MiltonMilton Duty decd. - of which
Estate said Defendant says that hs is
now and has been for more than two years
last past the Public Administrator.
And as such administrator defendant says
that said plaintiff is now and has been con
fined and restrained by him of her liberty.
Defendant admits that plaintiff was formerly
the slave of MiltonMilton Duty during his life
time and at his death she became as
she is now a slave belonging to the Estate
of said MiltonMilton .
Defendant admits that said MiltonMilton Duty
died in St. Louis County in the State ofMissouri
MissouriMissouri about the year 1838.
Defendant denies that before his death
said MiltonMilton Duty made his last WillWill in
due form of law as alleged in plain
And defendant denies that by
that alleged WillWill or by any other legal
mode the said Duty did emancipate
Defendant denies that said plain
tiff has any right whatever to be in
formed whether or not all the debts of
said Estate have been paid, or that an
ample fund is in the hands of the
defendant to pay the same.
therefore defendant declines to answer
said allegation in plaintiffs petition.
Defendant denies that plaintiff has a
right to institute and prosecute her said
suit as a poor person; and that as
said plaintiff has failed to comply with
the provisions of the law Entitled âAn
Act to [ inable ] persons held in slavery
to sue for their freedomâ she ought
not to be permitted to prosecute the
Therefore defendant prays that
said petition be dismissed or that
Judgement be rendered in his favour.
John F. DarleyJohn F Darley
in proper person
Thos. HarveyThomas Harvey , Attorney
for the heirs of MiltonMilton Duty.