John F. DarleyJohn F Darley , Adm
Circuit CourtCircuit Court
Saint LouisSt Louis County
April Term 1850.
Defendant states that it is true plaintiff is now
and has been held in slavery by defendant as
stated in plaintiffs petition.
But defendant denies that said plaintiff is now
or has been at any time previous hereto a
And defendant says that said
plaintiff is now and has always been a
slave and as such she now belongs to the
Estate of MiltonMilton Duty decd. of which Estate de-
fendant says that he is now and has
been for more than two years last past
the Public Administrator.
And as such
administrator defendant says that said plain-
tiff is now and has been confined & restrained
by him of her liberty.
Defendant admits that plaintiff was formerly
the slave of MiltonMilton Duty decd. during his
life time and at his death she became
as she now is a slave belonging to the Estate of the said MiltonMilton .
Defendant admits that MiltonMilton Duty
died in Saint LouisSt Louis County in the StateMissouri
of MissouriMissouri about the year 1838.
Defendant denies that before his death
said MiltonMilton Duty made his last will in
due form of law as alleged in plaintiffs
And defendant denies that by that
alleged WillWill or by any other legal mode
the said Duty did emancipate all his
Defendant denies that said plaintiff has any
right whatever to be informed 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 the
said allegation in plaintiffs Petition.
Defendant denies that plaintiff has
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 enable persons held in slavery to sue
for their freedomâ she ought not to
be permitted to prosecute the same.
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 , Atty.
for heirs of MiltonMilton Duty.