John F. DarleyJohn F Darley , Admr.
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 defendant as stated in plaintiffs
But, defendant denies that said plaintiff
is now, or has been at any time previous
hereto a free person. - And Defendant
says that said plaintiff is now and al
ways has been a slave - and as such
she now belongs to the Estate of MiltonMilton
Duty decd. - of which estate said Defendant
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
plaintiff is now and has been confined
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 will in due
form of law as alleged in plaintiffs
And defendant denies that by
mode the said Duty did emancipate
all his negro slaves and among them
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. And therefore
defendant declines to answer said
allegation in plaintiff's petition.
Defendant denies that plaintiff has a
right to institute and to prosecute her
said suit as a poor person; and
that as said plaintiff has failed to com
ply with the provisions of the law
entitled An âAct to enable persons held
in slavery to sue for their freedomâ,
she ought not to be permitted to prose
cute the same.
Therefore defendant prays
that said petions be dismissed, or that
judgement be rendered in his favour.
John F. DarleyJohn F Darley .
in proper person
Tho HarveyHarvey , Attorney
for the heirs of MiltonMilton Duty.