John F. DarlyJohn F Darly , 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 Petition.
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
always has been a slave for life and as such
he now belongs to the Estate of MiltonMilton
Duty decd. of which Estate said Defend
ant says that he is now and has been
for more than two years last past the
Public Administrtor. And as such
administrator Defendant says that said plaintiff is
now and has been confined & restrained by
him of his liberty
Defendant admits that plaintiff was for
merly the slave of MiltonMilton Duty during his life
time and at his death he she became as
she now is 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 plaintiffs petition.
And defendant denies that by that alleged
WillWill or by any other legal mode the
negro slaves and among them the plaintiff.
Defendant denies that said plaintiff has any
right whatever to be informed whether or not
all the debts of the 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 an
swer said allegations in the plaintiffs
Defendant denies that plaintiff has a
right to institute & prosecute his said suit
as a poor person; and that as said plain
tiff has failed to comply 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 per
mitted to prosecute the same.
Therefore Defendant prays
that said petition be dismissed or
that judgement be rendered in his favor.
John F. DarleyJohn F Darley
in proper person
Thos. HarveyThomas Harvey , Attorney
for the heirs of MiltonMilton Duty