David McFoy, a person of color v. William Brown
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DavidDavid McFoy McDavid McFoy Foy
William BrownWilliam Brown

St Louis Circuit CourtCircuit Court
Nov: Term 1849

And the said defendant by his Atty
LaBeaume comes and moves the Court to
the writ the proceedings in above suit
brought to April Term of this court 1850, and give
said plaintiff into the of their defendant for
the following reasons: first, because said DavidDavid is both
against the law and equity in and cases made and
because said suit is improperly and illegally
instructed because the petition is not sworn to according
to law, and no costs for security given as given by the
statute; also because said suit is misguided in its
inception and will work manifest injustice and
if permitted to stand for trail at the next
Term of this court because said suit is brought
with no expectation of success but only for purposes
of delay and arrogance because there is not
a of either by proff or otherwise
that said plaintiff is free was born free And further
because said defendant is entitled to the
of said plaintiff as guardian of AdelineBrownBrown &
others and as administrator of the estate of ThomasThomas F Brown
F BrownThomas F Brown of Preston CountyPreston County VirginiaVirginia and because
this defendant in claiming said plaintiff as a slave
in the capacity aforesaid has fully complied with
the statute in such cases made and provided and
is still ready and willing to show to this honorable
court by not admitting of the shadow of a doubt
that he is entitled to the of said plaintiff
as a slave as aforesaid to wit as a slave of heirs
in the state of VirginiaVirginia

WilliamWilliam Brown BrownWilliam Brown
by his Aty: C.EdmundEdmund LaBeaume LaBeaumeEdmund LaBeaume