Patsy Curd vs. William H. Barksdale
View original image: Page  011
[missing figure]

In the St Louis CircuitCircuit Court
CourtCircuit Court Spring Term

PatsyPatsy Curd CurdPatsy Curd Plaintiff
WilliamWilliam HH Barksdale BarksdaleH Barksdale Defendant

Defendant for answer to plaintiffs Petition
says that he admits that he does now and has
the month of September 1847 held said
plaintiff in bondage as a slave, that he Defend
ant an the 7th day of September 1847 He purchased
said plaintiff from Thomas B Dyer also three of
her children. One of whom has since died, the
other two are the ones named in said plaintiffs
Petition, Defendant says he was informed &
believes that said Plaintiff and her said children
were braught to St LouisSt Louis to be sold by, John
Curd now of St Josephes MissouriMissouri and by him left
with said Thomas B Dyer who was a friend
relative of said Curd to be sold that he defendant
took said negroes on trial & after having kept them
a few weeks became satisfied to buy them and
did buy them from said Dyer & took his will
of sale for them which is hereto anexed & paid
him the said Dyer for said negroes Eleven hundred
dollars the sum mentioned in said bill of sale
Defend and says he has since said purchase keept
and used said negroes as his slaves

Defendant says he knows nothing of the truth
of the statements of said plaintiff that she
resided five years in OhioOhio or that she is Entitled
to her freedom & that he knows nothing of her
history previous to the time he Comenced his
negotiations buy her and her children

Defendant says he is advised that all coloured

View original image: Page  012
[missing figure]
persons in the state of MissouriMissouri are taken in
law prima facie to be slaves. He says that said
plaintiff & her children are coloured persons that
they were represented to him by said Thos B Dyer
to be slaves, and that he Defendant baught them
believing them to be slaves. He says that the
character of said Dyer & of said Curd who he
defendant understood had brought said plaintiff &
children to St LouisSt Louis was such that Defendant
did not think it necessary, nor did he investigate
their title to said negroes but took them as
slaves relying on his bill of sale. Defendant
says he never heard from said plaintiff nor
from any lawer to which he attached the
slightest credit that said plaintiff or her
children were free, til he was served with
process in this cause. Defendant does not
admit any of the statements in said petition
Except that he holds said plaintiff & her children
in slavery. He knows of no fact to
Establish the Claim of said plaintiff or
Either of her Children to freedom & He asks
the Court to hold said parties to street legal
proof of Every fact necessary to Establish her
or their freedom

W.H. Barksdale

Subscribed and sworn to before
methis1st. day of April AD 1850

M SM S Cerre . CerreM S Cerre Clk