Samuel, an infant, by and through his next friend, Marcy T. Andrews v. Barnard Lynch
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In Cir CourtCircut Court
St Louis
County

SamuelSamuel [of color] Plff
vs
Barnard M LynchBarnard M Lynch Deft

The said defendant answers the said
petition and says that whether the said
plaintiff is the said child of the mother mentioned
in the petition the deft has no knowledge
sufficient to form a belief, whether the said supposed mother of
the plaintiff was ever carried by any
owner or master into OhioOhio or ever resided there as mentioned
in said petition this deft has no knowledge
sufficient to form a belief.

Whether the said Bowde ever resided
in OhioOhio or not defendant has no
knowledge sufficient to form a
belief.
Whether the said MaryMary the supposed mother
of plff is a free person or not this deft
has no knowledge sufficient to form
a belief.
This deft makes no answer
to the allegation in said petition
that at the time the said MaryMary resided
in OhioOhio slavery and involuntary
servitude was prohibited in said
state because deft is not able to ascertain
from said petition either

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in its original or amended form
when it was that said supposed
residence existed.

The color of the plaintiff is darker than
a Mulatto; and he was purchased by deft
as a slave in this State and was held as a
slave prior to the commencement
of this suit and is still so
held by deft, and was held as
a slave by the person who sold
him to this defendant

Polk Glover & Campbell


for Deft