Gabriel, a man of color v. Michael Wiles
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GabrielGabriel (of Color)
Michael WilesMichael Wiles

The Defendant comes
& declares to the Plaintiff's Petition
& says that the same does not
contain facts sufficient to Entitle
the Plaintiff to his freedom,
for causes of Dismissal sets
down the following:

1. The fact as alleged in the Plaintiffs
petition, that the he was taken
into CaliforniaCalifornia Territory does
not entitle him to a judgement
of freedom

2. This Court cannot take judicial
notice of the laws of CaliforniaCalifornia
the general allegation therefore
that by the laws of CaliforniaCalifornia
the Plff became & is entitled
to his freedom is insufficient.

3. The facts set out on the face of
the Plaintiffs Petition show
that the taking of the Plaintiff
by the Defendant into CaliforniaCalifornia
was a mere transit of that
Territory & therefore gives the
Plaintiff no right of action
for his freedom.

Todd & Krum
Attys for Deft