Laura, a woman of colour v. Henry B. Belt
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LauraLaura woman of color vsHenryHenry B Belt

suit for freedom

Plaintiff by her attorney JoelJoel C RichmondRichmond by
way of answer to the response of James ChristyJames Christy
made to the order of this Court in this cause that
he the said ChristyChristy should appear on the 2nd day of March 1852 and show cause why an attach
ment should not issue against him the said
ChristyChristy for a contempt of the Court in this cause
states that he the said ChristyChristy did in manner &
form as stated in said order force decoy and
take from her place of confinement LauraLaura
the plaintiff and that he the said ChristyChristy by the aid
and assistance of one E CurtisEdward Curtis did on the 16th day of February 1852 force decoy and take her
the said LauraLaura the plaintiff in this cause from out
of the jurisdiction of this Court after suit
had been brought by plaintiff for her freedom
and process served on the defendant HenryHenry B Belt
Plaintiff states that at the time she was removed
as aforesaid by the said James ChristyJames Christy and E CurtisEdward Curtis out
of the Jurisdiction of the Court that the said ChristyChristy
and CurtisCurtis had full knowledge and due notice of the
orders of the Court made in this cause and among
said orders is that which directs that the plaintiff
be not removed out of the Jurisdiction of this Court
during the prudency of her suit for freedom
Plaintiff denies that said James ChristyJames Christy was unad
vised at the time he removed plaintiff as aforesaid
that she the plaintiff had commenced a suit for her
freedom but states he the said ChristyChristy did before & at that
time have an entire and full knowledge that said suit
had been commenced for the freedom of plaintiff.
Plaintiff

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Plaintiff states that the said Jaems ChristyChristy did
violate that order of this Court which directs that
plaintiff should not be removed out of the ju
risdiction of this Court during the pendency
of her suit for freedom after he had received due notice
of the same and that he the said ChristyChristy and E CurtisEdward Curtis
did remove plaintiff out of the Jurisdiction of this
Court after suit had been commenced for her free
dom and process served on the defendant HenryHenry B
Belt all of which appears of record in this cause.
Plaintiff by way of demurrer to the answer
of the aforesaid James ChristyJames Christy to the order of the Court
made on him in this Court states that said answer is
no defence to the motion for an attachment
against him the said ChristyChristy as ignorance of
the orders of this Court in cases therein pending is no excuse
for a violation of the same.

LauraLaura

By her

Att RichmondRichmond Joel .