Mary Davis v. Samuel B. Bellis
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State of MissouriMissouri
Saint LouisSt Louis County
In the St Louis Circuit CourtCircuit Court

To April Term 1855

MaryMary of Color
otherwise MaryMary
Samuel B. BellisSamuel B Bellis

Defendant answers
and denies that
Plaintiff was
formerly owned
and claimed by
John TJohn T Moore MooreJohn T Moore in the County of St LouisCounty of St Louis
as alleged in the Petition. Defendant
further denies that said MooreMoore ever
executed a Deed manumitting and
setting free the Plaintiff as set forth in
said Petition and Defendant believes the
Deed a copy of which is filed with the
Petition marked exhibit A to be a person
Defendant admits that he claims the
Plaintiff to be his slave and avows that
she is his slave by virtue of a purchase
from WilliamWilliam H. Heath made some time in
the year 1854. Defendant further saith
that he hath not at the time of filing
his answer hereto the Bill of Sale from
said Heath to him of said Plaintiff
nor is the same recorded but he can
procure the original - Defendant
prays Judgement and for
his costs and charges

J.B. Thompson Defts atty