Laura, a woman of colour v. Henry B. Belt
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LauraLaura vs
HenryHenry B Belt
woman of color
suit for freedom

In the Circuit CourtCircuit Court
of St Louis County
State of MissouriMissouri
April term 1852

Plaintiff states that she
is a free person and that she is in possession of
and held as a slave by defendant. Plaintiff
states that she became entitled to her freedom
and is a free person because she was taken from
the state of MissouriMissouri in the year of 1847 or 1848 by
her then owner and master John MC KenneyKinney to Terri
tory belonging to the United StatesUnited States, called Indian
Territory north of thirty six, 36, degrees thirty, 30, minutes of
north latitude in which territory slavery is prohibited and
that she remained in the aforesaid territory near Fort Scott,
and performed labour for said MC KenneyKinney he
claiming her as his slave until about the month
of september 1850. Plaintiff states further that her said
Master MC KinneyKinney resided in and made the aforesaid
territory his home and kept plaintiff in his possession
during the time mentioner from 1847 or 1848 until as aforesaid to until about
september 1850 and then bought her back to
the state of MissouriMissouri and therefore
she claims to be a free person. Plaintiff states that
before and at the time of commencing this suit that
she was a free person and was held and is still held as a
slave by defendant and she prays judgement for
her freedom and release from the claim of defendant and
all others to her as a slave

LauraLaura By her

Atty JoelJoel C RichmondRichmond Joel

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JoelRichmond Joel C RichmondRichmond, attorney for plaintiff makes
oath and says that he believes the matters

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matters and things as stated in the
foregoing petition are true.

JoelJoel C RichmondRichmond
Att for plaintiff

Sworn to & subscribed
10th Jany. 1852

M. S. CerreM S Cerre clk

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To the Honorable Alexander HamiltonAlexander Hamilton Judge
of the Circuit Court of the County ofCounty of St Louis
St LouisCounty of St Louis and state of MissouriMissouri.

Your petitioner LauraLaura
, a woman of colour, states that she is a free
person and as such is entitled to her freedom. But
that she is held as a slave and is in possess
ion of HenryHenry . B. Belt. She states that she is
entitled to her freedom because she was taken
in 1847 or 1848 by her then owner and master
John MC KenneyKinney from the state of MissouriMissouri
to the United StatesUnited States Territory, called Indian Territory,
near Fort Scott. In which Territory slavery is
prohibited said territory being north of thirty six, 36, degrees
thirty (30) minutes, north latitude. she states further that
said MC KenneyKinney resided and made his home in the
aforesaid territory from the time above mentioned
until about september 1850 and that she your
petitioner remained with and performed labour for
said MC KinneyKinney in the aforesaid territory during the
time heretofore stated and therfore she claims
to be free. Your petitioiner also states that she
is a poor person without any estate and prays
that she have leave to sue as a poor person
according to the statute in such cases
provided.

LauraLaura

By her Attorney

JoelJoel C RichmondRichmond Joel

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JoelRichmond Joel C RichmondRichmond, attoney for the above named petitioner
LauraLaura , makes oath and says that he believes that the
matters & things as stated in her petition are true.

JoelJoel C RichmondRichmond

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Sworn to and subscribed
Jany 10th, 1852

M. S. CerreM S Cerre Clk

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To the Clerk of the Circuit CourtCircuit Court of St Louis
County State of MissouriMissouri

It is hereby ordered that
the within named petitioner LauraLaura a person of
colour be allowed to sue for her freedom as
a poor person without giving security for costs
and that shebe allowed reasonable have reasonable liberty
to attend her Counsel and the Court as occasion
may require and that she be not removed out of
the Jurisdiction of this Court and that she be not
subjected to any severity on account of her suit
for freedom.

Given under my hand as Judge of
the Circuit Court of the County of St LouisCounty of St Louis
and state of MissouriMissouri this day of JanuaryA.D. 1852

A. HamiltonAlexander Hamilton

Judge 8th Judicial Cir.Mo.
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LauraLaura
vsHenryHenry B. Belt

Circuit CourtCircuit Court

Filed 10th Jany 1852, Leave to sue as poor person

M. S. CerreM S Cerre Clk

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County of St. LouisCounty of St Louis,

S.S

The State Of MissouriMissouri

To the Coroner of St. Louis County, Greeting:

We command you to summon HenryHenry B Belt to appear
before the Judge of our Circuit CourtCircuit Court , on the first day of the next
term thereof, to be held in the City of St. LouisCity of St Louis, within and for the
County of St. LouisCounty of St Louis, on the third Monday of April next, then and there to answer the complaint ofLauraLaura as set forth in the annexed petition
and have you then there this writ.

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Witness, Michael S. CerreMichael S Cerre , Clerk of said
Court
with the seal thereof hereto affixed, at office, in the city of St. LouisSt Louis, this Tenth day of January in the year of our Lord eighteen hundred and fifty two.

M. S. CerreM S Cerre

Clerk
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I acknowledge myself bound for all costs that may accrue in the above cause. Witness my hand and seal, at St. LouisSt Louis, this day of
185

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Executed this writ on the 12th day of Janry 1852
By delivering to H B Belt a true copy of the
writ and [ all so ] Reading the order of the CircuitCircuit Court
CourtCircuit Court there on the same to said

H. B. Belt

Coroners fees $1.00. E English Coroner
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No. 22.

Saint Louis Circuit CourtCircuit Court
April Term 1852

LauraLaura (of color)
vs Summons
HenryHenry B. Belt

Pet for freedom

RichmondRichmond

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It is hereby ordered that the within named petitioner LauraLaura
a person of Color be allowed to sue for her freedom as a
poor person without giving security for Costs and that
she have reasonable liberty to attend her Counsel
and the Court as occasion may require and that
she be not removed out of the Jurisdiction of
the Court and that she be not subjected to any
severity on account of her suit for freedom.
Given under my hand as Judge of the Circuit Court
of the County of St LouisCounty of St Louis this day of January AD
1852.

A HamiltonAlexander Hamilton Jud, 8th Judicial
Cir. MO.


a true copy attest

M. S. CerreM S Cerre Clk


Filed January 10th 1852

M. S. CerreM S Cerre Clk


$3 due
Copy Worth 28 cents
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Order. 21.p. 421. 467

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LauraLaura
vs
HenryHenry B Belt
woman of color
suit for freedom

In the CircuitCircuit Court
CourtCircuit Court County ofCounty of St Louis
St. LouisCounty of St Louis state
of MissouriMissouri.

JoelJoel C RichmondRichmond attorney
for the plaintiff in the above entitled
cause
being duly sworn on his on his oath states that since the commencement of said
suit and serviceand service on the defendant that
he the said defendant sold the plaintiff and
that James MJames M Riley and James ChristyJames Christy became
the purchasers of said plaintiff and that
on the 16th day of February 1852 that the said
James ChristyJames Christy and --- E CurtisEdward Curtis
did decoy the said plaintiff from the place
at which she had been confined
to wit the
jail of Bernard M LynchBernard M Lynch whose slaves are kept
for and by by stating to her that they wished
her to go and see her attorney and that
instead of taking her to see an attorney that
the said ChristyChristy and CurtisCurtis with other per
sons to this affiant unknown did by force & threats
compel her the said plaintiff to go
on board of the steam Boat "IsabelIsabel " which was
at that time at the port of St LouisSt Louis in the
state aforesaid and that the defendant and the
said Christy & Curtis shipped or caused the said plain
tiff to be shipped on board of said steamBoat
IsabelIsabel and to be carried to New OrleansOrleans in
the state of LouisianaLouisiana or to some other place
out of the jurisdiction of this court for
the purpose of selling her as a slave the said
boat being at the time spoken of bound for New OrleansOrleans
Affiant states that the aforesaid CurtisCurtis did

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take the said plaintiff from the Jail of the saidBernard M LynchBernard M Lynch which is in the
aforesaid city of St LouisSt Louis and that he
the said CurtisCurtis with others to this
affiant unknown did force and compel by threats
and violence the said plaintiff to go
on board of said steam Boat IsabelIsabel after
she plff had informed them, the said CurtisCurtis and
others, that she was a free person and
affiant is informed and believes that the said
CurtisCurtis and the others who assisted him in
forcing said plff on said boat were aided
and abetted by the said James ChristyJames Christy in
all that was done to decoy and force
the said plaintiff in the manner and
form heretofore mentioned and that the said CurtisCurtis and others have
caused the said plaintiff to be carried
out of the Jurisdiction of the Court.

Affiant also states that it was well known
to the said CurtisCurtis that the plaintiff in this
cause had brought suit for her freedom as
he was the person who bid for the said plaintiff
when she was sold by defendant and that he
the said CurtisCurtis was the agent or Clerk of the said
James M Riley & James Christy And affiant states that he believes that the
said Riley & Christy were told
at the time plaintiff was sold as afsd
of her suit for freedom
at the time he
bid for and bought the plaintiff. Affiant
also states that he informed the said CurtisCurtis on the
day on which plaintiff was sold as aforesaid
that she had sued for her freedom. Affiant
states that he has called upon the defendant
in this cause and upon the said James ChristyJames Christy and
CurtisCurtis and asked as counsel for the
plff for some information of the whereabouts
of said plaintiff and that they have all failed or refused
to give him any information on the subject
Affiant states that the said plff was confined

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from the time which she was sold by
the defendant which was about the 10th of January
last until the time she was taken away by the
said CurtisCurtis in the negro jail or yard of the
said Bernard M LynchBernard M Lynch and that she
was carried too and taken from said jail or
negro yard by the aforesaid CurtisCurtis Affiant
states that it was not known to him until the 24th of this month Febr 1852 that said plaintiff had
been carried off in the manner spoken of when
he received a letter from a passenger on said steamboat IsabelIsabel on one who
purports himself to have been such at the time said
plaintiff was taken on board of and carried off
on said steamer IsabelIsabel said letter ate at
Memphis Febr 15th 1852.

JoelJoel C RichmondRichmond

Att for plaintiff
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JoelJoel C RichmondRichmond attorney for plaintiff in
the within & foregoing cause makes oath
and says that the statements contained in the foregoing affidavit are true as he
verily believes.

JoelJoel C RichmondRichmond

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Sworn to and subscribed before
me, this twenty fourth day of
February 1852.

Adolph Kehr

Notary public
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LauraLaura vs H B Belt

In the Circuit CourtCircuit Court

woman of colour
suit for freedom

Filed 26th Feb 1852

M. S. CerreM S Cerre Clk Affidavit

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In the Circuit CourtCircuit Court for St. Louis County

LauraLaura of Color plaintiff
against
HenryHenry B Belt defendant

In obedience to an order
of this Hon Court made at the present November Term 1851, a copy of which is herewith filed in
and by which order James ChristyJames Christy with one
E CurtisEdward Curtis is required to show cause to this Honble
Court on the second day of March 1852 why
an attachment should not issue against them
for a comtempt of the order of said Court. And
now the said James ChristyJames Christy comes and says that
it is not true that he with said E. Curtis on
the 16th day of July 1852 or at any time decoyed
the said LauraLaura from the place where she was
confined & from the Jurisdiction of this Hon Court
and the said James ChristyJames Christy denies that he
at said time had any knowledge whatever that
this Hon court had ever made any such order
as the one referred to in the order a copy of which
is hereto annexed. And the said James ChristyJames Christy
presently denies that he ever removed or decoyed
said LauraLaura from the place where she was con
fined and beyond the jurisdiction of this Court
after he had any knowledge that she was prose
cuting her suit for freedom.
The said JamesJames Christy
ChristyJames Christy further states and gives the Court
here to be informed that he the said JamesJames Christy
ChristyJames Christy never knew nor had he any notice or
information that the saidLaura Laura had
instituted any suit for freedom until

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the sheriff of said County served upon him
the Copy of the order of this Hon Court hereto
attached. This respondent denies that he
violated any order of this Hon court after
having due notice of the existence of said
order and he denies that he has at any
time done any act or thing in contempt of
any order of this Hon Court and denies
all and each of the statements contained
in the order (a copy of which is herewith filed)
in which this respondent is charged with having
decoyed and moved from the place where she
was confined the said LauraLaura beyond the jurisdi
ction of this Court after having noted that
said LauraLaura was prosecuting her suit for free
dom and in violation of the order of this
Hon Court. The said James ChristyJames Christy hereby
protests that he has not committed any
contempt or knowingly violated any order
of this Hon Court Wherefore he prays to be
hence discharged with this costs .
James ChristyJames Christy the above named respondent on his oath says he believes the aforegoing
answer and the matters therein as stated
are true.

James ChristyJames Christy

Sworn to and subscribed 2nd March 1852

M. S. CerreM S Cerre Clk

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LauraLaura woman of colour Plff suit for freedom vsHenryHenry B Belt Deft

In the St. Louis Circuit CourtCircuit CourtNovember Term 1851

Whereas JoelJoel C RichmondRichmond attorney for the
plaintiff in this cause has filed his affidavit in
the court alleging among other things

That one E CurtisEdward Curtis and James ChristyJames Christy did
on the 16th day of February 1852 decoy said
said plaintiff LauraLaura from the place where she was con
fined & from the jurisdiction of the court during
the pendency of her suit for freedom and with
full knowledge by the said James ChristyJames Christy and
E CurtisEdward Curtis of the orders of this Court that she
the said LauraLaura should not be removed
out of the jurisdiction of the court during the
pendancy of said suit and with full knowl
edge that said LauraLaura was prosecuting her
suit for freedom. Therefore it is ordered by
the Court that the said James ChristyJames Christy & E CurtisEdward Curtis
show cause to said court on Tuesday next the 2nd day of March 1852 at 10 oclock A M at the Court
House of the city of St LouisSt Louis why an attachment
should not issue against them for a con
tempt of the order of said Court in the
.

AH

Feby 26th
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State of MissouriMissouri County of St. LouisCounty of St Louis

SS

I Michael S. CerreMichael S Cerre Clerk of the CircuitCircuit Court
CourtCircuit Court within and for the county aforesaid certify the foregoing to be
a true copy of the order made by said Court in said cause
Whereto whereof I hereto set my hand and affix
the seal of said court at St. LouisSt Louis this 27th Feby 1852

M S CerreM S Cerre Clk

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LauraLaura vs Belt

Answer of James ChristyJames Christy

In the CircuitCircuit Court
CourtCircuit Court

filed Mch 2nd 1852

M. S. CerreM S Cerre Clk

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County of St. LouisCounty of St Louis,

SS.

The State Of MissouriMissouri,

To E CurtisEdward Curtis & JamesJames Chrity & James MJames M Riley WilliamWilliam
B. Miller Laura W &
ReubenReuben BartlettBartlett Greeting:

You Are Hereby Commanded, that setting aside all manner of excuse and delay,
you appear before our Circuit CourtCircuit Court for the County aforesaid, on the 2nd day of March 1852at the hour of 10 AM at the City of St. LouisCity of St Louis, then and there
to testify, and the truth to say in a certian matter of controversy now pending in our said
Court, wherein LauraLaura , a woman of colour suit for freedom is
plaintiff and HenryHenry B Belt is defendant on the part of the plaintiff and herein you are in no wise to fail.

Witness, Michael S. CerreMichael S Cerre , Clerk of our said Court,
with the seal thereof hereto affixed, at office,
in the City of St. LouisCity of St Louis, this 27th day of February in the year of our Lord one thousand, eight hundred and fifty two.

M S CerreM S Cerre

Clerk C. C.
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LauraLaura vs Belt

suit for freedom

Circuit CourtCircuit Court
Executed (Except Feby 27)
W B Miller Wm Hopkins
& L.HopkinsHopkins not found
Fees $2.30 E. English -
Coroner

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County Of St. LouisSt Louis.

SS.

The State Of MissouriMissouri

Tothe Coronoer of St. LouisSt Louis Corder Fine
Bernard M LynchBernard M Lynch Adolph Kehr
Benjamin B Doyton & HenryHenry B Belt Greeting:

You Are Hereby Commanded, that setting aside all manner of excuse and delay,
you appear before our Circuit CourtCircuit Court for the County aforesaid, on the 2nd day of Marchat 10 o clock AMat the City of St. LouisCity of St Louis, then and there to tes
tify, and the truth to say in a certain matter of controversy now pending in our said Court,
wherein LauraLaura (a woman of colout in suit for freedom is plaintiff and HenryHenry B Belt is defendant on the part of Plaintiff and herein you are in no wise to fail.

Witness, Michael S. CerreMichael S Cerre , Clerk of our said Court,
with the seal thereof hereto affixed, at office,
in the City of St. LouisCity of St Louis, this 27thday of February in the year of our Lord one thousand eight hundred and fifty two

M S CerreM S Cerre

Clerk C. C.
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LauraLaura vs Belt

suit for freedom

Circuit CourtCircuit Court
Executed the within
by summoning the with
in named witnesses as directed on the 27th day Feby 1852. E . English fees $2.50 cts, Coroner

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In the Circuit CourtCircuit Court for
St Louis County

LauraLaura a woman of Colour plff
against
HenryHenry B Belt defendant

In obedience to an
order of this Hon Court made at the present
November Term 1851 of said Court in
the above entitled cause, requiring this
respondent to show cause why an
attachment should not issue against
him for a contempt of an order of
this Hon Court Cause and shown the
following to act, respondent states that
no order was ever served on him
in the above cause nor did he know
that any order ever had been
made in the above entitled cause
This respondent states that he did
hear that said LauraLaura had instituted
suit for her freedom but that this
respondent was no party to the
issue and did not consider that
he had any thing to do with said
suit, he states that said LauraLaura was sold
by the sheriff of said county and
as the agent for Riley & Christy he
bid for and purchased said
LauraLaura for them, and after he
purchased said LauraLaura he requested
Mr. Hughes an attorney of the St LouisSt Louis
Bar to look into the matter

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and advise what ought to be done
in the premises, and this respondent
states that said Hughes advised
that said LauraLaura ought to be sold
This respondent states he gave no
further attention to the matter as he
relied on the [ advise ] given him by
said attorney.
This respondent denies
that he decoyed said slave from the
place where she was confined and
he denies that he removed said
LauraLaura out of the jurisdiction
of this Hon Court, Knowing that
he was violating any order of this
Court, he states that all that he
did in the premises was as agent
for other and without any knowledge
on his part that he was violating
any law or any order of this Court &
he denies that he has committed any
contempt of any order made by this
Hon Court Wherefore he prays
to be hence discharged .

HudsonHudson Atty

for
respondent
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Edward Curtis on his oath says he
believes the above & the matters therein as
stated are true.

Edwd Curtis

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Sworn to & subscribed March 2nd 1852

M. S.Cerre Clk

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LauraLaura of Color vs H B Belt

Answer of
Edwd Curtis

Filed Mch 2nd 1852

M. S. CerreM S Cerre Clk

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LauraLaura woman of Colour vs suit for freedom HenryHenry B Belt

In the St. Louis Circuit CourtCircuit Court
November Term 1851

Whereas JoelJoel C RichmondRichmond attorney for
the plaintiff in this cause has filed
his affidavit in this Court alledging among
other things that one E CurtisEdward Curtis and JamesJames Christy
ChristyJames Christy did on the 16th day of February 1852 decoy said plaintiff LauraLaura
from the place at which she was
confined & from the Jurisdiction of this
Court during the pendency of her suit for
freedom and with full knowledge by the
said James ChristyJames Christy & E CurtisEdward Curtis of the order
of this Court, That she the said LauraLaura
should not be removed out of the juris
diction of this Court during the penden
cy of said suit and with full knowledge
that said LauraLaura was prosecuting her suit
for freedom. Therefore it is ordered
by the Court that the said James ChristyJames Christy and E CurtisEdward Curtis
show cause to said Court on Tuesday next
the 2nd day of day of March 1852 at 10
o'clock AM at the Court House of the City of St. LouisCity of St Louiswhy an attachment should
not issue against them for a contempt of
the orders of said Court in the premises

A H

Feby 6th
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rend="bracketed">

State of MissouriMissouri
County of St. LouisCounty of St Louis

SS.

I, Michael S. CerreMichael S Cerre Clerk of the Circuit

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within and for the County aforesaid, certify the foregoing to be
a true Copy of the order made by said Court in said cause
Witness whereof I hereto set my hand and affix the
seal of said Court at office, in the city of
St. LouisSt Louis, this 27th Feby 1852.

M. S.Cerre Clk

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Executed this writ on the 27th day of February 1852by delivering to James ChristyJames Christy & E CurtisEdward Curtis a true copy of
the within and offered to read the same which they refused
to [ heare ] in St. Louis County & State of MissouriMissouri.

E. English

Coroner Fees $ 2
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LauraLaura vs Belt

Filed 3rd March 1852

M. S.Cerre Clk In the CircuitCircuit Court
CourtCircuit Court
Curtis

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Laura Woman of color vsHenryHenry B Belt

In the Circuit CourtCircuit Court
County of St. LouisCounty of St Louis StateMissouri
of MissouriMissouri

suit for freedom

Plaintiff by her Attorney JoelJoel C RichmondRichmond
by way of reply to the answer of E CurtisEdward Curtis made
to the order of this Court in the above entitled cause
for him, the said CurtisCurtis to show cause on the 2nd day of March 1852 why an attachment should
not issue against him the said CurtisCurtis for a
contempt of this Court in the above entitled
Cause and plaintiff states that he the said E CurtisEdward Curtis
did have full and complete notice and knowledge of
all the orders made by the Court in the above
entitled cause in the suit of plaintiff for her freedom and
that he the said CurtisCurtis was fully informed of the same
by the plaintiff LauraLaura & other persons.
Plaintiff states that the said E CurtisEdward Curtis did on the 16th day of February 1852 decoy amd force the said plaintiff
from her place of confinement and did remove her
the said plaintiff from out the jurisdiction of
this Court having a full knowledge that he was viola
ting the orders of the Court made in the suit of
plaintiff for freedom. Plaintiff states all that has
been done by the said CurtisCurtis in regard to and
touching the said plaintiff since the commence
of her suit for freedom has been done with a full
knowledge that he was violating the orders of
the Court made in the aforesaid suit of the
plaintiff for freedom. Plaintiff by way of
demurrer to the answer of the said E CurtisEdward Curtis to the
aforesaid order of this Court made in this cause
states that said answer is no defence to the motion

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against him made in this cause against him
the said E CurtisEdward Curtis to show cause why an attachment
should not be issued against him the said
CurtisCurtis as ignorance of the orders of this Court
made in regard to Causes therein pending is
no excuse for violations of such orders.

LauraLaura ,

by her

Att
RichmondRichmond Joel

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JoelRichmond Joel C RichmondRichmond attorney for plaintiff makes oath and
says that the matters and things as stated in the
foregoing answer are true as he verily believes.

JoelJoel C RichmondRichmond

Att for Plff
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Sworn to and Subscribed
before me this 3rd March 1852

Adolph Kehr

Notary Public
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LauraLaura
vsHenryHenry B Belt

suit for freedom

Answer of plff to
CurtisCurtis response on
motion for attachment

Filed 3rd March 1852

M. S. CerreM S Cerre Clk

Filed 3rd March 1852

In the Circuit CourtCircuit Court CountyCounty of St Louis
of St. LouisCounty of St Louis State ofMissouri
MissouriMissouri

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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 .

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JoelRichmond Joel C RichmondRichmond atorney for plaintiff makes
oath and says that all the matters and things as stated
in the foregoing answer are true as he verily
believes.

JoelJoel C RichmondRichmond

Att for Plff

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[missing figure]

Sworn to and subscribed
before me this 3rd March 1852

Adolph Kehr

Notary public
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[missing figure]
LauraLaura
vsHenryHenry B Belt

suit for freedom
Answer of plff to
the response of ChristyChristy
on motion for attachment

Filed 3rd March 1852

M S.Cerre Clk