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The original document is part of the Missouri State Archives St Louis Circuit Court collection.
This electronic document is published as part of the St Louis Circuit Court historical records project.
The original document is part of the Missouri State Archives St Louis Circuit Court collection.
and the said
his attorney
several supposed trespasses above said to his
charged, in manner and form as in the said
declaration is alledged and of this he
himself upon the
and for further plea in this behalf as to the making
the said
wounding and imprisonment for the said
to have or maintain her aforesaid action thereof
against him because he says, because he says
that the said plaintiff before and at the time
where
servant, of him the said defendant, and as
bound faithfully to serve him the said defendant,
and the said defendant
said plaintiff just before the said time where
in the said declaration mentioned, neglected her duty
as
of him the said defendant, and behaved and
conducted herself in a disorderly,
and improper manner toward the said defendant
and then and there contrary to the obedience
to the said defendant,
whereupon the said defendant, then and there did
moderately
plaintiff for her
misconduct, and
voidably a
plaintiff and imprison her for the space of time
in the said declaration mentioned as was
for him to do for the
same supposed trespasses in the said declaration
mentioned. And this the said defendant is
ready to verify, wherefore he prays judgment if the
said plaintiff ought to have or
aforesaid action thereof against him
and for further plea in this behalf the said
defendant says that the said plaintiff ought not
to have or maintain her aforesaid action thereof against
him the said defendant because he says that the
said plaintiff at the time
ration mentioned, was and still is a
not free as in the said declaration is
this he is ready to verify - wherefore he prays
judgment if the said plaintiff ought to have and
maintain his aforesaid action thereof against her.
and for further plea in this behalf the said defendant
says, that the said plaintiff ought, not to have or maintain
her aforesaid action thereof against against him
This electronic document is published as part of the St Louis Circuit Court historical records project.
The original document is part of the Missouri State Archives St Louis Circuit Court collection.
because he says, that the said plaintiff at the
time
and
and this he is ready to verify, wherefore he prays
Judgment if the said plaintiff ought to have
maintain her aforesaid action thereof
him
ads
pleas
This electronic document is published as part of the St Louis Circuit Court historical records project.
The original document is part of the Missouri State Archives St Louis Circuit Court collection.
vs.
This electronic document is published as part of the St Louis Circuit Court historical records project.
The original document is part of the Missouri State Archives St Louis Circuit Court collection.
And the
by the said
alleged she ought not to be banned from having
gainst him, because she
and form as the same are above
are not sufficient in law
the said Lethe from having and maintaining
her aforesaid action thereof against him, and
she is not bound by the Law of the land
to answer the same, and this she is ready
to verify wherefore for want of a sufficient
plea in this behalf, the said Lethe prays
judgment and her damages
and as to the said
the said Lethe
any thing by the said,
above alleged ought not to be
having and maintaining her aforesaid
action thereof against him, because she
time when &c. of his own wrong and without the
cause by him in his said
and
and form as the said
complained against him, and this she prays
may be
of any thing by the said
having or maintaining her aforesaid
action thereof against him, because she
saith that the said
by him in his said fourth plea alleged
her of her liberty and held her in servitude
in
above thereof complained against
him, and this she prays may be
of by the Country
This electronic document is published as part of the St Louis Circuit Court historical records project.
The original document is part of the Missouri State Archives St Louis Circuit Court collection.
Nar
This is an action of
Trespass. Let a Sum-
mons
Executed this writ on
We Command you to summon
he be and appear before the Judge of our
at the next term, thereof to be held at the city of
first monday of October next then and there to
answer unto
to the damage of said Lethy of one thousand dollars
and have you then there this writ.
the said
day of June in the year eighteen hundred
and twenty three
and arms made an assault upon the said Lethy and
her then and there beat wounded and
restrained of her liberty and held in servitude
from the day and year last aforesaid for a long space
of time to wit for the space of three months and
other wrongs to the said Lethy then and there did
against the peace of the State and to the dam
age of the said Lethy of one thousand dollars
and therefore she brings her suit & c