The Answer of Samuel E Douglass to the rule upon him to shew cause why an Attachment shall not issue against him in the case of Lucinda Sumbry a petition for freedom

This respondent respectfully shews for cause that the mother of said Petitioner was and long before at the time and after the birth of petitioner was the slave of this respondent and his sisters, and the petitioner was born a slave, and hath never been manumitted, or in any manner become entitled to her freedom, and is now a slave. Her Father was reputed to be a freeman, and during his life the petitioner for several years at his particular request was permitted to reside with him: that he left the City of Washington, and the petitioner as the slave of the respondent was permitted by him to remain with her paternal grand father and his family after his death, until for some misconduct she was arrested by the police, in consequence of which this respondent sent for her to have her brought home. She was secreted and this respondent caused her to be arrested as a runaway; and she was committed to prison. On her arrest she was carried before a Justice of the Peace and D. A. Hall Eqr appeared for her as counsel and to respondents with great surprise represented that she was free. Respondent called to see Mr Hall in Company with a respectable citizen who knew her to be the slave of the respondent, and both stated the fact to Mr Hall. But he was not satisfied and a few days afterwards caused a writ the petition of said Lucinda to be served on this respondent. She was committed to jail on the 10th Oct 1854 and the petition was served on this respondent on or about the 14h and he endorsed upon it, and authority to Jos H. Bradley Eqr to appear to him as his attorney. The petitioner was in jail, and this respondent then offered to Mr Hall to take her out, or permit him to take her out if he would give security that she would neither run, nor be stolen away, stating to him, at the same time that three of the family servants had already escaped and he feared she would go also. This Mr Hall declined. Subsequently this respondent through a friend, in the early part of the October Term 1854 applied to Mr. Hall to have the cause tried, offering if means were wanted to procure the attendance of witnesses to aid him, to have them summoned and to compel their attendance, or if he would give the names of his witness or witnesses that this should be obtained for him. That afterwards, and before and during the March Term of this Court 1855 the same offers were repeated to him again and again. And it was represented to him that the girl was suffering in jail, and her detention was a serious loss and injury to this respondent. To all these representations your respondent received only vague and evasive replies, until he became satisfied that no one could be found hardy enough to give any evidence tending to show that the petitioner was in any manner entitled to her freedom Your respondent well knew there was no such title, and believed that Mr Hall himself was satisfied there was no just foundation for such pretended claims and did not intend to prosecute the cause.

Your respondent was not aware of any law or usage, or rule of Court which compelled him to keep her here, and nothing was further from his thoughts than any disrespect to or disregard of the authority or process of this Court, when he took her from the jail in the month of June 1855, and sold her. He had paid the sum of $87.70⁄100 for her detention & support while there, and there was no prospect of the cause being brought to a hearing and if it should be he well known not a particle of evidence of any fact or circumstance tending to show her right to be free could be addressed, and he did not believe he was doing wrong to her, or any manner violating any law, or rule, of this Court in so doing.

Your respondent sold her to go beyond the Jurisdiction of this Court, and she in fact went beyond it. Where she is now he does not know but presumes he can ascertain Indeed so confident does he feel that he can do so, that he is perfectly ready and now offers to give security in any reasonable amount to bring her back to this District, if in the trial of said cause it shall be found that she is in any way entitled to be free.

The Petitioner is now about fourteen, or fifteen years of age, and cannot possibly be of any service in the preparation of said cause and her Counsel has had full access to her for more than fifteen months past during the whole time of her imprisonment, to obtain all the information in her power to give

He prays your Honors to require the trial of said petition at this present term of the Court he giving security as tendered above, and that the said rule be discharged

Sworn to in Open Court Test Jno A. Smith clk 17 Jany 1856