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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
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
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
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
Filed 17 Jany 1856