Plea and Demurrer in Jacobus v. Kitchell et ux.

Plea and Demurrer in Jacobus v. Kitchell et ux.

Mary Ann Jacobus accuses Milden and Elizabeth Kitchell of calling her a whore. Lincoln writes a plea and demurrer for the Kitchells in the case of Mary Ann Jacobus v. Milden Kitchell et ux. Tazewell County Circuit Clerk John A. Jones files the document on September 16, 1851.

Lincoln, Abraham

Abraham Lincoln Presidential Library and Museum

1851-09-16

pdf

en

300056

T1851.09.16-1

42115 (legal)

Milden Kitchell & Elizabeth Kitchell ads Mary Ann Jacobus

And the said defendants come, and as to so much of the plantiffs declaration as charges the speaking the following, to wit "Mary Ann Jacobus is a whore" "Mary Ann Jacobus gets her fine clothes by whoring" say plantiff actio non because they say the said defendant Elizabeth is not guilty of the speaking of said words in manner and form as is in said declaration alleged; and of this they put themselves upon the country &c

Lincoln p.a.

And as to the remainder of said declaration, to wit, so much thereof as charges the speaking of words other than those recited in the above plea, said defendants say actio non because they say the same is not sufficient in law for the said plantiff to have and maintain her said action against the said defendants; and thus they are ready to verify, wherefore &c

Lincoln p.a.

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Mary Ann Jacobus ads E & M Kitchell

Demur & Plea

Filed Sept 16, 1837, J A Jones Clk

Complete

100

20

paper and ink

2 p

32 x 20 cm