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Brunswick District & county to wit. Ishmael Dunn Plt complain of Ephraim Parham Deft in custody and so forth for this to wit; that whereas the said Ishmael the plaintiff, is a good, true, honest, and faithful citizen of Virginia, and as such, from the time of his birth hitherto hath behaved and, carried himself and was reputed to be of a good name, condition and conversation, and free from any crime, and particularly from the crimes of felony & hog stealing Nevertheless the said Ephraim the defendant, well knowing the premises, and maliciously contriving to deprive the plaintiff of his good name, credit, and reputation as aforesaid, and to subject him to the penalties of the law, and to bring him into infamy and disgrace, on the first day of August in the year of our Lord 1795 at the parish of St. Andrews in the county aforesaid, falsely and maliciously related, spoke, published, proclaimed, and with a loud voice pronounced these feigned, scandalous and opprobrious words following, of and concerning the plaintiff in the presence and hearing of divers good and honest people of the commonwealth of Virginia, to wit;
"he (the Plaintiff meaning) hath stolen a Negroe from John Dunn -- and "he (the Plaintiff again meaning) hath stolen a hog from William Gee & I (the Deft meaning) can prove it meaning that the Plaintiff had committed Felony by stealing a Negroe from John Dunn -- & that the Plaintiff had moreover stolen a hog from Wm. Gee & that he the Deft could prove it
by reason of the speaking and publishing of which said feigned, scandalous, and opprobious words by the defendant of and concerning the plaintiff as aforesaid, the plaintiff had the great infamy and scandal of the hurtful and wicked crimes of Felony & hog stealing among very many venerable and creditable persons with whom the plaintiff was before in great honour and esteem; and the plaintiff is farther in danger of a prosecution under the laws of the commonwealth to the damage of the plaintiff one thousand pounds; and therefore he brings suit, and so forth, Gregory P Qee
Pledges of prosecution John Doe, and Richard Roe.