The Dallas daily herald. [volume] (Dallas, Tex.) 1873-1887, 1875-07-31

Probable Line Of nelense Of Respond
Win y iirlef synopsis oI
The Prospective Grafton ~
Plaintiffs Counsel,

lnirn sui hNhlllhi ANF 'fN''f'" '''f'''''''
PAINTING COMPANY, In the sum ~
thlrly-one thousand hve hundred dol
lars, for an .alleged llbel, Mrs smith
having taken tho pauper oath, The pa
perH we're regularly issued and served
on defendants
Az tbs petition IN unexpectedly rlchl
aud exhibits such wonderful degree
Of legal lore aud scholarly finish, tho
nubjolned exir0ota are given Amer
reoIllng that her husband has long
aInoe abandoned her and falls aud
neglocia 10 join her In tho suit, aho
prays 10 bo permitted 10 bring aud
carry on the suit In her own name
llhe states lhaiehe waa born Ia thoelly
OF Richmond, Va, Of Caucasian race,
and haa no mixture Of any other blood
In her vclnsi neither had or WIS ever
suspected Of having any colorcd blood
In her veins that she II " white wo-
man, aud Inns over been no regarded
aud has ever boon respected hnd
treated M SUCH that the white citizens
of her nntlyc State, Virginia, and OF
all other plncea where II Inns been her
lot 10 live, haze sought her society and
have received and treated her with re-
apect and kindness, Then follows n
brief biographical sketch OF herself
aud parcnts, together with her trials
troubles, trlbulatIons, gains and losses
In Memphis, which eliminated In
leaving her IN u destitute condition.
Sho further states TINT while In this
deatitute condition.
she obtained information that the
slilc of Tcxas was fine, prosperous,
productive aud thrifty State, with good
society, and overlooking with plenty,
wherefore she was prompted aud In.
lluenood IN remove 10 said State OF
Texas 10 build up her broken down
fortune TINT she first stopped In th,
city of Jefferson, Texas, aud after, to.
wit, IN 1879, she moved 10 and settled
IN the city OF Dallas, where she has
since lived; thnt for the lust six months
she has been living at the corner oi
Jackson aud Market streets, where SHE
has been keeping n boarding house, en-
lertalnlng bonrders and guests for hire
~ means Of support and maintain
ance; that up I'll the BID day of July,
1875, she had good reputation M n
worthy aud respectable housekoeper,
and was up I'LL said time last aforesaid
In good repute M u worthy housekeep-
or, and had u good run ofcustom In hel
said business Of keeping u boarding
house as aforesaid; that thereby SHE
was enabled TO support and maintain
herself; that up til said 23d dry of July
1875, abe never had been suspected o.
having any colored blood IN her veins
or OF being u c0lored woman, hut OF
the contrary she had always been high
ly respected M u white woman; that
Notwithstanding all these facts, the de
PENDANTS, being engaged In the publ
cation and circulation Of n newspaper
In the city and county of Dallas, Texas
to.wlt; THE DALLAS DAILY HERALD
which said paper had . large circula
ton In the city and county of Dallas,
Texas; she further AYERS and charges
that sa d company aforesaid, well
knowing TINT plaintiff was white wo
man and of tho Caucasian race, through
their duly authorized agent an(
business manager OF said company
aforesaid, to.wit: w. G. Holland
maliciously contriylng to injure
disgrace, denme and bring int
dsrernte plaintiff and to injure her II
her business of keeping boarders (hei
means of support and maintenance)
and to deprive her of her good name
and reputation NJ a white woman II
the society III which she Your petition
err lives. to-wlt, In the city and county
Of Dallas, Texas, did, on the sd day o
July, 1875, compose and publish II
said DALLAS DAILY HERALD and did
then and there circulate said DALLAS
DAILY HERALD In the city and county
Of Dallas, Texas, Of and concerning
plaintiff the following false, scanda.
lous and libelous matter; said publ.
cation so far as relates to plaintiff IN
huce perbd Is rs follows, to-wit:
"From the International the eouplt
went to house kept by a colored
woman named Fannie Smith, wher,
they remained until last Thursday
) night, when they suddenly left ant
took quarters at the Planters House
on Elm street. Immediately ate
their departure Fannie missed forty
four dollars-the proceeds of sale of
buggy, which she had placed In he
trunk for safe keeping. Discovering
her loss she procured u warrant for tn
couple and they were arrested an,
brought before Judge Burford for ex
animation"
That by means of said false, scanda
lous, malicious and libelous matter .,
published and circulated as aforesaid, %
and concerning plaintiff as aforesaid
by said company aforesaid, by thel
ingent and business manager, w. G.
Holland, as aforesaid, who then ant
there had authority, on the part Of sale
company aforesaid, to publish and cir.
culate said paper and said scandal0us
malicious and hbelous matter ssas afore
said, plaintiff hath fallen into disgrace
and contempt with several of her ne.
qualntances with whom she was Ii
great esteem; for that, by said false,
scandalous, malicious aud libelous
publication and circulation aforesaid
many persons were made to believe
plaintiff was part negro that, by said
false, scandalous, malicious and libel.
qua publication and circulation In said
DALLAS DAILY HERALD, by said COM
pany Aforesaid, plaintiff hath been