Year: 1874

much more patent 20 be used BY said defendant and
closure threatened disclosure whateyer het said
his hands. }of such os any other wicked pusposS


in AsS ss SES .sa es sns
he had on personal knowledge, end which the the
Sood sh oS Ss o
for protecting himself against eoc soeesqnences Oh
for nS ali N. so. D
to said Beocher. Which Beecher had Ooniea TO hun At
of retracton" which would have been quite nateria!
for the vndcaton OF the ana ne OF
tails might have appeared which would tend to identify
the plaintiff the person who wrote said etractlon,
and who had been named to said defendant by said


And tho defendant further answering, saith that in tho
oason and with motions before set forth said de-
fendant took especial care ana pains 70 ca 10
said Wnsow or that might prosecute In that be,
half and without any malice or uniriendly purpose
%ent on his part that he knew o. aud con
oerning the plaintiff, any one OF the circumstances s
statement of said Tlton the supposed statements of
said Bowen and the statements OF said Beecher in the
premses and in doing this for the aforesaid.
and with the intent aforesaid. and without any malice
toward the complainant but on the &c contrary; with
defendant carefully concealed AS far as he could all
facts and circumstances that would tend to connect
Beecher as the other party concerned with him, and
had hoped that the name or tue palntn would not Dc
connected herewith, and refraned In the document
which is above complained Of called the "retraction
dated Jan. 49, lS7l from having the same photo 6o &
fendant published In bis investigation, In order 10 gvo
greater certainty to their ana IN order t9at
her and also with the same feeling OF kindness the SAID
defendant also refraned from producing OF
the plaintiffs as IN said publication VIII appear that he
did not make any assertion against tne paln.ln as the
woman who was mentioned In said letter Of IltOn upon
any knowledge OF his but that any mention Of the
name of the plaintiff, anything which might tend to


identity the plaintiff TO the woman IN SAID letter re-
ferred to- the work OF and the act OF sald Beecher
and that il the plaintiff agreed TO anything that the
said defendant believed himself that the injury or
wrong any, done TO the plantn by said Beecner
and by this defendant.


And said defendant further says. because Of the pre-
mise, II any wrong has been inadvertently done the
publication of his the facts and circumstances.
herein set FORTH under which the facts were published,
upon which said wrong or injury is claimed IN said
verify should aud ought to DO received III evidence and
considered In or any ny nab bd may d Ge
defendant has felt himself bound or ODlged 10 90, Ill
making the publication, as hercinbefore set forth.


And for another and further plea in answer to the
plaintiff allegations in her bill OF complaint as herein
before fortn the defendant saith nat the facts and
circumstances and documents heTelnbefOre by him
detailed and set forth above and to which he refers
as part Of this his answer snow that the publication
was a privileged communication which he had right 10
make under the circumstances. as hereinbefore set
forth. which he was thereby justlfed III making and
Which shoud be held not liable or actiOnable,
and no damage IN Law accrue to the plain
tiff as against the defendant therefore Of all OF
which he puts himself on the country for trial
plaintiffs complaint, says that the facts stated in said
publication heretofore complained Of in the paintifs
complaint received by hun from the information of
said Beecher and were received by hun and he
so told by said Beecher and that they were stated in
said publication by said defendant proof of the his
tory of tue relations between himself and the said
Beecher, herenDeore set forth, and not with any
intent thought o; wish to njure SAID paint ana with
country for trial.