In the District Court of the First Judicial of Washington Territory holding Terms at Walla Walla City for the counties of Walla Walla and Columbia
Joseph Wells Plaintiff vs William A Church and Martha Church Defendants
And now comes the Plff and for reply to the new and affirmative matter set up in the Defendants answer to the writ of Habeas Corpus and Plff Complaint denies that the said Maty Wells came voluntarily to the Defts house or that she now or since the 26th day of June 187 has remained at the house of the defendant of her own will or pleasure
2 Denies that said Maty Wells is now of the age of fourteen years but avers that she is now about fifteen years old
3 And the Plff further avers that the said Defendants have repeatedly refused to allow the Plff to see or speak to his wife and that the said Defendants William A Church has repeatedly threatened to kill the Plff in case he Plff should see or speak to his said wife and to carry out said threat said Deft made a violent assualt and battery on the Plff
Wherefore the Plff prays as in his complaint
J Lasater[?] Plffs Atty
