The "President & Directors of the North Eastern Rail Road Company" seek exemption for the "Slaves & Free persons of Color owned & hired by this company from the performance of ordinary road duty." They submit "that the nature of the Services required to be performed by these laborers - the necessity of their being transported from one place to another & to meet the exigencies that may and do continually arise: and the great pressure under which Such Services frequently have to be performed to enable the company to fulfill its engagements with the public as a common carrier - all combine to render it very difficult and at times impossible for these laborers to perform ordinary road duty." The petitioners therefore "pray your Honorable body to exempt the Said laborers from the said duty."
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Repository: South Carolina Department of Archives and History, Columbia, South Carolina
