To His Excellency Thomas E. Bramlette.
Govenor of Kentucky

The undersigned respectfully represent that they were of Counsel of Thomas Woodward, charged with the murder of a man, named Baker. A copy of the indictment is herewith presented. Upon this charge he was tried at the present term,- he was convicted of manslaughter, and the period of his confinement in the Jail and Penitentiary fixed at two years.

We sincerely believe that the defendant has been unjustly convicted and that the verdict is wholly unwarranted by the testimony. The facts clearly established by the proof are as follows. The defendant was the proprietor of a bar room or Coffee House fronting on the river in the city of Louisville. On the day the homocide was committed, a man by the name of Martin Bruce, the owner of a Beer waggon, called at the coffee House of defendant to deliver beer or to inquire if defendant needed any. Whilst Bruce was in the house, the deceased

Baker entered the house, became violent and abusive, and commenced an assault upon Bruce, and threw at him a cooking iron, an instrument made of iron or steel and resembling in shape a chisel, he also threw a beer mug or tumbler which struck the windows of the house. The noise and rattling of the glass attracted the witnesses who were introduced by the Commonwealth. Three of these witnesses prove that they saw Bruce, the beer man, running from the door of the house, he was stricken over the head by the deceased with a cooking iron, he knocked or pushed down the deceased, jumped into his waggon and drove rapidly away. At this time the defendant came to the door of the house- the deceased then approached him putting his hand into his bosom as though, in the language of one of the witnesses for the commonwealth, he intended "to draw a pistol or knife or something." According to the testimony of M^rs Myers, a witness for the Commonwealth, the parties then clinched and both of them were on the ground when she saw a knife in the hands of the accused. It is true that as to the

exact time when the cutting occured there was some contrarity of statement by the witnesses of the Commonwealth. But we do not hesitate to say that the weight of evidence is as we have given it on the proof of the Commonwealth. On behalf of the defendant it was clearly established that the deceased after he had made the assault on Bruce approached the accused, who was standing in or near the door of his house seized the defendant, thrust his hand into the bosom of his coat, and threatened to take his life, using language of great violence. One of these witnesses was in the house when the altercation commenced between deceased and Bruce the beer man. The conduct of deceased was violent whilst the conduct of accused and his language was pacifid. He heard the accused urging the deceased to abstain from violence, and when accused came to the door he heard him say to deceased that he ought not to trust Bruce in that way, when deceased approached him with his hand in his bosom and cursing him threatened to take his life, the parties then clinched and fell

over the horse block in front of the door when the cutting occurred. The testimony of defendant was wholly unassailed, except by proof that the witnesses for the commonwealth who stated that they did not see the witnesses introduced by the accused. The Coroner introduced by the Commonwealth, states that he took from ^the^ pockets of dec^d two Cooking Irons, described as above.

We beleive that we have stated the substance of the testimony. And we confidently rely that it is not a case which justified a convictiion for manslaughter.

The counsel for the accused was so confident of an acquittal on the ground of self defence, that they voluntarily limited themselves to two speeches of fifteen minutes each.

We feel that gross injustice has been done to an innocent man. The accused Thomas Woodward, is, we are credibly informed and verily believe, a quiet peacable citizen and an honest man. He is poor, has a young and interesting wife and respectably connected.

We trust that your Excellency will give to his case a favorable

consideration and pardon him.

Very respectfully
Yours &c
W. F. Bullock
E S Craig } atto