Etta Clark, Texas Sex Worker & Madam, Signed Legal Statement-Very Rare

4pp, measuring 8.375" x 13.75", El Paso, Texas, dated July 14, 1894. Signed "Etta Clark", the document is a handwritten legal petition by Clark's lawyer, William H. Coldwell, for a suit between Clark and Edna Hoyt. Clark claimed that Hoyt falsely inflated the value of damages in her own suit against Clark, as well as claiming that the case wasn't even in the jurisdiction of the court. Reading in part:

"...plaintiff Edna Hoyt has falsely and fraudulently averred her actual damages in this case to be the sum of One hundred and Forty-Two dollars and has falsely and fraudulently averred her exemplary damages in this case to be the sum of Five Hundred dollars…That plaintiff has so averred her damages to be in the sum aforesaid for the purpose of conferring jurisdiction of this case on this court when in truth and in fact this court has no jurisdiction thereof….Edna Hoyt was the owner of the personal property described in the petition in this case and that the defendant Etta Clark had taken the same from the possession of the said Edna Hoyt and converted the same to the use and benefit of the said Etta Clark…said defendant says 1st. That it appears the plaintiff's 1st amended original petition that this court has no jurisdiction of this case. 2d. That said petition does not aver the time or place of the alleged taking and conversion by said defendant. 3d. That said petition does not aver any facts that show that plaintiff is entitled to recover punitive damages. Wherefore defendant says that she ought not to be required to [illegible] said petition, and of all this she prays judgment of the court…" With flattened folds and a few ink stains. There is a small tear and paper loss at the right edge, not affecting any of the text. Boldly signed.

Etta Clark was a noted El Paso sex worker and madam. The petite French-Canadian stood only five feet tall and had a fiery temper, but successfully ran her business as one of El Paso's five most popular brothels (or parlor houses). The five important madams between 1881 and 1915 were Alice Abbott, Etta Clark, Gypsy Davenport, May Palmer, and Tillie Howard -all charming and shrewd businesswomen. Clark may best be known for having shot one of her rivals, Alice Abbott, in the groin after a dispute over one of Alice's girls defecting to Clark's parlor.

This item comes with a Certificate from John Reznikoff, a premier authenticator for both major 3rd party authentication services, PSA and JSA (James Spence Authentications), as well as numerous auction houses.

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