Ford argued that he had freed the Holmes' under the terms of his agreement, having asked Holmes to work for Ford's son digging gold in California and had arranged to house and care for Holmes' wife and children, despite that they were unfit for work.
Ford asserted that he had relieved the Holmes family of their responsibilities under his agreement, having requested Holmes to work for his son mining for gold in California and had arranged to provide for Holmes' wife and children, despite their lack of employability.