In an echo of the requirement in that the Israelites could execute a manslayer only with the evidence of two or more witnesses, of the United States Constitution provides that the government may convict a person of treason only with the testimony of two witnesses to the same overt act or a confession in open court. A then-recent precursor of the Constitution's provision appeared in 1776 in the Laws of Virginia, which provided that defendants be "convicted of open deed by the evidence of two sufficient and lawful witnesses, or their own voluntary confession." At the Constitutional Convention, the requirement for two witnesses first appeared in the first draft of the Constitution presented on August 6, 1787. During debate on August 20, 1787, John Dickinson of Delaware questioned what was meant by the "testimony of two witnesses" and whether they were to be witnesses to the same overt act or to different overt acts. The Convention consequently voted to insert the words "to the same overt act" after "two witnesses." Benjamin Franklin supported the amendment, arguing that prosecutions for treason were virulent and perjury too easily made use of against innocent defendants. In "The Federalist Papers", Alexander Hamilton cited the requirement for two witnesses to establish treason as one of several provisions in the Constitution that enumerate rights that, taken together, amounted to a bill of rights.