Petn. filed, leave to sue as a poor person & order on Sheff to hire out petitioner Bk 14 p 435. Plea filed BK 15 p 18. Dissmissed Jany 18th 1845 15 p no costs Sheriff to deliver slave plaintiff ) 16 p 106.

Andrian Paschall vs Richard W Ulrici

Suit for Freedom

Shff to Bond in 650 $

Executed this writ in the County of St Louis , by seizing the body of Andrian Paschall on the 18th day of March and by summoning Richard W Ulrici , the 19th day of March 1844, he being the person claiming said Andrian Paschall - as I am herein commanded

The Petition of Andrian Paschall ( a Man of Color) to the honorable Saint Louis Circuit Court

Your Petitioner respectfully represents to this honorable court that he is now held in Slavery by Richard M. Ulrici and your Petitioner further represents that about Six or Seven years Since (your petitioner does not remember the exact time) he was sent from the State of Missouri into the State of Illinois by one Gabriel Paul to whom your petitioner then belonged and under whom the said Ulrici claims for the purpose of assisting in the cutting and curing of hay was then and there held in Slavery Contrary to and in violation of the constitu tion of Illinois and an act of Congress for the government of the territory north west of the Ohio river , Your Petition further States that since that time he has come into the possession of the said Richard M Ulrici and that he has been held in Slavery ever since

And your Petitioner represents that by reason of the above represented -detion your petitioner has become and is entitled to his freedom and is a freeman and your petitioner respect fully prays this honorable Court to grant him have to sue as a poor person in order to establish his right to freedom and to assign him counsel for his assistance in that behalf. And your Pe- tetioner will ever pray

Andrew Paschall a man of color complains of Richard M Ulrici in custody of a plea of pass. For that the said Defendant on the first day of march in the year eighteen hundred and forty four with force and arms assaulted the said Plaintiff to wit at the county of St Louis aforesaid and then and there beat and bruised and all treated him and then and there imprisoned him and kept and detained him in prison there for a long time to wit for the space of one month then next following contrary to the laws of the State and against the will of the said plaintiff and other wrongs to the said plaintiff then and there did against the peace and dignity of the State and to the damage of the Plaintiff of one thousand dollars and the plaintiff avers that before and at the time of committing the said grievances he was and still is a free person and that the defendant held and still holds him in slavery therefore the plaintiff brings his suit &

Andrian Paschall (a man of color) being duly sworn upon oath says that he has good cause to to believe that he will be restraince from the liberty necessary to make good his right to freedom and that he may be subjected to severity on ac-count of his application for free-dom and that he may carried out of the jurisdiction of this court un-less the court cause this affiant to be taken out of the possession of the said Richard M . Ulrici or cause the said Ulrici to give bond and security for his appearance in this court upon this day of trial

Said Andrew Paschall above petitioner may sue as a poor person to establish his right to freedom and are assigned as his caounsel. It is further order-ed that the said Andrew Paschall have reaso-nable liberty to attend his counsel and the court as after as her may requires that he be not carried out of the jurisdiction of the court and that he be not subjected to any severity on account of his application for freedom

State of Missouri to Mil - burn Sheriff of the county of St Louis Greeting — You are hereby comman-ded to seize the within named affiant and petitioner Andrew Paschall where-ever he may be found and bring him be-fore Bryan Mullanphy our judge of the eighth Judicial Circuit of Missouri on 14th March 1844 at nine oclock AM County of St Louis in the city of St Louis at state of missouri Blend any claimant of his person, or any in whose possession he may be found to appear at the said trial and place have you there this unit as witness to this hand of our said Judge in open court this 13 March 1844

Andrew Paschall vs. Richard W . Ulrici

Plea

You are hereby notified, that Depositions of Witnesses to be read in evidence in the above cause, on the part of defendant will be taken at the office of Spalding & Tiffany in the City of St Louis in the County of St Louis and State of Missouri on the 14th day of December instant between the hours of 8 o'clock in the forenoon, and 6 o'clock in the afternoon: and the that the taking of said depositions, if not completed on that day, will be continued from day to day at the same place and between the same hours, till completed.

A. Paschall vs R. W. Ulrici

Notice to take Depositions

The above notice is acknowledged on the of the Plaintiff

So I atty for Plaintiff Executed the within notice by delivering a true copy to I Car at the county of St Louis This 9th day of December 1844 A Paschall not found in my county

Depositons of witnesses, produced sworn and examined, at the office of Messrs., in the city of Saint Louis , in the County of Saint Louis , state of Missouri , before me, Frederick Kretschmar, a Justice of the Peace within and for said County of Saint Louis , in a certain cause, now pending in the Circuit Count for the County of St Louis State aforesaid, between Adrian Paschall, plaintiff, and Richard W . Ulrici , , defendant, on the part of the defendant:

Gabriel Paul , being produced, sworn and examined on the part of the plaintiff, deposeth and saith:

Before my being sworn and examined as a witness in the above entitled suit, Richard W. Ulrici, the defendant, executed and delivered to me the release, hereto attached, marked A. I know the plaintiff in this suit, I bought him, with his mother, sister and brother at the sale of the Estate of Auguste Chouteau , made by the Commissioners appointed by the Circuit Court in or about the year 1832, he was then about five or six years of age. The mother and children, among whom was the plaintiff, were sold to me as slaves for life. I have held the plaintiff ever since as a slave, until I conveyed him to Mrs. Ulrici, my daughter which was in or about the month of february 1844.

I never gave the plaintiff permission or order to go to the state of Illinois , whilst he was in my possession. About the year 1836. 37 or 1838, when the plaintiff was about 10 or 12 years of age, I sent a German, named George Henderline, to Illinois , to make hay. During his absence I missed the plaintiff, and on the return of the German George on the following day, I ascertained that Adrian , the plaintiff, had been likewise over to Illinois . For this I severely scolded and punished him. Before his return I did not know what had become of him. Except the time, here stated, the plaintiff has never been over to Illinois , he has not left me a minute, whilst he was my slave. He always attended to and waited upon me personally and was my house servant. In the summer 1843 I the plaintiff, at the rate of $ 13.00 per month to Sir William Stuart , to go with him to the rocky moun-tains. On his return in the fall Mr. Sublette paid me the wages for Adrian , upon an order of Sir William . The trip of Sir William and party was an excursion of pleasure. I am in the habit of speaking french to my family and servants, and when Adrian , the plaintiff, returned from Illinois , as before stated, I scolded him in french. The German George Henderline spoke some English, sufficient to be understood, but no french; he did not understand french. George Henderline stayed about one year with me. When he returned from Illinois , he went with the hay, to the stable and Adrian went into the kitchen . Of this I was informed by a servant from the Kitchen, and I ordered him to my room, to reprimand him. Upon my asking George Henderline, why he had taken Adrian along, he answers that the Boy had gone with him, and he thought that I had permitted him to go; not under If I had wanted to send more assistance with George , I could have sent a full grown man, as I had more servants at my disposal, or I could have hired another german; I would not have sent a small Boy. Henderline was by me sent over to the prairie in Illinois to cut hay cure it and bring it over on my cart and horse, which he took with him.

Cross Examined by plaintiff's counsel:

I had only the german, George Henderline, at work in Illinois . I was in bed, when he started with the cast. I rise at 8 or 9 o'clock in the morning and they started quite early. I had given my orders the day before.

Question: How did you know that he ( Adrian ) had gone to Illinois ?

Answer: I did not know it, I only missed him.

Question: Did adrian go as a servant, with Sir William Stuart to the Rockey moun-tains?

Answer. Yes, he did go with him as such.

Further deponent saith not

There all men by then presents that Richard W. Ulrici for drivey & for are doller to me paid by Gabriel Paul of St. Louis do here by release & discharge him force from all liability to me on to me & my wife for as an amount of his conveyance to my wife of Adrian Paschall who has served me in the St. Louis Circuit Court , and from every & all covenants or warranties express or implied extend into by him for the title of said Adrian : & man especially from this covenant, & liabiality contained if any, in his held of fall of said Adrian to any wife Estelle hereby declaring him free & discharged from all responsibility to me on to my said wife on account of said Adrian , should the title to him fail or should he obtain his freedom witness my hand & seal this 13th De-cember A. D. 1844.