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The original document is part of the Missouri State Archives St Louis Circuit Court collection.
This electronic document is published as part of the St Louis Circuit Court historical records project.
The original document is part of the Missouri State Archives St Louis Circuit Court collection.
The petition of
a mulatto, that he was born a slave being the
property of Benjamin Horine of
this state that the said Benjamin Horine
let your petitioner free by an instrument in writing effectual for that purpose when he your
petitioner should arrive at the age of
twenty one years that your petitioner is
now about twenty nine years of age and since he
arrived at the age of twenty one years
he has not been claimed as a slave
or as the property of said
can establish his freedom in the Courts
by Law that one Jay Duty of the
petitioner & insists upon holding him
as a slave And your petitioner has reason
to believe & does believe that the said
Duty his agents and attorneys will by force
and violence remove your petitioner out of this
state so as to prevent his suing for
his freedom. Petitioner most respectfully
prays that he may be permitted to sue
in this Honorable Court for his freedom
as a poor person according to the Laws
of this state and that the necessary orders
may be endorsed herein according to
the statutes in such cases made & provided
and as in duty bound will ever pray.
It is ordered by the Court That the
within petitioner be allowed to sue
on giving security satisfactorily to
the Clerk for all costs that may
be adjudged against him
2. That said petitioner have reasonable
liberty to attend his counsel
and Shreve as occasion may require.
That
he be not removed out of the jurisdiction
of this Court and that he be not subject
to any severity on account of his application
for freedom.
This electronic document is published as part of the St Louis Circuit Court historical records project.
The original document is part of the Missouri State Archives St Louis Circuit Court collection.
The Plaintiff states that the defendant heretofore to wit
on the
the said plaintiff without any reasonable, probable or lawful
cause whatever.
And the plaintiff avers that before and
at the time of the committing of the said grievances
he was and still is a free person.
And that the defen
dant held & still holds him in Slavery,
Wherefore the
Plaintiff asks judgement declaring him free.
Plff being duly sworn upon his oath states the
above petition is true sworn to & subscribed
this
Declaration
Filed
This electronic document is published as part of the St Louis Circuit Court historical records project.
The original document is part of the Missouri State Archives St Louis Circuit Court collection.
I told him I would
he got action order
Summons
Pet: for freedom
petitioner be allowed to sue on giving security
satisfactorily to the clerk for all costs that may
be adjudged against him. That Said Petitioner
nerhassett& Shreve as occasion may require
that he be not removed out of the Jurisdiction of
this Court and that he be not subject to any
severity on account of his application for free
dom
Issued
We command you to summon
to appear
before the Judge of our
term thereof, to be held in the
next, then and there to answer the complaint of
free man of Color
as set forth in the annexed petition
and have you then there this writ.
I acknowledge myself bound for all costs that may accrue in the above cause.
This electronic document is published as part of the St Louis Circuit Court historical records project.
The original document is part of the Missouri State Archives St Louis Circuit Court collection.
We command you to summon
to appear
before the Judge of our
term thereof, to be held in the
next, then and there to answer the complaint of
man of Color
as set forth in the annexed petition
and have you then there this writ.
I acknowledge myself bound for all costs that may accrue in the above cause
It is ordered by the Court that the
within petitioner be allowed to sue
on giving Security satisfactorily to
the Clerk for all costs that may
be adjudged against him.
That said petitioner have reasonable
liberty to attend his Counsel
Blennerhassett & Shreve as occasion
may require - that he be not removed
out of the Jurisdiction of this
Court and that he be nor subjected
to any severity on account of
his application for freedom.
A true copy of the writ &
petition
This electronic document is published as part of the St Louis Circuit Court historical records project.
The original document is part of the Missouri State Archives St Louis Circuit Court collection.
Plea
This electronic document is published as part of the St Louis Circuit Court historical records project.
The original document is part of the Missouri State Archives St Louis Circuit Court collection.
And the said defendant by
attorney comes & defends the force & injury &
and says that he is not guilty of the said
supposed imprisonment above laid to his charge
in manner & form as the said plaintiff hath above
thereof complained against him-
And of this he
puts himself upon the County
And for further plea in this behalf defendant says
that said plaintiff whose name is
is a slave for life & is the property of defendant; and that
as such property he said defendant does hold said
plaintiff to labour & service which by the laws of
this state & of the Constitution of the
he defendant has the right to hold said plain
tiff as his slave.
And this he said defendant
is ready to verify.
Wherefore he prays judge-
ment &
Defendant
that he believes the within pleas & the
matters therein stated as stated are true.
This electronic document is published as part of the St Louis Circuit Court historical records project.
The original document is part of the Missouri State Archives St Louis Circuit Court collection.
In the matter of
freedom
In the
Being satisfied from the within
statement of
within named petitioner
to be removed beyond the Jurisdiction of this
Court before the termination of his suit for freedom
It is ordered by this Court that the clerk issue a
warrant under the Seal of this Court for the apprehension
of the said Petitioner & that he be brought without delay
before this Court.
It is further ordered that the Sheriff
take possession of said petitioner and hire him out
to the best advantage from time to time during the
residency of the suit.
And that said Sheriff take a Bond
from the hirer payable to the state of
penal sum of Fourteen hundred dollars with such
security as the Sheriff approves
the petitioner shall during the pendency
of his suit have reasonable liberty of attending
his counsel & the Court.
That he shall not be
removed out of the Jurisdiction of this
Court during the pendency of his suit and
that he shall not be subjected to any severity
on account of his application for freedom-
and that the hirer will pay the hire to the
Sheriff and return the said petitioner at
the expiration of the term for which
he is hired or as soon as said suit is determined.
agent & attorney
that said plaintiff or petitioner, also
known as
him and that he is his own property-
that for some time past he has eluded
the search of defendant - But that he
defendant has possession of said
now & that he intends to have him sent home
to his owner - & that he shall do so unless
restrained by due course of law.
He states that
dollars