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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.
To the honorable Luke Lawless one of the Judges of
the Circuit Court of the
of Michael
the said
years ago and since the
and eighty seven, and that he has never done any thing
where by he had
that he the said
forfeit his freedom yet be the said J. J. Birdsong has and
Law right and against his will in the
the county of
as he the said
of this State, in order that he may sell him as a
four one of the near Southern States. wherefore your
petitioner humbly prays your
made, that your petitioner be allowed to sue as a poor per-
son, for the purpose of
Honour
Honour with also order, that the petitioner have reasonable
liberty to attend his counsel and the court, when
may require; and that the petitioner be not taken or re
moved out of the jurisdiction of the Court, nor be subject
to any severity
and your petitioner as in duty found
duly sworn according to law deposeth saith that the
knowledge & belief
best information which he had gathered he
that it is the pupose and intention of the within named
J. J. Birdsong to carry the within
carry him to one of the Southern States in order to sell him as
a slave - that the said Birdsong is what is
negro
purpose of
is now engaged in making purchases of the kind with this
and for this end
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 this suit was summoned to answer.
the plaintiff in this suit in a plea of
battery and false imprisonment, and therefore the said
Michacl
attorney, complained against the said G. G. Birdsong
for that the said defendant on the
A.D. 1835
to wit at
there beat
imprisoned and kept
any reasonable or probable cause whatsoever, for a long
time to wit, for the space of twenty days then next following
contrary to the laws and
the will of the said plaintiff and the plaintiff avers
that before and at the time of
grievances he was and still
defendant held and detained and still holds and
the plaintiff and other wrongs to the said plaintiff then
and there
and against the peace and dignity of the State -
hath sustained damage to the amount of five hundred
dollars and therefore he brings this suit.
We command you to summon J. J. Birdsong that he be and appear before the Judge
of our
then and there to answer unto
and false imprisonment wherefore the said plaintiff saith he is injured and hath sustained
damage to the
Executed this writ by reading
affidavit and order of the
Birdsong on the
of
vs
J J Birdsong
action
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.
It is
The petition of
a coloured