Victoire a free girl of color held in slavery, who is permitted by the court to sue by Alexis Amelin her next - friend as a poor person, by her attorneys John M Bass & Isaac G McGirk assigned as Counsel by said court complains of Francois Menard and Andre Landreville of a plea of Trespass with force & arms for that the said defendants heretofore to wit, on the first day of January one thousand eight hundred and twenty seven with force and arms at the County of St Louis , aforesaw unlawfully an assault did make in & upon the said Victoire and then and there beat, bruised & ill- treated the said Victoire and then & there imprisoned her and kept and detained her in prison, without any reasonable or probable cause what soever, and have ever kept & detained her the said Victoire in prison and do still keep and detain her in prison against her will contrary to the Laws of the state and the said Plantiff That before & at the time of the committing the grievances aforesaid she was & still is a free person and the defendents held & detained her & still hold & detain her the and said Victoire in slavery other wrongs then and there did to the said / Victoire against the peace of the state wherefore the said Victoire says she is injured and has sustained damage to the amount of five hundred dollars and therefore she sues

We commanded you to summon Francois Menard that he be and appear before the Judge of our Circuit Court at the next term thereof to be held at the City of St Louis within and for the County of St. Louis on the Fourth monday of July next then and there to answer unto Victoire who sues by her next friend of a plea of Trespass to the damage of said plaintiff of Five hundred dollars and have you then there this writ

John M Bass presents to the court the petition of Elizabeth , Virginia & Victoire children of Mary a colored woman praying that they may be permitted to institute suit against Francois Menard and Andre Landreville for establishing their right to Freedom and that they may be permitted to due as poor persons thereupon the court permit the said Elizabeth Victoire and Virginia to sue as aforesaid and direct that an action of assault and Battery and false imprisonment be commenced against the said defendants by their next friend in the names of the said Elizabeth , Victoire & Virginia and assign John M Bass and Isaac @ M McGirk as their Counsel and it is ordered by the court that the said defendants permit the said plaintiffs to have reasonable liberty of attending their counsel and the court when occasion may require it and that the said plaintiff shall not be taken or removed out of the Jurisdiction of this court and that the said plaintiff shall not be subject to any severity of treatment on account of their said application for freedom

We commanded you to Summon Francois Menard and Andre Landreville that they be and appear before the Judge of our Circuit Court at the next term thereof to be held at the City of St Louis within and for the County of St Louis on the Fourth monday of November next then and there to answer unto Victoire who sues by her next friend of a plea of Trespass to the damage of said plaintiff of Five hundred Dollars and have you then there this writ

Victoire a free girl of color vs Francois Menard and Andre Landerville.

To the clerk . This is an action of assault & Battery and false Imprisment

Let a summons issue

Executed this writ on Andre Landreville August 8th 1827 in the City of St Louis by informing him of the contents thereof and his acknowledging the service of the same - Francois Menard not found in my county Nov 10th 1827

Victorie vs Menard & Landreville. notice

And the said Andre Landreville by his Attorney causes and defends the force and injury wherefore And says he is not gulity of the said supposed trespass assaults and battery and false imprisonment & above laid to his charge or any part thereof in manner and form as the said Victoire by her next friend Alexis Amelin hath above thereof against him of this he the said Andre Landreville puts himself of upon the county

and the plaintiff doth the like Bass $ McGirk for pltff And for further plea in this behalf the said Andre Landreville says the said Victoire ought not to have or maintain her aforesaid action thereof against him because he says that he the said Andre Landreville at the times mentioned in the said declaration had not nor claimed to have nor hath he nor doth he now claim to having but disavoweth and disclaimeth to have any title claim or interest in or to the said Victoire and this the said Andre Landreville is ready to verify ; wherefore

Victoire vs Landreville

and the said Victoire for replication to the plea of the said Landreville secondly above pleaded says that she ought not to be banned & precluded from having & maintaining her action aforesaid against the said Landreville because the says that the said Landreville at the said several times in her said declaration mentioned & before the said times did claim to have & hold the said Victoire as a slave & still does claim the said Victoire as a slave and of this she the said Victoire puts hereself upon the county

Victoire vs Landreville