To the Honorable Luke E. Lawless judge of the cir-cuit court of St Louis county : the petition of Andrew by Celeste his mother and next friend respectfully represents. That in the month of october 1799 on certain. Robert Bunton (then and for many years subsequent a resident of Vincennes in the north western terretory) purchased of a certain William Jullian in the town of Louisville and state of Kentucky . Judy the grand mother of your petition-er as a slave for life and immediately thereaf-ter brought the said Judy to Vincennes aforesaid the place of his residence where she was kept and used as a slave by the said Bunton and family untill th about the month of april 1800, at which time she was delivered to a certain Touisant Dubois who brought her to Kaskaskia in the territory aforesaid, when she was deliverd to a certain Peter Menard who brought her to St Louis in the territory of upper Louisiana and sold her in the month of aug-ust 1800 to a certain Wm. H. Lecompte .

Your petitioner further represents that the said Judy remained in slavery until a short time since, when she and several of her children with the said Celeste were pronounced to be free by the verdict & judgment of the circuit court of St. Louis & St Charles county. Your petitioner further represents that he is now held in slavery by a certain Peter Sarpy contrary to law, he therefore prays that he may be permitted to bring suit as a poor person by Celeste his mother and next friend for the recovery of his freedom against the said Peter Sarpy . Your petitioner further represents that he is appre- hensive that the said Sarpy may send or take your petitioner beyond the bounds of this State , he your petitioner therefore prays that the said Sarpy . be com-pelled to bond and security. to have your petitioner forthcoming to answer and abide by the judgment of the court in the premises and may it please your honor to make the usual orders in such cases made & as in duty bound will ever pray -

This day Celeste a free woman of color personally appeared before the court designed a petition of the peace for the county aforesaid and made oath that the matters and things in the foregoing peti-tion contained to far as they abpend upon her own knowledge an and then and there coming from the information of others she belives to be true.

It is hereby ordered that Andrew be allowed to sue as a poor person to establish his right to freedom by Celeste his mother and next friend and that Ferdinand W Risque is assigned him as counsel for that purpose.

That the said Andrew have reasonable liberty to attend his counsel and the court, as occasion may require; that he be not removed out of the jurisdiction of the court and that he be not subject to any severity on account of his application for freedom.

Andrew by Celeste his mother & next friend vs Peter Sarpy Petition

Andrew by Celeste his mother and next friend by leave of the court first had and obtained com-plains of Peter Sarpy of a plea of trespass for false imprisonement. For that the said defen-dant heretofore to wit on the first day of July in the year of our Lord one thousand eight hun-dred and thirty nine with force and arms assaulted the said plaintiff to wit at the county aforsaid and then and there beat bruised and ill treated him and then and there im-prisoned him and kept and detained him in prison there without any reasonable or pro-bable cause whatsoever, for a long term, to wit: for the space of hours then next following contrary to law and to the will of the said plaintiff, and the said plaintiff avers that before and at the time of the committing of the grievances, was, and still is, a free person and that the defendant held and still holds him in slavery , and other wrongs to the said plaintiff then and there did to the damage of the said plaintiff two hundred dollars and therefore he brings his suit &c.

Andrew by Celeste his mother and next friend vs Peter Sarpy Declara-tion.

This is an action of Tres--pass for false imprison-ment to recover freedom Damage $200. Clerk will issue summons.

We command you to Summon Peter Sarpy if he be found in your county that he be and appear before the judge of our Circuit Court , on the first day of the next term thereof, to be held at the City of St. Louis , within and for the County of St. Louis , on the third Monday of November next, then and there to answer unto Andrew , whosues by Celeste his mother and next friend of a plea of trespass for false imprisonment to the damage of said plaintiff of two hundred dollars: And have you then there this writ.