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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
of color respectfully represents, that she is held
as a slave in the county aforesaid by one D. Franklin
Knox, who claims her as his property - but petitioner
belives that she is entitled to freedom, and states
as her ground to freedom, the following facts - that
in the year
the property of said
of
detained to service and labor as a slave from the
month of June of that year until the succeeding month
of September, when she was again brought back
to the county of
such a holding of petitioner as aforesaid in slavery
in the state of
of the
and laws of the state of
from a state of
honorable court for leave to sue as a poor person
in order to establish her right to freedom.
Petitioner further
to sell her, so as to carry her out of the jurisdiction
of this court, and she therefore prays, that a warrant
may be issued and such
by the act entitled ``cca act to unable person
in slavery to sue for this freedom'' and she will pray de.
sworn says that the facts set forth in the forgo-
ing petition are true.
First, that said
a poor person, to establish her right to freedom, and the
Court assigns as her counsel
Second. that said Cloe Ann smith have reasonable
liberty to attend her counsel and the court as occasion
may require; that she be not removed out of the jurisdic-
tion of the Court, and that she be not
on account of her 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.
of
the said defendant on the
eighteen hundred and forty four
&c made on an
wit at
there beat,
plaintiff and then and there imprisoned her, the
said plaintiff and kept and detained her in prison
there, without any reasonable or probable cause
whatsoever, for a long time, to wit, for the
twenty four hours then next following, contrary
to the laws of said state and against the will
of the said plaintiff. And the said plaintiff
ting of the said
a free person, and that the defendant held and
still holds her in slavery - To the plaintiffs
damage ten dollars and therefore she brings
of color
vs
Trespass in false imprt
suit for freedom.
No Circuit returnable
Tuesday morning
at 9 o'clock
1844
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
he be found in your County that he be
and appear
before the Judge of our
be held at the
third Monday of
false imprisonment
to the damage of said plaintiff
dollars: And have you then there this writ.
I acknowledge myself bound for all costs that may accrue in the above cause.
Witness my hand and seal, at
vs
Field & Murdoch
It is ordered by the Court that the said
as her counsel, 2nd that the said
attend
occasion may require that she be
removed out of the
court and that
any
Executed this
on
it
within
by reading to him the said
on this writ
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.
You are hereby commanded to seize
or, in whose possession soever she be found; that you have her before the
Judge of our
een hundred and forty-four
possession the said
time and place, and before the Judge aforesaid.
Summoned
Judge of the
Oclock
vs
Executed this com
mand in the
1844
Within
Custody of the Jailer
of
ty - with whom
she is left for safe
keeping
for by
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 T.
Knox his attorney comes and defends the
injury when &c and
the said supposed Trespass above said to his charge
or any or either of them or any part thereof, in manner
and form as the said plaintiff hath above thereof
against him, And of this he said defendant puts himself
upon the county &c.
Chloe A. Smith
vs
Plea
Not Guilty
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
respectfully states, that there is now defending
in said
false
imprisonment, wherein this petitioner
is plaintiff and one
defandant: That she has just cause to
believe that
in
the
the said plaintiffs
right to
that she has
the
vs
Petition for change
of venue.
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 plaintiffs counsel
come into court
and move the
to set aside the
non suit in this case
entered for the following
reasons, and to certify the same
to the court of
1. Because the plaintiff has filed in
this case a petition as provided for by
for a change of
2. The Court
3. Because the court had no jurisdiction
in this case after the
petition duly sworn to, the statute
making it
certify the case to another
vs
Motion & reasons
to
and to certify the case
to the court of