the petition of Peggy Perryman respectfully represents that on or about the first of december past, - - she was residing, with her friends, in Arkansas , in the peaceable enjoyment, of her freedom and civil rights, to which she was enitled by her parents, by being free persons, her father, a free person of color, in said state, and her mother was lawfully married, to her her father, an Indian of, the Black foot tribe Your Petitioner represents, that about that time she was suddenly seized, by persons, to her before unknown gaged, and transported, and finally sold into servitude that, her her relatives, by the mother side and, all not, only free since, the memory of man but are distinguished, among their tribe, your petitioner represents as such free born person she, is entitled, to her freedom from the engagement of which she is, wherefore she prays, in considerationof the promises she, may have leave, to sue, as a poor person, in order to establish, her right, to freedom and that counsel, to her for that purpose, order be made, as to secure of prosecuting, her said, as in duty bound she,

by the court, in the, petition, shall during suit have reasonable liberty of all and the court that she and,, of the state or jurisdiction that she shalln not be subject to any severity on account of her application, for her freedom, and that she be permitted to sue, as a poor person,

Peggy Perryman , a free woman, of color, complained of Joseph Philibert, of a plea, of trespass, for false imprisonment, for that whereas heretofore to wit, at the city and county of saint louis, and state of missouri, as about, the spring of the year one thousand eight hundred and forty seven as your petitioner recollects, the said Joseph Philibert drendant aforesaid then, and there with, force and arm assaulted, the said Peggy and her the, said Peggy then, and there took, and imprisoned and restrained, her of her liberty, and her the said Peggy held in servitude from, the spring of the year 1847 at which time, as your petitioner, is informed the said defendant, purchased her from one Bartley untill, the present time, and still holds her in servitude, without any reasonable or probably cause, against the law, of the land and against the will of her, the said Peggy , and that she Peggy , before and at the time of the, said greivances was, and still, and that the said defendant holds her in servitude,, and servitude, and to the great damage, of and therefore, she sues,

to dismap suit 18p 347.

Executed this order of Court by reading, it and the Petition and declaration to Joseph Philibert in the County of St Louis April 28th 1848

Service 50 Copy 1,10

The Petition, of Peggy Perryman respectfully represents, that on or about the first day of december 1845 She residing with, her friends, in Arkansas , in the enjoyment, of her freedom, and and civil rights, to which she was entitled, her parents being, free persons, her father, a free person of color, of color in said state, and her mother who was lawfully married, to her father an Indian, of the Black Foot tribe. your petitioner represents, that about that time She was suddenly seized, by persons to her before unkown, gaged and transported, and finally sold, into servitude, that her relatives, by the mother side and all not only free since, the memory, of man, but and distinguished, among their tribe, - your Petitioner represents, as such free person, she is to her freedom from at which she is now restrained, by Joseph Philibert Wherefore, she prays, in consideration, of the promises, she may have had to sue as a poor person, in order to establish, her right to freedom and that counsel, may be to her for that, purpose and that such order be made as to secure, her in the privelege, of presenting, her said claims and, as in duty bound, she will pray

suit for freedom

plaintiff attend counsel, to 19 p 26 motion to dismap, .

Peggy Perryman a free woman of color complains of Joseph Philibert of a plea of Trespass, for false imprisonment for that, at the city and County of St Louis and State of MO during the spring of 1847, your petitioner recollects the said Joseph Philibert defendant then, and there, with force, and arms assaulted, the said Peggy , and then, and there took, and imprisoned, and her of her liberty and her, the said Peggy held in serviude, from the spring of the year, 1847 at, which time the present, time and still holds her, in such servitude without any reasonable or probably casue against, the law of, the land and against, the will of her, the Peggy , and she, the said further, and declares that she before, and at the time, of the committing of, the said greivances, was and still, is a free person and, that the said Deft, held and still, holds her, in servitude and slavery against, the will of, and and to the great damage of the said Peggy , and therefore she sues,

It is ordered, by the court, in the within case that the petitioner shall be allowed, , to sue as a poor person and shall, the of this suit have reasonable liberty of attending her counsel and, the court and that she shall not be removed out of the state of or jurisdiction of this court, and shall not be subject to any severity on account of her application, for freedom and that she be permitted to sue, as a poor person,

Personally

We command you To Summan Joseph Philibert 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 Mon-day of next, then and there to answer unto Peggy Perryman (ofcolor) of her petition for freedom. filed V dr3th 1848. And have you then there this writ.