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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 Hon
The petition of
nine years humbly represents that he was born free the child of
in slavery by
Administrator of the Estate of said
held in slavery by the said
for leave to sue said
petition
to her freedom, and your petitioner begs have to refer to
said petition of
as sets forth her title to freedom may be taken as
part of this petition: and your petitioner humbly prays
that he may be permitted to sue said
recovery of his freedom by judgement of law, and may
present such suit as a poor person and have counsel
assigned him by the Court have reasonable liberty
of attending his counsel and the Court, and further that
all persons claiming under said
from removing your petitioner out of the jurisdiction
of this Court so will ever pray c
The mark
makes oath and says that the facts set forth in the foregoing petition
are true.
The mark of
No. 8.
vs
Petition to sue for
freedom
Petition filed
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.
James, a person of colour, who by leave of the Court
first had and obtained brings this suit as a poor person, by Field his counsel assigned by the Court for this purpose,
of
before and at the time of the committing of the greivances
mentioned, was and yet is a free person, and the said
arms at
did make an assault
platinfiff kept and detained him in prison for a long
space of time to
and then and there held ever since has held still holds
in
then
damage of the plaintiff, and for the recovery of his freedom
the plaintiff brings suit &c
James, coloured person vs
Suit for freedom
in forma pauperis
Let summons
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
freedom.
to the damage of said plaintiff
I acknowledge myself bound for all costs that may accrue in the above cause.
Petition filed usual order Bk 15
vs
Summons
Petition for freedom (
Field
Filed
“It is ordered that the Petitioner have leave to sue as a
poor person the Court assignes R. M. Field Esq. as his
counsel: it is further orderd that said Petitioner have
reasonable liberty to attend his counsel the Court, as
occasion may require; that he be not subjected to
any severity on account of his application for freedom,
and that he be not removed without this jurisdic-
tion of this Court.”
a copy
attest:
Executed this writ in the
1844
reading to the said
orders of the Judge, endorsed upon this
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 defendant in this action makes
and
colour instituted a
against this affiant for her freedom;
and that the process in the case of
served at the same time and as
affiant believed that there was but one
suit. Under this
counsel in the case of
but omitted to mention to his counsel the
fact that
that the defence in one case would
be a defence in both. This mistake was
not discovered until he was called upon
by the sheriff for the cost accruing
upon the judgement by Default.
Being the administrator of the late
owner of the plaintiff he knows nothing
of the merits of the claim.
this
by Walter W Blair Deputy
vs
affidavit
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 defendant in this cause moves to
Set aside the judgment
Court on the
for the following reasons to wit.
The Mother of the
for her freedom; and the process in both
defendant supposing that there
one Suit
of the Mother Supposing and believing
the defence in that
to both.
2nd Because the judgement is irregular
in this; that it is a "final judgement
of liberation upon default without proof
of the plaintiffs right to freedom, as required
by
vs
Motion to
judgment
by Default
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.
Be it remembered that judgement by default
was taken against the defendant in
this cause at the present Term for
appearance-
his affidavit which was mislaid by the Clerk
the following is agreed to be the substance
thereof by the Counsel for the
“that at the time of the service of the
“in this case a
“upon the defendant in behalf of the mother
“of the
“
“believing that they
“same action
“in the case of the mother only- That defend
“Could not make affidavit that there
“was a good defence on the
“the
“administrator- and
“which the
“to facts which are alleged to
“long before the death of the
“without the defendants knowledge
The Defendant moved to
judgement by default upon the grounds
judgment was irregular in this that it
was a final judgement of liberation
by default without the
any testimony except the facts stated in his
on the part of the plaintiff
The Court upon hearing of argument
having
the
the judgement of the Court in overruling
and prays that it may be signed and
the Court
vs
Bill of