Jeffrie vs. Joseph Robdoun
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wound, bruise & ill treat the said JeffrieJeffrie and did then and there
seize, lay hold of & falsely imprison him the said JeffrieJeffrie and
then and there kept & detained him the said JeffrieJeffrie in prison
against his will without any probable or reasonable cause what
soever and still does at the county aforesaid detain and impris-
on him the said JeffrieJeffrie without any probable or reasonable cause what
soever and still does at the county aforesaid detain and impris=
on him the said JeffrieJeffrie without any probable cause
whatsoever and against the will and consent of him the said
JeffrieJeffrie and other wrongs to the said JeffrieJeffrie then and there did
to the damage of the said PlaintiffJeffrieJeffrie of one thousand dol=
lars & against the peace & dignity of the state of MissouriMissouri
& therefore he sues &c - PettisPettis atty for Plff = And also for that
the said Defendant heretofore to wit on the day and year
last aforesaid at the county aforesaid with force and arms made a assault upon him the said JeffrieJeffrie and then & there
beat, bruised, wounded, maimed, and ill-treated him the said
JeffrieJeffrie and then & there unlawfully held, detained and im-
prisoned him the said JeffrieJeffrie against his will and consent &
without any legal cause whatsoever & has ever since held, detain
ed and imprisoned him the said JeffrieJeffrie & still does hold, detain
and imprison him the said JeffrieJeffrie against his will & consent &
without any legal cause whatsoever and other wrongs to
the said JeffrieJeffrie the said defendant on the day and year last
aforesaid at the county aforesaid then and there did against
the peace and dignity of the State of MissouriMissouri and to the
damage of the said JeffrieJeffrie of one thousand dollars & therefore
he brings suit &c PettisPettis Atty for Plffâ and afterwards to wit
on the fourth day of February in the year 1824 the following plea
was filed in said cause to wit = "JosephJoseph Robidous = adsm =
Jeffrey = And the said RobidouxRobideaux by his attornies comes and de-
fends the wrong and injury when &c and says that the said
Jeffrey ought not to have or maintain his aforesaid action
thereof against him the said RobidouxRobideaux because he says that
the said Jeffrey is his slave, without this that the said Jeffrey
at the time of the commencement of the said suit was a
free person and of this he the said RobidouxRobideaux puts himself upon
the country &c Shother & Coseuzâ - âAnd the said Plff by his attorney

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action thereof against him &c StrotherStrother & Coseuz for deft-" and
on the same day and year the follow replication to the aforsaid
Replication plea was filed to wit = âAnd the said Plaintiff, by his attorney
for replication to the aforesaid plea of the said defendant says -
that he ought not to be barred or precludeds from having his
aforesaid action thereof against the said defendant because
he says that at the _ of the committing of the aforesaid assault
& Battery & False Imprisonment he was not the slave of him
the said RobidouxRobideaux - And this the said plaintiff says prays may
be inquired of by the country PettisPettis for Plffâ = And afterwards
to wit on the seventh day of October in the year eighteen hundred and twenty threethe fo in the said Circuit CourtCircuit Court , the following
further precedings were had to wit "JeffrieJeffrie -vs- FrancoisFrancois Robi-
doux On motion of the Defendant by his attorney leave is given
him to amend his pleadingsâ Whereupon in the year last aforesaid
last aforesaid & on the thirty first day of the said month of Oc-
tober the following amended declaration was filed music pro tune by consent in the office
Declaration = of the said Clerk to wit "St Louis County = Circuit CourtCircuit Court Febru-ary Term 1823 - JeffrieJeffrie a Mulatto Boy by RachelRachel Camp his next
friend who sues as a poor person by PettisPettis their attorney complains
of Joseph RobidouxJoseph Robideaux of a plea of trespass for assault & Battery
& false imprisonment. For that the said Defendant heretofore
to wit on the first day of October in the year Eighteen hundred and twenty at St LouisSt Louis to wit at the county aforesaid with
force & arms did then and there assault beat and ill treat
the said JeffrieJeffrie and did then and there seize and lay hold of
the said JeffrieJeffrie and then and there imprisoned the said Jef-
frie and then & there kept and detained him the said JeffrieJeffrie
in prison against his will & without any reasonable or probable
cause whatsoever & still does detains & imprison the said
JeffrieJeffrie against his will & consent & other wrongs to the said
JeffrieJeffrie the said defendant then and there did against the
peace and degnity of the State of MissouriMissouri to the great
damage of him the said JeffrieJeffrie of one thousand dollars
and therefore he sues &c - And for that the said defendant
heretofore to wit on the day and year aforesaid at the County aforesaid with force and arms did then and there assault, beat