Marguerite v. Pierre Chouteau Sr.
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MargueriteMarguerite , a free woman of color
vs
PierrePierre Chouteau Sr Chouteau SrPierre Chouteau Sr .

B. In the Circuit CourtCircuit Court
of St Louis County, In
va action, before the
November Term 1825.

And the said MargueriteMarguerite , by her [ attornies ], as to
the said Plea of the said PierrePierre Chouteau Sr Chouteau SrPierre Chouteau Sr
by him first above pleaded, as to the said several
trespasses in the introductory part of that plea
mentioned, and therein attempted to be justified,
Saith, that she the said MargueriteMarguerite ,
by reason of any thing by the said PierrePierre
in that plea alleged, ought not to be barred
from having and maintaining her aforesaid
action thereof against him the said PierrePierre , because she saith, that she the said MargueriteMarguerite
was not, at the time of the committing of
the said several trespasses by him the said
PierrePierre , in her said declaration set forth, nor is she
now a slave, as the said PierrePierre in his said
Plea hath above alleged, but that she the
said MargueriteMarguerite was at the time of the committing
of the said several trespasses, by the
said PierrePierre , in her said declaration above
set forth, and is now a free person by and
according to the usages, customs and laws of the
land, and ought not to be held and detained
as a slave in the possession and service of
the said PierrePierre , nor of any other person by or under
whom the said PierrePierre may claim, and this
she the said MargueriteMarguerite prays may be enquired
of by the County .

Gamble, McGirk &
Farris, Attys for plff