Nelson Kerr, a man of color v. Matthew Kerr
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State ofMissouri MissouriMissouriCircuit CourtCircuit Court Third Judicial
Circuit
July TermAD 1834

St Louis County SS Nelson KerrNelson Kerr a man of color by
BirdBird his attorney complains of Matthew KerrMatthew Kerr
of a plea of tresspass assault & battery & false
imprisonment for that heretofore, towit on
the first day of September in the year of our
Lord eighteen hundred & thirty three at StSt Louis LouisSt Louis aforsaid the said defendant with
force & arms an assault did make upon him
said plaintiff & him the said plaintiff did
then & there hurt bruise wound & ill treat
and the said defendant did then & there
unlawfully imprison the said plaintiff & hath kept
& detained him in prison there from
then [ untill ] the commencement of this
suit & other wrongs to the said plaintiff
then & there did against the peace & dignity of the state and the plaintiff
that before & at the time of the
committing said the
said plaintiff was and is now a free person
and the defendent held & detained & still
holds & detains plaintiff in slavery wherefore
plaintiff says his is greatly injured & hath
sustained damages to five hundred dollars
therefore he sues to

GA BirdGA Bird atty


for Plff