Samuel Stokes, a man of color v. John Finney and William Finney
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State of MissouriMissouriCircuit CourtCircuit Court November Term AD 1838

St. Louis County ss - To the HonorableLukeLuke E Lawless ELuke E Lawless LawlessLuke E Lawless
Judge of Said Court in Chancery Sitting
Your Orator SamuelSamuel Stokes a man of color
humblycomplaining[ sheweth ] unto your
Honor that about sixteen years past your
Orator & his wifewerefree persons & their
child CharityCharity & grand child Mary Daughter
of Charity were slaves belonging to the
Estate of WilliamWilliam Stokes deceased & the
said CharityCharity & her child MaryMary werethen
offered for sale by the administrator as
execution of said Estate your orator stated
that he & his wife felt at that time
great anxiety to make such arrangements
as to secure the freedom of their child &
Grand child aforesaid but they were unable
at that time to buy them- that having
great confidence in the responsibility
& integrety & human feelings of John and
WilliamWilliam Finneywhom your orator prays may be
made defendants to this Bill he applied
to the said Finneysdescribing to them his
feelings & in relation to said CharityCharity
& her daughter & besaughtthem to purchase
said CharityCharity & her child MaryMary then about
a year old - your orator states that the
said Finneys agreed with your orator
to purchase said CharityCharity & MaryMary if they
could do so at a reasonable price & to
hold them as slaves untilsaid your
orator could pay them the price for which
they should be sold which your orator
agreed to do as soon as he could and as
soon as said price was paid said