Charles, a man of color v. Peter Verhager
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State of MissouriMissouri
County of St LouisCounty of St Louis Ss:

In the St. Louis Circuit CourtCircuit Court
July Term 1840

CharlesCharles , a man of color, the plaintiff in this action
by his attorney TT Polk .PolkT Polk & C. C.CarrollCarroll ,, complains of
PeterPeter VerhagenVerhagen , the Defendant, of a plea of trespass for
that the said Defendant on the first day of May Eighteen Hundred and forty, at the said County of St. LouisCounty of St Louis, with force
and arms, made an assault upon him the said Plaintiff
to wit, at the County aforesaid, and then and there beat,
bruised and ill-treated him, the said Plaintiff and then and
there imprisoned him the said Plaintiff, and kept and de-
tained him in prison there, without any resonable or probable
cause whatsoever, for a long time, to wit: for the space of twenty
days then next following, contrary to the laws and customs of this
State, and against the will of the plaintiff; and the said
Plaintiff avers that before & at that time of committing the a-
foresaid grievances, he was & still is a free person, and that
the said Defendant held and detained him and still holds
and and detains him in slavery against law & right and
against the will of the Plaintiff to wit: at the County
aforesaid; and other wrongs to the said Plaintiff then and
there did to the great damage of the said Plaintiff and
against the peaceanddignity of the State- Wherefore the
said Plaintiff saith that he is injured & hathsustained damage
to the amount of Five hundred Dollars & therefore
he brings this suit-

C. C. CarrollCarroll
T. PolkT Polk
for Plaintiff