Brunetta Barnes, by and through her next friend, Peter Charleville v. Barry Meachum
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State of MissouriMissouri
County of St LouisCounty of St Louis


In St Louis Circuit CourtCircuit Court , Nov Term 1840

Barner, by PeterPeter Chareville
her next friend false imprisonment action of
Beny Meachum

Petition to
MeachumMeachum , as prayed.

To the honourable Luke E LawlessLuke E Lawless
Judge of the Saint Louis Circuit CourtCircuit Court

The humble petition of BrunettaBrunetta Barnes
BarnesBrunetta Barnes by PeterPeter CharlevilleCharleville her next friend, resepectfully showeth to your honour. That the
applied for and obtained purmission from
your honour heretofore to bring an action of
and false imprisonment against
Beny Meachum who unlawfully detains
her in slavery. and that the has in
of that permission instituted said against
said MeachumMeachum , That she is a female of the age
of fifteen year as nearly as she can state. That
said MeachumMeachum is in the of sending her to
sell and deliver milk on board the several
lying at St LouisSt Louis . That she
is daily sent there her with milk, and that
the hour at which she is sent is at daybreak
in the morning. long before it is fully light
That she is exposed on these occasions to insults
of the character from various members of
the of different . That said MeachumMeachum
holds in his service other persons (among them her
) who areis more fit than herself for such .
That she has to said MeachumMeachum
through PeterPeter CharlevilleCharleville , a written request
in the most respectful language,
the she suffers from the employment
aforesaid, and the discontinance
of such employment in future and that
said MeachumMeachum has continued to send
her as before to said steamboats, and her declared

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his determination to pay no regard to her request

Your petitioner respectfully shows to your
honour that the hardship of which she complains
is of a nature to her, and that this application
to your honour for relief is not made in a
of or through the wish to
give annoyance or occasion in convenience to said
MeachumMeachum because she is at present exposed to
insult, which the said MeachumMeachum
space her without any to himself-

In consideration whereof she your petitioner
humbly that your honour may make
an order to the effect that the said MeachumMeachum
shall discontinue sending her on board the
steamboats aforesaid for the aforesaid
or upon any other protect whatsoever and that
your honour will grant to her & further
relief as the case may
in your honours action seem to require
and in duty bound your petitioner
shall ever pray

Thos J for