Charles, a man of color v. Belina Christy and Melanie Christy
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St. Louis Circuit CourtCircuit CourtMarch Term 1841

Belina ChristyBelina Christy

And the said defendant
in her own proper person comes and says that
this Court ought not to have or take further
cognizance of the actions aforesaid because she
says that the said ()
trespasses and false imprisonment in the
declaration mentioned and the said holding in
slavery therein mentioned, were done in the
State ofIllinois IllinoisIllinois & not elsewhere & by reason
of a claim to the services of said plaintiff
under the laws of that State: and the said
plaintiff so being held by defendant to service
in IllinoisIllinois, under color of the laws thereof,
escaped & ran away from defendant
to the State ofMissouri MissouriMissouri, against the will
of defendant & brought this suit: he the said
plaintiff never having resided in the State ofMissouri
MissouriMissouri at any time and this the defendant
is ready to verify, wherefore she
prays judgment&c.

SpaldingSpalding & TiffanyTiffany
attys for deft