Charles, a man of color v. Perter Verhagen
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then and there imprisoned him the said
plaintiff and kept and detained him in
prison there, without any reasonable or
probable cause whatsoever for a long time
to wit for the space of Twenty days then next
following contray to the laws and customs
of this state and against the will of the
plaintiff and the said plaintiff that
before & at that time of committing the aforesaid
greivances he was & still is a free
person and that the said defendant held
and detained him, and still holds and
detains him in slavery against law & right
and against the will of the plaintiff to wit
at the county aforesaid; and other wrong &
to the said plaintiff then and there did
to the great damage of the said plaintiff
and against the peace and dignity of the
State. wherefore the said plaintiff saith that
he is injured & hath sustained damage
to the amount of five hundred dollars &
therefore he brings this suit C.C. CarrollCarroll
T. PolkT Polk for plaintiff - upon which said
Petition and declaration the Clerk of said
Court Issued a summons which is
the words and figures following to wit
County of St LouisCounty of St LouisSs. The State of MissouriMissouri
To the Sheriff of St LouisSt Louis county - greeting Summons
We command you to summon PeterPeter VerhagenVerhagen Summons
if he be found in your county that he
be and appear before the judge of our
Circuit court, on the first day of the next
term thereof to be held at the city of
St LouisSt Louis within and for the County of St LouisCounty of St Louis