Pierre, a man of color v. Gabrial Chouteau
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In the S LouisS LouisCircuitCircuit Court
CourtCircuit Court
April Term 1852

and now comes the said
plaintiff by Cobbs his attorney and
moves the Court to set aside the order
of dismissal made in this suit and
to reinstate the same on the docket
for a trial on its merits for the following
reasons viz:

1st Because the order of dismissal
was made when W Field, one of plaintiffs
counsel had removed from the state,
Hall the other was dead, and the
plaintiff was confined in jail, having
been in prison there ever since the 5th day of april 1848.

2nd Because this Court has given
a judgement of liberation in favour of this
plaintiff against this defendant &
the evidance of this plaintiffs right to
a reaffirmance of that judgement is
on file in this suit.

3rd Because a refusal of a trail of
this suit for freedom on its merits
is a violation of the compromise
being the statutes of the United StatesUnited States &
against the peace & dignity of the
state of MissouriMissouri, as also of the Union