Mary Charlotte, a woman of color v. Gabriel S. Chouteau
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[missing figure]
Mary CharlotteMary Charlotte (of color)
GabrielGabriel S Chouteau S. ChouteauGabriel S Chouteau

In the Circuit CourtCircuit Court
of St. Louis County
April Term 1853

And now at this day comes the said plain-
tiff by her attorneys and moves the court to set
aside the Judgment of non suit in this case
and to grant the said plaintiff a new
trial for the following reasons

1st Because the said plaintiff was surprised
by the objection of Defendants to the admission
or evidence of the and certified copies of the
two deeds () from AndrewAndrew ToddTodd to Joseph Didier and
of Joseph Didier to AugusteAugust Chouteau ChouteauAugust Chouteau (here set out
said copies)

2nd because the court erred in refusing to allow
said deeds to be given in evidence to the jury-

3rd because the court erred in refusing to admit
legal and competent evidence offered by the

4th Because the court erred in instructing the
jury that there was no evidence before them
authorising them to find a verdict for said

5th because the court otherwise erred on the said
Judgment of non suit was otherwise erroneaus and void.



for plaintiff