Mary Charlotte, a woman of color v. Gabriel S. Chouteau
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In the St Louis Circuit CourtCircuit Court
May 24th 1845

And now the said plaintiff
by her Attorney, comes & moves the Court, to
set aside the verdict rendered in the above
suit, & grant a new trial for the following reasons
biz 1st Because the verdict was against the evidence
2nd Because the verdict was against, the weight of evidence,
3rd Because the verdict was against the Law & Evidence
4th Because the Court refused evidence of the
plaintiff to be given to the jury which should have
been given

5th Because the Court allowed evidence to be
given to the jury for the deft which should have
been refused

6 Because the instructions given by the Court
were not in accordance with the evidence,

7 Because Instructions given by the Court were
contrary to Law.

8 Because instructions asked by the plaintiff
were refused, when they should have been given

9 Because instructions were given for the
defendant which should have been refused,

10 Because the Court refused, modified, & destroy-
ed the application of the instruction asked by the
plaintiff, denying the right of British subjects
or traders residing within the United StatesUnited Statesto
hold a slave in defiance of the Laws of CongressCongress
when & where American Citizens were deprived of it,

1st 2nd '2d

HenryHenry L Cooks
Plff Atty