Jesse, a man of color v. George W. Coons
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State of MissouriMissouri
St. Louis County
ss.

JesseJesse , a man of color, plaintiff
in this action, complains of George WGeorge W Coons .
CoonsGeorge W Coons , defendant in said action, of a plea
of trespass and false imprisonment; for that
the said defendant on the twenty fifth day of May in the year of Our Lord eighteen hundred and forty four, with force and
arms, at the County aforesaid assaulted the
said plaintiff and then and there beat, bruised
and ill-treated him, and then and there imprisoned
him and then and there kept and
detained him in prison, without any reasonable
or probable cause whatsoever for a long time
to writ: for the space of six hours then next
ensuing, against the will and consent of the
said plaintiff and contrary to the laws of
the State of MissouriMissouri, and the liberties of
the people thereof; and the said plaintiff
avers that before and at the time of the committing
of the grievances above set forth he the
said plaintiff was, and still is, a free person, and
that the said defendant wrongfully and
unjustly, held and still holds him, said
plaintiff, in slavery; and other wrongs
to the said plaintiff then and there did
against the peace of the State of MissouriMissouri
and to the damage of said plaintiff
five thousand dollars, and therefore he sues

Risque
â TownsendTownsend for plff.