James, a person of color v. Hiram Cordell
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JamesJames a person
of Colour
Hiram CordellHiram Cordell

Circuit CourtCircuit Court of
St Louis County
November Term 1844

The defendant in this cause moves to
Set aside the judgment entered by this
Court on the 25th day of November 1844
for the following reasons to wit.

The Mother of the present plaintiff commenced
suit in this Court against the defendant
for her freedom; and the process in both
cases was served at the same time. The
defendant supposing that there was but
one Suit [ imployed ] Counsel in the case
of the Mother Supposing and believing that
the defence in that casewould be a defence
to both.

2nd Because the judgement is irregular
in this; that it is a "final judgement
of liberation upon default without proof
of the plaintiffs right to freedom, as required
by Statute

Jarver Attorney for