Mount St. Mary's College to the use of Louisa Mahoney, a woman of color v. Francis B. Jameson and Edmund H. McCabe
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aforesaid; but that she has ever since
the expiration of the said five years
as aforesaid been wrongfully and illegallyheld in Slavery
and claimed as a slave and is now wrongfully and illegally
held in Slavery and claimed as a
Slave, by the Defendant FrancisFrancis B Jameson B. JamesonFrancis B Jameson .

Plaintiff further states that
during most or all of the time since
the removal of the Defendant FrancisFrancis B Jameson
B. JamesonFrancis B Jameson from the State of MaryMary
land to the State of MissouriMissouri, to wit:
Between eleven and twelve years
the said LouisaLouisa has been hired, and
is now hired by the Defendant FrancisFrancis B Jameson
B. JamesonFrancis B Jameson to the Defendant EdmundEdmund H McCabe
H. McCabeEdmund H McCabe , of the City and CountyCounty of St Louis
of St. LouisCounty of St Louis, and State of MissouriMissouri
aforesaid in virtue of which she is
now in the possession of the Defend
ant EdmundEdmund H McCabe H. McCabeEdmund H McCabe and wrongfully and illegally held
by him in slavery; that she has
been and is, hired as aforesaid at the
rate of ninety six dollars per
year, out of which it was agreed
her clothing and bills for medical
attendance should be paid; that
but little medical attendance
has been required, which has been
rendered free of charge by the
Defendant EdmundEdmund H McCabe H. McCabeEdmund H McCabe
who is a Physician; that the
cost of clothing has not exceeded
the average sum of
dollars per year.

Plaintiff further states

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that the agreement above setforth, in
terms as set forth, and upon the express
stipulation as set forth, was entered in
writing upon the books of the Plaintiff,
so being a corporation as aforesaid,
at the time the said agreement was
made between the Plaintiff and the
Defendant Francis BFrancis B Jameson . JamesonFrancis B Jameson as
aforesaid; that examination of said
books was made within a few years
thereafter, and has since been made
and inquiry also made of the proper
offices, but that the said books had been
burned and destroyed, and torn and
defaced so that the said agreement
so entered in writing as aforesaid,
could not be found, and so that no
record of that date could be found;
and that Plaintiff cannot, therefore,
produce such writing.

Plaintiff further States
that an instrument of writing was
given by the Plaintiff to the Defend
ant Francis B. JamesonFrancis B Jameson , at the time
of the making of the said agreement,
stating the same as above set forth
and the express condition and proviso
that the said LouisaLouisa at the expira-
tion after the said five years was to be
free as aforesaid, and that the
consideration in giving said in
strument of writing was the express
stipulation that the said LouisaLouisa
was to be free at the expiration