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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Mount St. Mary's College
a corporation duly incorporated
by the laws of the state of MarylandMaryland
To the use of LouisaLouisa (a
woman of Colour) Plaintiff
vs
Francis B. JamesonFrancis B Jameson
EdmundEdmund H McCabe H. McCabeEdmund H McCabe
Defendants

In the
CircuitCircuit Court
CourtCircuit Court ,
St Louis
County,
April Term 1854

The Plaintiff,
a corporation duly incorporated by the laws
of the state of MarylandMaryland, who sues to the use
of LouisaLouisa (a woman of colour) states that
about eighteen years ago, to wit: about the
seventh day of march eighteen hundred & thirty six, the said LouisaLouisa (a woman of colour)
being then owned and prossessed as a slave
by the Plaintiff, and the Plaintiff being
at that time indebted to the defendant,
Francis B. JamesonFrancis B Jameson , for money advanced by
him for the Plaintiff an agreement was
then entered into between the Plaintif and
the defendant Francis B. JamesonFrancis B Jameson that
the said LouisaLouisa should serve him (the
defendant Francis B. JamesonFrancis B Jameson ) for five
years to pay the sum of two hundred
and fifty dollars for money so advanced,
and that at the expiration of the said
five years She was to be free; that one
of the moving considerations in said
agreement was the expressstipulation
that the said LouisaLouisa was to be free
at the expiration of the said five years,
and that the defendant, Francis BFrancis B Jameson .
JamesonFrancis B Jameson should manumit and
emancipate her at the expiration of

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the said five years; that by virtue and
in pursuance of said agreement and the
said express stipulation the Plaintiff
transferred and delivered the said
LouisaLouisa into the possession of the
defendant Francis B. JamesonFrancis B Jameson at the
time aforesaid, and she then commenced
serving him; that the said defendant
Francis B. JamesonFrancis B Jameson was them a resident
of the state of MarylandMaryland and continued
to be a resident of said state between
five and six years thereafter, during all
of which time the said LouisaLouisa continued
to serve him; that he then changed his
residence to the state of MissouriMissouri and
removed her with him to the said state,
where he has since resided and now
continues to reside.

Plaintiff further states that
the said LouisaLouisa faithfully served the
defendant Francis B. JamesonFrancis B Jameson until the
expiration of the said five years, and
that she was at the expiration of the
said five years, and still is entitled to her
freedom, and to manumission and
emancipation by virtue and in pursuance
of the express agreement and express
stipulation aforesaid; but that she has ever
since the expiraion of the said five years as
aforesaid been wrongfully & illegaly held in slavery, and claimed as
a slave, and is now wrongfully & 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