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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the defendant, Francis B.Jameson from the
State of MarylandMaryland 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, Francis B. JamesonFrancis B Jameson , to the
defendant Edmund HEdmund H McCabe . McCabeEdmund H McCabe , of the city and
county of St LouisSt Louis, and state of MissouriMissouri
aforesaid, in virtue of which she is now in
the possession of the defendant, EdmundEdmund H McCabe HEdmund H McCabe . McCabeEdmund H McCabe
and wrongfully & 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
HEdmund H McCabe .McCabeEdmund H McCabe , who is a physician; that the cost
of clothing has not exceded the average sum of
eighteen dollars per year.

Plaintiff further states that the
agreement above set forth, 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 B. JamesonFrancis B Jameson as aforesaid;
that examination of said books was made within
a few years thereafter, and has since been made,
an injury also made of the proper officers, 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
for produce such writing.

Plaintiff further states that

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an instrument of writing was given by the Plaintiff
to the defendant Francis B. JamesonFrancis B Jameson , at the time
of the making of the said agreement, stating the
same as above setforth and the express condition
and premise that the said LouisaLouisa at the expiration
of the said five years was to be free as aforesaid,
and that the moving consideration in giving said
instrument of writing was the express stipulation
that the said LouisaLouisa was to be free at the expiration
of the said five years, and that the defendant,
Francis B. JamesonFrancis B Jameson should manumit and
emancipate her at the expiration of the said
five years

Plaintiff asks that the defendant,
Francis B. JamesonFrancis B Jameson , may be compelled by the
judgement of this court to specifically execute and
perform the said agreement, and to manumit
and emancipate the said LouisaLouisa , and further
that he may be compelled to render an account
and make payment for the value of the
service of the said LouisaLouisa beyond the said
five years as aforesaid, during the illegal
detention of the said LouisaLouisa by the said
defendant, Francis B. JamesonFrancis B Jameson , so wrongfully
commissed as aforesaid

Plaintiff further asks that
the said Edmund HEdmund H McCabe . McCabeEdmund H McCabe be made a party
defendant to this petition, and that he be required
to answer the same; and further that he may
be compelled to render an account of the value
of the service of the said LouisaLouisa during the time
she has been hired to him as aforesaid, beyond
the said five years as aforesaid, during her
illegal detention so wrongfully committed as
aforesaid; that he be enjoined and restrained