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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To the St Louis Circuit CourtCircuit Court

Your petitioner, LouisaLouisa , a woman of colour,
states that about seventeen years ago, to wit:
about the seventh day of march eighteen hundred and thirty six, being then owned and possessed
as a slave by Mount St. Mary's College, near
Emmitsburg, in the county of FrederickFrederick , state
of MarylandMaryland, and the said College being at that
time indebted to Francis B. JamesonFrancis B Jameson , the former
President thereof, for money advanced by him for
the same, an agreement was there entered into
between them that she should serve him 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 by virtue and in pursuance
of said agreement she was transferred and
delivered into the possession of the said FrancisFrancis B Jameson
B. JamisonFrancis B Jameson by the said College at the time
aforesaid, and then commenced serving him;
that the said Francis B. JamisonFrancis B Jameson was then a
resident of the state of MarylandMaryland and continued
to be for five or six years or between five and six
years, during all of which time she 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 residend and
now continues to reside; that since said removal
from the state of MarylandMaryland to the state of MissouriMissouri
the said Francis B. JamisonFrancis B Jameson has continued to claim
and hold her, and now claims her as a slave;
that during most or all of said time last aforesaid
to wit: for about eleven or twelve years, or between
eleven and twelve years She has been hired
and is now hired by the said Francis BFrancis B Jameson .
JamisonFrancis B Jameson to Edmund H. McCabeEdmund H McCabe , of the

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City and County of St LouisCounty of St Louis, and state of
MissouriMissouri aforesaid, in virtue of which she is
now in the possession of th esaid Edmund HEdmund H McCabe .
McCabeEdmund H McCabe and held by him in slavery.

Your Petitioner further state that whilst
in the state of MarylandMaryland, and whilstserving
the said Francis B. JamisonFrancis B Jameson in said state as
aforesaid, she was informed by an officer or
officers of said Mount St Mary's College that
the said agreement in terms as aforesaid and
upon the condition aforesaid was entered in
writing upon the books of the said College;
that she went to the said College to inquire
about it and did inquire of then Procurator
of the College whether the same was so enforced and was
informed by him that if could be found; but that
the books had been torn and defaced so that
no records of that date could be found; that
she was afterwards informed by the officers of the
said College and by the President thereof who
came into office after the [ reliving ] of the said
Francis B. JamisonFrancis B Jameson from the same position, that
the said agreement in terms aforesaid had been
made between the said Francis B. JamisonFrancis B Jameson and
the said College and that the same had been
entered in writing on the Books of the said College;
She was further informed by the sisters of CharityCharity
that the said books had been burned and
destroyed or so defaced that no record of that
date could be found

your Petitioner further states that she
has been informed in this state, and but a
short time since through the said President
who su since the removal of the said Francis BFrancis B Jameson .
JamisonFrancis B Jameson from the state of MarylandMaryland to the