Petition to sue,
for freedom as a pauper

Wit PeterPeter Doolins St LouisSt Louis, Benedict, S LouisS Louis
John Ken in S LouisS Louis,

2 subp issued,

Trespass assault & Battery damage, 1000.

The aforesaid JacobJacob Horens,
by CarrCarr his attorney, comes & defends, the charge,
of the wrong & injury, when and saith, that he
is not guilty, of this he puts himself upon, the
county, and for further plea in this behalf,
the said JacobJacob says, that the said plaintiff is & always, has been, a slave upon his birth, & the
propeprty, of him, the defendant, and that he
purchased him, of one condition Agasse Brooke,
in the state, of KentuckyKentucky, on the twenty fourth, day
of July eighteen hundred & ten, of the
said Bill the following Bill, of sale to wit, In consideration, of three hundred fifty,
dollars, to me this day granted, bargained, sold set over & delivered, a certain negro man, by the known by the name, of Bill aged twenty,
four or twenty five, years, or, there about, for which I warrant & defend, the bills, of s. negro,
all persons whatsoever, & also warrant him clear, of all impediments as witness my hand & seal, this 24th day of July 1810&â

Wherefore, the said JacobJacob Honne prays judgment the whether the plaintiffs action might, not to be barred,

The the plaintiff joins issue on, the first plea,, and
as to the second plea (protesting, that the defendant, did not obtain such bill of sale as therein alledged) for replication thereto, say

that he on the day of the assault, & false in
prisonment, said in his declaration way and
still is, free, and of this he puts himself,
upon the the county

Plea,

Whereas, a petition from BillyBilly Tarlton, a man of
colour,, has been presented to the court of common pleas, of the
county of Saint LouisSt Louis, praying the said court to admit the
said BillyBilly Tarleton to sue, as a pauper, for his freedom he being
held (as he states) in unlawful servitude, by a certain Jacob HorineJacob Horine ,
affidavit of WilliamWilliam RussellRussell , of Joachim, on file that he has prob-
able reason to believe that the matters contained in the said petition,
are true whereupon the court assigned D Barton Esquire, as cousel
for said BillyBilly Farleton,, to issue, against Jacob HorineJacob Horine , and take
the proper measures in this case, agreeably to the statute, in such
case made, and provided, And the court did order and dirict that
the said Jacob HorineJacob Horine , permit the said BillyBilly Farleton, to have a reason-
able liberty, of attending his counsel and this court whenever occasion
may require it and that the said petitioner, shall not be taken
nor removed out of the jurisdiction, of this, court, nor be subjected to
any severity, because of his application for freedom
we command you that you summon Jacob HorineJacob Horine , if he may
be found within your bailiwick, that he be, and appear before,
the judges of our court of common pleas to he holden at the
town, of SaintSt Louis, LouisSt Louis within and for the said county of st Louis
on the third, monday of february next then &, there to answer unto
WilliamWilliam Farleton,, otherwise called BillyBilly Farleton,, otherwise called
Bill a black man, in a plea, of trespass assault, and, battery, and
false imprisonment, to the Damage of the said WilliamWilliam Farlton,
otherwise called one, thousand Dollors as it is said,
have you then there this writ,

WilliamWilliam Farlton,, otherwise called BillyBilly Farlton,
otherwise called Bill, a black man who is admitted
by the court here to sue in this behalf, as poor person, com-
plain of Jacob HorineJacob Horine , of a plea, of trespass, with force
and arms, for that heretofore, to wit on the first day of may in the year of our Lord, one thousand eight hundred and thirteen, the said , with force and
arms at the township of Joachin, in the county aforesaid,
and within the jurisdiction, of this court, did make
an assault, on him the said WilliamWilliam Farlton,, and
him the said WilliamWilliam ,, did then and there unlawfully beat wound, and abuse, take, enslave, and imprison,
and him the said WilliamWilliam , in prison, and deprived
of his liberty there for a long time to wit from the
said first day of may in the year last aforesaid,,
untill the twenty fourth day of september then
next ensuing, without any reasonable and lawful
cause, and against the laws of this territory, did
detain and other outrages, on him the said
WilliamsWilliams , then and there committed. against the
peace of the united states of AmericaAmerica, and of this
territory; and to the damage of the said WilliamWilliam Farlton, otherwise called as aforesaid,, one thous-
and dollars therefore, he sues, by his counsel assigned, him by the court

in assault
battery false imprisonment,

Let a writ of sum
mons its issue, in a plea
trespass, assault, battery and false imprisonment,
to the plaintiff's demage
one thousand, dollars
and attach to the writ
a full copy of the
order of the court in
this case.

This third day of October in the year of our Lord one thousand & eight hundred and thirteen and of our inde-
pendence the thirty eighth

Tr, ass, battery, false imprisonment,

JacobJacob Horine ,HorineJacob Horine the deft being, duly sworn,
says that he purchased, the plaintiff in KentuckyKentucky,
as a slave, from one certain Squire Brooke living, in JeffersonJefferson county, that he send, by
his deponents brother, to said, Brooke to fur,
nish him, with the necessary proof, of
to said plaintiff time sufficient for him, to
return, to this term but, he has not, yet re, turned that he does not think he can safely,
go to trial, without the evidence, of said Brooke,
the Bill, of sale, which Deponent supposes,
is in his possession such other evidence, as he
can furnish, that deponent, does not think he ought, to permit, this case to go on, to trial without giving, him said Brooke on opportunity, of establishing, his right, to sale said plaintiff, as a slave, that he expects to recieve, an answer, from said Brooke, sufficient, to be ready, for trial, as the
next term,

You are hereby commanded to summons Benedict & John
Keer that setting aside all manner of excuse, and delay they be and appear, in proper
PersonPerson before the judges of our court of Common, pleas on the twenty first day of February next, at the town, of saint, Louis then & there to testify and the truth to,
say in a certain matter of controversy now pending in our said court wherein WilliamWilliam
Farlton is, Plaintiff and Jacob HorineJacob Horine , defendant on the part, of the defendant, and
have you then there this writ.

Subpa, for
Benedict

John KerrJohn Kerr of the couty
of St LouisSt Louis

Executed

You are hereby commanded to summon Benedict Kerr & John Kerr,
that setting aside all manner of excuse and delay they be and appear in proper person
before the judges, of our court of common, pleas on the twenty eighth day of junenext, at the town of StSt Louis. LouisSt Louis, then there to testify and
the truth to say in a certain matter of controversy now pending in our said court, wherein
BillyBilly Farlton, is plaintiff and Jacob HorineJacob Horine ,
defendant on the part of the plaintiff, and have you then there this writ.

subpa- for
Benedict & John Kerr
of S Loius county

Executed

You are hereby commanded to summon Jno Benedict K & John Kerr,
that setting aside all manner of excuse and delay they be and appear in proper person
before the judges of our court of common pleas, on the fourth
monday of october next, at the town of StSt Louis. LouisSt Louis, then there to testify and
the truth to say in a certain matter of controversy now pending in our said court, wherein
WilliamWilliam Farlton, is plaintiff and Jacob HorineJacob Horine ,
defendant, on the part of the plaintiff, and have you then there this writ.

subpa, for
mr. Benedict & copy
John KerrJohn Kerr
of St LouisSt Louis county
1st leres

Executed

You are hereby commanded
that setting aside all manner of exuse and delay you be and appear in a proper person
before the judges of our court of common pleas, on the 25th day of October, at the town of StSt Louis. LouisSt Louis, then there to testify and
the truth to say in a certain matter of contrversy now pending in our said court, wherein
WilliamWilliam Farlton, a negro, is plaintiff and Jacob HorineJacob Horine ,
defendant, on the part of the plaintiff and have you then there this writ.

subp

Executed

To my attendance, this term,
as a witness four, Days $2.00
traveling to
60 miles

twenty miles 3.10

a petition, in behalf, of a BillyBilly Farlton