Joseph Jefferson, a free man of Colour vs. James McKnight, William McCutcheon
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Executed this petition on James McKnightJames McKnight by reading the same to him this 24th Oct. 1826

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No 23-

Nov Term 1826

In the CircuitCircuit Court CourtCircuit Court
July Term, 1826.

JosephJoseph Jefferson JeffersonJoseph Jefferson
vs
William W.Chouteau&
James M.Knight
Petition to the
to sun as a poor person
for his founder.

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State of MissouriMissouri
County of St LouisCounty of St Louis

In the circuit court July term 1826

To the Honorable, the Judge of the cir
cuit court of said county.

The petition of JosephJoseph Jefferson JeffersonJoseph Jefferson
a mulatto man, aged about twenty seven years,
humbly represents to your honor, that he was born
in the state of VirginiaVirginia from a black mother, and free
white father, whose name is Thomas JeffersonThomas Jefferson , in a
state of Slavery, following the condition of his mother
the said JeffersonJefferson , that father of your petitioner being
the mster of your petitioner that when
your petitioner was only of the age of about four
years, as your petitioner is informed the said
Thomas JeffersonThomas Jefferson , the there owner of your petitioner
about that time sold your petitioner as a
slave to one James McKnightJames McKnight , an condition
that said McKnightMcKnight should not hold your petitioner
in slavery any longer, than to your petitioner
should arrive at the age of twenty one
years of age; but should then discharge your
petitioner from slavery, suffering your petitioner
to go at large in the full enjoyment of his actual
rights and privileges, as a free man man
And a petitioner representats, that the siad
James McKnightJames McKnight , brought your
petitioner along with him many years ago,
from the state of VirginiaVirginia to the then territory
now state of MissouriMissouri, when he the said McKinght
resided ever since, and held your petitioner
in his possession and custody, for sometime,
as his slave. That about fourteen years
ago the said James McKnightJames McKnight , as your petitioner
is informed, sold your petitioner as a slave
is McKnightMcKnight , the father of the
said JamesJames , but upon what precise conditions
or times, your petitioner is ignorant, but your
petitioner has be informed and believes, that
the conditions of said sale, by James McKnightJames McKnight
to TimothyTimothy McKnight , McKnightTimothy McKnight his father, with the same
under which said JamesJames purchased your petitioner
from the said Thomas JeffersonThomas Jefferson , above mentioned,
and that the said TimothyTimothy McKnight McKnightTimothy McKnight
the father of the JamesJames was informed and was
cognizant of the conditions under which said
JamesJames bought your petitioner as aforsaid, at the

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turn your petitioner was sold by said JamesJames to
TimothyTimothy McKnight McKnightTimothy McKnight , the father of said JamesJames .
And your petitioner further represents to your honor
that the said Timothy McKnightTimothy McKnight held your petitioner
in his custody and posession as his slave during
his life time, which was terminated not long since by
death that your petitioner, after the death of said
Timothy- McKnight, came into the posession &
custody of William McCutchenWilliam McCutchen , of the county of
St LouisSt Louis, & State of MissouriMissouri, who your petitioner
to the same in lieu of the said
Timothy McKnightTimothy McKnight deceased, and that said
McCutchen has held your petitioner ever since the
death of said Timothy-Mcknight deceased, in his
possession and custody as his slave, as your pe
titioner is informed and believes, under the pretence
that your petitioner was left to him as a legacy
by the last will and testament of the said
Timothy McKnightTimothy McKnight deceased; that your petitioner,
[ altho ] he has long since arrived at the
age of twenty one years, is still held & claimed
by the said McCutchen as his slave for life, deprived
of his natural freedom and personal litherly
contrary to the terms of the saidcontract between
the said James McKnightJames McKnight and the
said Thomas JeffersonThomas Jefferson , above mentioned, and
contrary to and in contempt of the laws of the
land, and contrary to equity and good can
secure, as your petitioner is advised & believes
In tender consideration whereof, your petitioner
prays that (in order that full and ample
justice may be done to him) he be
permitted to institute his action of apauld
& battery and false impresonment, agrument
the said william McCutchen, and the
said James McKnightJames McKnight , and all other person
who may set up a claim to your petitioner
as a slave, claiming under, by or
through the said JamesJames , to try the
right of your petitioner to his claim of
freedom and that your honor will make
all the necessary orders and deceases, which
may be deceased necessary & proper, in whalf
of your petitioner, & that he may be permitted
to sue as a poor person; & your petitioner

will ever pray de
next L. C. McGirk

JosephHis X MarkJeffersonJefferson

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No 23
St Louis Circuit CourtCircuit Court
November Term 1826

Joseph JeffersonJoseph Jefferson
vs William M Cutchen
James M Knight

Narr.

This is an actionof Trespass
assault battery & falseimprisonment
damages of 800
The Clerk will a summon,


atty for pltiff

Filed 19th October 1826

Arch GambleArchibald Gamble Clerk

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Executed this writ on M McCutchen by reading to
him the same March March the 2nd 1827 as
Service $ 1-00

Jas C. Musicek Sheriff
for R. SimpsonR Simpson Sheriff

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State of MissouriMissouri
County of St LouisCounty of St Louis

In the Circuit CourtCircuit Court November Term 1826

Joseph JeffersonJoseph Jefferson a free man of colour
who is permitted by the Court to sue as a poor person
by I his attorney assigned as counsel by this
court of William M Cutchen and famed
M Knight of a plea of trespass, For that the
said WilliamWilliam and famed heretofore court on the first day of July in the year of Lord one thousand eight hundred and twenty six, with force and arms at the
city of St LouisSt Louisunlawfully and assault did make upon
the body of said JosephJoseph and then and there did
and him said JosephJoseph and then and there
imprisoned him said JosephJoseph and kept and detained him in
prison without any reasonable or probable cause whatso-
ever against the will of said JosephJoseph and have eversince
kept and detained him said JosephJoseph in prison and still
keep and detain him said JosephJoseph in person without any
reasonable or probable causewhatsoever, Countrary to the
laws of this State, and the said WilliamWilliam and JamesJames other
wrongs then and there did him said JosephJoseph against
the peace and dignity of the State.

Wherefore the said JosephJoseph says he is injured and
hath sustained damaged from said WilliamWilliam and JamesJames
to the amount of eight hundred dollars and therefore he
sucs-

McGirk & Charles
Attys for plff

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Executed this writ on James McKnightJames McKnight by reading the
same to him this 24th Oct 1826 The writ was not
executed on Wm. McCutchen for of a belief that said Wm.
McCutchen was not a resident of St Louis County

R SimpsonR Simpson Shff
by James G Musick D Shffs

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County of St LouisCounty of St Louis
The State ofMissouri MissouriMissouri

To the Sheriff of said County Greeting

We Command you to summon William McCutchenWilliam McCutchen and JamesJames McKnight
McKnightJames McKnight that they be and appear before the Judge of ours
Circuit CourtCircuit Court at the next term Thereof to be held at the city
of St LouisSt Louis within and for the County of St LouisCounty of St Louis on the Fourth Monday in November next then and there to answer into JosephJoseph Jefferson
JeffersonJoseph Jefferson a free man of color who is permitted by the Court to sue as
a poor person of a plea of Trespass to the damage of said plaintiff
of Eight hundred dollars ~ and have you then there this writ

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WitnessArchibald GambleArchibald Gamble Clerk of our
said Court at Office this 16th day of October 1826

Archibald GambleArchibald Gamble Clerk

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County of St LouisCounty of St Louis
The State of

To the Sheriff of said County Greeting

We command you to summon William McCutchenWilliam McCutchen that he be and appear
before the Judge of our circuit Court at the next Term thereof to be held at the city
of St LouisSt Louis within and for the County of St LouisCounty of St Louis on the Fourth Monday in March
next then and there to answer unto Joseph JeffersonJoseph Jefferson a free man of Color
who is permitted by the Court to sue as a poor person of a plea of Trespass
to the Damage of the said plaintiff of Eight hundred and Dollars and have you
then there this writ

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WitnessArchibald GambleArchibald Gamble Clerk of our said Court
at office this Third day of February 1827

Archibald GambleArchibald Gamble Clerk

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James McKnightJames McKnight
with William McCutchenWilliam McCutchen
adsJoseph JeffersonJoseph Jefferson , a man
of Colour

Suit for freedom

And the said JamesJames Mr Knight who is in
pleaded in this suit with William McCutchenWilliam McCutchen
comes and defends the force and when
and say, that the said JosephJoseph ought not to have
and maintain his action aforesaid, because he
says that the said JosephJoseph was, at the time
of the commencement of this suit, and still
is a slave, without this that the said JosephJoseph
was at the time of the commencement of this
suit, a free person, as is said by
his declaration in this behalf is above
supposed, and of this he the said JamesJames
put himself upon the bounty

By his attorneyE.

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No. 23.
Nov Term 1826

Js.McKnightMcKnight :
with McCutchen
ads

Joseph JeffersonJoseph Jefferson the

filed Dec 1st 1826

A GambleArchibald Gamble Clk