The petition of GeorgeGeorge a man of colour
commonly called George RelfeGeorge Relfe humbly whereto
that your said petitioner was born a slave in
the state of VirginiaVirginia the property of an JamesJames Duff
DuffJames Duff and intermarriage of one
JamesJames H Relfe H. RelfeJames H Relfe with the daughter of said
Duff your petitioner was by his said master
given and delivered to his said son in law
JamesJames H Relfe H. RelfeJames H Relfe that said James H. RelfeJames H Relfe
after his marriage rended some time at
Wheely in VirginiaVirginia and removed thence
in the year 1815 and after remaining
about one month at St. Genevieve in MissouriMissouri, settled in the then territory now state of IllinoisIllinois and resided
there about two years. where he again
removed and settled in MissouriMissouri where
he has ever since resided your petitioner
further states that from the time of the marriage of said JamesJames H Relfe H. RelfeJames H Relfe your petitioner
continued in the possession of said JamesJames H Relfe
H. RelfeJames H Relfe and was held by him as a slave
and resided within in VirginiaVirginia at
and in IllinoisIllinois during the whole period aforesaid
your petitioner further represents that while
the said JamesJames H Relfe H. RelfeJames H Relfe held and kept your petitioner in IllinoisIllinois (your petitioner being then about seventeen years
of age) he said JamesJames H HJames H recognized your
petitioner to be free and prevailed in him
your petitioner to bind himself by a contract in writing to serve him said JamesJames H
HJames H until he your petitioner should arrive
at the age of twenty eight years ; and the

said JamesJames H HJames H . therefore prepared a writing
or caused it to be done which he represented
to be of the effect aforesaid and your petitioner
confiding in the truth of said representation and
being unable to read subscribed said paper
and your petitioner has since learned that
said writing if valid would bring him
to serve said Relfeninety nine years
but your petitioner is advised that said
writing is utterly void in law and the said
James H. RelfeJames H Relfe has frequently admitted that
he could not hold your petitioner is virtue
thereof and according by about a year or more
ago he said JamesJames H HJames H . informed your petitioner
on that he was free and suffered him to
go at large and act as a free man
which your petitioner did for several
months where the said JamesJames H HJames H ., contrivinghow to cheat your petitioner out
of the rights which he had acquired by occasion of the premises prevailed on the said JamesJames Duff
DuffJames Duff his father in law to reclaim your
petitioner and make sale of him and
the said James DuffJames Duff after having given
and delivered your petitioner to his
and son in law and suffered him to
remain in his uninterrupted possession
for a period of thirty years. executed
as your petitioner is informed and believes a
power of attorneyto D. Linn of St. Genevieve authorizing him to sell your petitioner which
he accordingly did to oneAugustus Jones
who sold him to one Thompson H. FicklinThompson H Ficklin

which sales your petitioner is informed and
believes was made for the benefit of said
JamesJames H Relfe H. RelfeJames H Relfe who received the proceeds
In virtue of which contrivances
the said Thompson H. FicklinThompson H Ficklin now claims your
petitioner as a slave and detains him
as such

Your petitioner upon the facts aforesaid
claims his freedom and prays that he may
be permitted to sue as a free person to establish his freedom and that he may
have the protection of your honorable court
until the cause shall be finally determined
according to the form of the statute in
such cases made And your
petitioner will ever pray

It is ordered that the within petitioner be permitted
to sue as a poor person to establish his
right to freedom and HenryHenry I GeyerGeyer is
hereby assigned to act as counsel for the petitioner

And it is further ordered that the petitioner
have reasonable liberty to attend his counsel
and the court where occasion may require ; and that the petitioner shall not be taken or removed
out of the jurisdiction of the court nor be subject
to any severity because of his application for
freedom.

St. LouisSt LouisJuly 7th 1828. Served the above order on ThompsonThompson H Ficklin
H. FicklinThompson H Ficklin in the city of St. LouisSt Louis by giving him a certified
Copy thereof

GeorgeGeorge a man of color other wise called George RelfeGeorge Relfe by GeyerGeyer his attorney complains of Thompson H. FicklinThompson H Ficklin
of a plea of Trespass, assault & battery
& false imprisonment For that the said
defendant on the fourth day of July in the
year of our Lord eighteen hundred and twenty
eight with force and arms, made an assault
upon the said plaintiff to wit at the county of
St LouisSt Louis aforesaid and then and there beat, bruised and ill-treated him the said plaintiff
and then & there imprisoned the said
plaintiff, and kept and detained him in prison there without any reasonable or probable cause
whatsoever and against the will of the said
plaintiff and then there held and detained
him the said plaintiff and still holds &
detains him in slavery, and the said plaintif
avers that before & at the time of the committing the
said severy grievances he was and still
is a free person - Wherefore the said
plaintiff saith he is injured & hath sustained
damage to the value of five hundred dollars
& therefore he brings suit.

We command you to Summon Thompson HThompson H Ficklin . FicklinThompson H Ficklin 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. LouisSt Louis on the Fourth monday
of July Instant then and there to answer unto George RelfeGeorge Relfe of a plea of Trespass, assault and battery and false imprisonment wherefore the said plaintiff
saith he is injured and hath sustained damage to the value of four hundred
dollars and have you then there this writ

Judgement in favor of plff Book 5 page 264

Petition & order of Judge
Declaration one count assault
& false imprisonment
to recover freedom 500
Issue a summons with
a copy of the Judges
in - GeyerGeyer

the Copy of St. LouisSt Louis, by writ Declaration & petition to him
to read and his acknowledging the service thereof

And the said Defendant by his
attorney comes and defends and the force and injury
when he and says that he is not guilty of the
supposed trespass in the declaration mentioned
in manner and form as the said plantiff has
above thereof complained against him and of this
he puts himself upon the county

plea

Thompson HThompson H Ficklin FicklinThompson H Ficklin the above named
defendant will take notice that I shall attend
at the office of the Clerk of the Circuit CourtCircuit Court
within & for the county of RandolphRandolph in the
state of IllinoisIllinois on the second and third, ninth
and tenth days of March next and then
and there between the hours of eight of
the O'clock of the fore noon and six of the
clock of the afternoon on each of said days
taken the depositions of witnesses to be read
at the trial of the above cause on the part
of the plaintiff

PhilipPhilip Cob being
duly sworn according to law deposith and saith
that on the eighteenth day of Febuaryinstant
he servedThompson HThompson H Ficklin FicklinThompson H Ficklin the within renamed
defendant with the by serving him a copy thereof and with this
deponent with

Deposition of witnesses produced sworn and
examined on the twenty sixth day of February in the year of our Lord one thousand eight hundred and twenty nine, between the hours
of eight of the clock of the forenoon and
six of the clock of the afternoon of that
day at the dwelling house of WilliamWilliam
Cole in the town of in the
county of WashingtonWashington state of MissouriMissouri
before me a justice of the
peace within and for the county of
WashingtonWashington aforesaid in a certain case
now pending in the Circuit Court of
the county of Saint LouisSt Louis, in the state
of MissouriMissouri, between GeorgeGeorge Relfe RelfeGeorge Relfe
plaintiff, and ThompsonThompson H Ficklin HThompson H Ficklin .FicklinThompson H Ficklin
defendant, on the part of the plaintiff.

James HJames H Relfe RelfeJames H Relfe of lawful age being produced
sworn and examined on the part of the
plaintiff, deposith and saith that he has
known since the month of september 1815 a certain
negro man named GeorgeGeorge , and believes him to
have been born a slave, the property of JamesJames Duff
DuffJames Duff of Rockingham county VirginiaVirginia at which
time to wit in the month of september 1815 he came
into the possession of the said deponent. This deponent, has always considered and the said GeorgeGeorge .

the property of Mr.Duff, but expected at his
andeath, the said GeorgeGeorge would be given to this
deponent or his family. This deponent brought
said GeorgeGeorge to the county of RandolphRandolph
State of IllinoisIllinois in the month of January in the year 1817 without the knowledge
of Mr.Duff (When this deponent left VirginiaVirginia
he expected to reside somewhere in the state
of MissouriMissouri) soon after this deponent took
up his residence in the State of IllinoisIllinois Mr.Duff became acquainted with the fact
but this deponent has no recollection of
giving him information thereof or that
be had taken GeorgeGeorge there. This deponent
removed from the state of IllinoisIllinois to the
state of MissouriMissouri in the month of November 1818 and at the particular request of
the said plaintiffGeorgeGeorge he brought him
with him. This deponent wished the said GeorgeGeorge to remain on this deponent's farm in IllinoisIllinois. This said GeorgeGeorge continued to reside with this deponent in MissouriMissouriuntil the spring of the year 1827, when
after he had made a second attempt to commit
murder on the family of this deponent,
this deponent drove the said GeorgeGeorge from his
house, and informed Mr.Duff of the

Circumstance, telling said Duff who is the
father in law of this deponent, that said GeorgeGeorge
was then running at and declined
having anything further to do with him. Soon after the receipt of this Letter by Mr. Duff, Mr. Duff forwarded to Dr. Lewis F. Linn of
StSt Genevieve. GenevieveSt Genevieve a power of attorney to take up
GeorgeGeorge and sell him as his property, and
to pay the proceeds of such to this
deponent Dr. Lewis F Linn therefore sold
said GeorgeGeorge to Augustus Jones of WashingtonWashington County
CountyWashington County, and A. Jones this deponent
believes and has been informed sold the said
GeorgeGeorge toThompsonThompson H Ficklin HThompson H Ficklin FicklinThompson H Ficklin the deponent
in the above action. In1817 this deponent
took an indenture for fifty years on GeorgeGeorge
according to the Laws, of the state of IllinoisIllinois
but this deponent never asked the permission his father in law Mr. Duff
nor does he
believe that Mr. Duff has any knowledge
of said indenture at this time

by plaintiff Witness you have stated that
GeorgeGeorge attempted to commit a murder in your
family, please state the circumstances of that affair?

Case. This deponent believes it was an the

Month of March in the year 1824he directed GeorgeGeorge the now plaintiff to go with the train to plow a garden for a neighbor; some time
in the course of the day GeorgeGeorge advanced into the
room where the deponent and some company
were sitting with an axe elevated in a striking
position swearing he would kill the rascal. This
deponent sprung towards him and with difficulty
avoided the blow. GeorgeGeorge then ran and was
followed by the deponent to the woods, where
he lost sight of him. GeorgeGeorge returned to the
house and endeavored to procure a furr, but
was prevented by a man of the neighbourhood
who happened to be in the house. The second attempt was made in the spring of
the year1827, when early one morning GeorgeGeorge came into the room took down
the furr. This deponent was shortly afterward
jarred by the cry of a negro woman
that GeorgeGeorge was going to kill Ned a negro man. This deponent followed GeorgeGeorge
who was in pursuit of Ned in the
bush threatening to shoot him and when this
deponent askedGeorgeGeorge to give up the furr
GeorgeGeorge pointed it at deponent and threatened
to shoot until this deponent stepped back

This deponent was under constant anxiety for
his family when absent from home on account
of GeorgeGeorge , and nothing insured him to keep
him as Comp in his family, but for the circumstance, that GeorgeGeorge was the son of an old
negro woman who had been the nanny
of Mr. Relfe; and to whom this deponent
had given a promise to keep GeorgeGeorge in the
family.

by plff. How much money did
. A Jones give Dr. Lewis F. Linn for
GeorgeGeorge ?

two hundred and fifty dollars

by plff. Has Dr. Linn accounted with
you witness for the proceeds of GeorgeGeorge as sold to JonesJones ?

He has

by plff. at what time did it become known to your father in law Mr. Duff, that you
reside in IllinoisIllinois?

Soon after this deponent arrived there

by Defendant - Do you know the time the
defendant ThompsonThompson H Ficklin HThompson H Ficklin FicklinThompson H Ficklin purchased said GeorgeGeorge
from JonesJones do you know of GeorgeGeorge informing said Ficklin
or telling him that he had no idea of of his being entitled to his freedom, & would serve Ficklin Defendant
as a slave if he the said deft would buy him GeorgeGeorge and
what you heard GeorgeGeorge say about that time as his promise to deft-before or afterwards purchase GeorgeGeorge ?

Deponent believes it was in the latter part of May
or first of June last he was informed by GeorgeGeorge that Thompson H. FicklinThompson H Ficklin had purchased him from JonesJones , and that he was
to to be sold to ScottScott and Rub of St. LouisSt Louis, who was to put him aboard one of their steam boats, and if he conducted himself well for two years, he would then be emancipated,
previous to that time GeorgeGeorge informed the deponent that he
had abandoned the idea of getting his freedom.

Mildred Relfe of Lawful age being properly sworn and examined on the part of the plantiff
deposith and saith in answer to the following
interrogation that is to say

by plaintiff Witness do you know GeorgeGeorge the plantiff in the above action?

I do

by How long have you known
him ? Since his birth twenty
nine years

plantiff WasGeorgeGeorge born a slave if so
whose property was he ? He was born
a slave and was the property of Mr Duff
the father of this deponent

Have you ever owned or possessed
Him ? If so how did you obtain possession, from whom, for what purpose and on what
terms ?

my father Mr Duff observed to this deponant
that he would make her a present of GeorgeGeorge
if she would take him home this was in September in the year 1815Therefore GeorgeGeorge came to the
possession of this deponent and her husband JamesJames H Relfe

H. RelfeJames H Relfe and continued in possession from that
time until the year 1827

Did you reside in the state of IllinoisIllinois,if so in what county and how long ?
Given Yes lived in Randolph County IllinoisIllinois
come there 3rd May 1817 and left there in the
month of November 1818

Did GeorgeGeorge the plantiff live
with you in IllinoisIllinois and how long?

He did the whole of the time this
deponent resided there.

Was it knownto your father
Mr Duff that you resided in IllinoisIllinois, at the time
GeorgeGeorge was with you there, if at what time
did it became known to Mr. Duff your father
that you resided in IllinoisIllinois?

Mr Duff knew of our residing in IllinoisIllinois
shortly after this deponnent and family came there
but the precise time when Mr. Duff became thus
informed this deponent cannot state.

Where was GeorgeGeorge born ? In the state of VirginiaVirginia county of

plaintiff, Where has GeorgeGeorge the above
Plaintiff resided in your possession? First in VirginiaVirginia, secondly in MissouriMissouri, thirdly
in IllinoisIllinois and fourthlyin MissouriMissouri

by plaintiff What knowledge has Mr.Duff
had of the place of residence of GeorgeGeorge
the plaintiff.

from the family corrospondence Mr. Duff must have known of the several removals
of this deponent, and also of GeorgesGeorges severals places of residence.

by plaintiff Have any arrangements been made
for the sale of GeorgeGeorge , if so to whom has he been sold, and how are the proceeds to be apportioned
and for whose use?

This deponent has understood that GeorgeGeorge was sold to A. Jones by Lewis F. Linn by power of attorney from Mr. Duff and that JonesJones sold GeorgeGeorge to ThompsonThompson H Ficklin HThompson H Ficklin .FicklinThompson H Ficklin and that the proceeds of the sale of GeorgeGeorge as sold by Dr.
Linn, were for the use of James H.Relfe
the husband of this deponent.

I Airs Hudspeth A Justice of the Peace within and for the county
of WashingtonWashington in the State of MissouriMissouri do here by certify that
JamesJames H Relfe HJames H Relfe . Relfe Mildred RelfeJames H Relfe the Deponents were before me
Severally sworm to testify the whole truth of their knowledge
Touching the matter in controversy aforesaid that they were
Examined and their examination reduced to writing and by
hand Respectively, subscribed in my on the day
between the hours and at the place in that behalf first
aforesaid

Justice fees
issueing subpoena	18 3/4
2 certificates on notices	50
5 certificates on Depositing	25
P T.McCabe	2.93 3/4
summoning withness	50
	$ 3.43 3/4

Thompson HThompson H Ficklin FicklinThompson H Ficklin the above named defendant
will take notice that I shall attend at the
dwelling house of WilliamWilliam Cole in the
Town of Caledonia in the county of
WashingtonWashington, state of missouri on the twenty sixth
and twenty seventh days of febuary
instant and then and there between the
hours of eight of the clock of the fore noon
and six of the clock of the afternoon of
each of said days taken the deposition
of Witnesses to be read at the trial of the
above cause on the part of the plaintiff

PhilipPhilip Cob being sworn
according to him deposith and saith that
on the eighteenth day of February instant
be served the accused a writ on Thompson H. FicklinThompson H Ficklin the defendent by delivering him a copy thereof
and further the said P. Cob saith not

subscribed & Sworn to before me A Justice of the
peace within and for the county aforesaid this 26th day of febuary A.D 1829

notice

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