Julia v. Samuel M. Kinney
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St LouisSt Louis cir cuit
1831

St Louis County to a woman of
color who by of the event
inflows of
SamuelSamuel of a plea of trespases
In that the said SamuelSamuel
on first day of march in the year1831
fore and
on the said Inla at St LouisSt Louis aforesaid
and then and there
of the said Inla and with
and
and then and there the said Inla
a quiet many blows and
and then and there and the said
JuliaJulia and left and detained for a
then without any and for a long space of time
to day, when
the said and all that this above when the aforesaid

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grievances were ant at
and to and the the first
day of march in the year1851 the said
JuliaJulia was and still is a free person and that even
the said SamuelSamuel there and then hold
and detained her, and still holds
and detains her inslaveryslavery
contrary to and against the will and
consent of the said JuliaJulia sad
JuliaJulia then and there was not only
injured by and blows and and than greatly injured
ant by above aid than and of and to the day
of the said JuliaJulia $500 and

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To the honorable WilliamWilliam C. CarrCarr judge of
the circuit court of St LouisSt Louiscounty

your petitioner JuliaJulia a woman of
color represents to ; that
she was born in the state of the slave
of about twenty five years
Said the sael
to and that
after the death of the said Asa
his son emigrated
to fiche county and state of IllinoisIllinois and and
ant that the said widow of and his son
your petitioner with
to Fiche County in the state of
IllinoisIllinois where and at which place she
thaneight weeks and then days; that she
was then taken to Lousiana fiche County
in the state of MissouriMissouri when she
seven months; that there said
the that for Lousiana

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and to the of
and of of what she a and there day
the said to
Lous and of she is now

is and that the above and
to on she is is
why of your
may to to
and that the any
a and and to
your to


to for
march 10th 1831

X

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State ofMissouri MissouriMissouri
Third Judicial Circuit CourtCircuit Court

It is hereby ordered that on the foregoing peti-
tion, the subscriber hereto, JuliaJulia , be permitted
to sue as a poor person to establish her right to
freedom and GeorgeGeorge F FGeorge F .Sholker esquire is
assigned as her counsel. It is also ordered
that the said JuliaJulia have reasonable liberty
of attending her said counsel and the court
whenever occasion may require and that
the said petitioner shall not be taken or
removed out of the jurisdiction of the court nor
be subjected to any severity because of her
application for freedom. Given under
my hand at my chambers this 11th day of March 1831.

WillWill . C. CarrCarr

judge [ 3 ] circuit
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No. 66___

JuliaJulia a woman
of color
vs
SamuelSamuel

to

filed March 10th 1831

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St louisSt Louiscircuit court march
term 1831-
St louisSt Louis county to wit

Barly and SamuelSamuel P. Barly
complain of

State ofMissouri MissouriMissouri- Third Judicial Circuit CourtCircuit Court . It is hereby ordered that on the foregoing petition
the subscriber thereto,JuliaJulia , be permitted to sue as a poor person to establish her right to freedom
and George FGeorge F Strosher esquire is assigned as her counsel. It is also ordered that the said JuliaJulia
have reasonable liberty of attending her said counsel and the court whenever occasion may
require and that the said petitioner shall not be taken or removed out of the Jurisdiction
the Court nor be subjected to any severity because of her application for freedom - Given
under my hand at my chambers this 11th day of March 1831-

WillWill C CarrCarr


Judge 3rd Circuit
A true copy of the order of the judge permitting the plaintiff to sue

ArchibaldArchibald Gamble GambleArchibald Gamble Clerk

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No 66

St Louis Circuit CourtCircuit Court
March Term 1831

JuliaJulia a woman
of color
vs
SamuelSamuel

This is an action
of assault &
and false imprison
ment -

Filed 11th march 1831

Archibald GambleArchibald Gamble Clerk

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Executed this writ on SamuelSamuel Mckinney by offering
to read it and the declaration to him which
he refused to hear read and acknowledged the
Circuit of the law in The city of St LouisSt Louis on the
11th day of March 1831

K WalkerK Walker Sheriff

Server $ 1,00
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County of Siant Louis

ss

The State of MissouriMissouri


To the Sheriff of the county of Saint LouisSt Louis Greeting

We command you to summon SamuelSamuel Mckinney that he be
and appear before the Judge of our Circuit CourtCircuit Court at the next term
thereof to be held at the city of St LouisSt Louis within and for the county
of Saint LouisSt Louis on the fourth monday of March instant then and
there to answer unto JuliaJulia a woman of color who by the permission
of the court sues in forma pauperis of a plea of trespass to the damage
of the said julia $500 and have you then there this writ

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Witness Archibald GambleArchibald Gamble clerk of our said circuit
court at office this Eleventh day of March One thousand Eight Hundred and thirty one

Archibald GambleArchibald Gamble Clerk

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Court for St Louis County

coloured PersonPerson

And the said SamuelSamuel
KinneyKinney by his Attorney Geo.D. Shaw
defends the force and injury been
that he is not guilty
to his charge or any thereof in
and form as the said plaintiff hath
of complained against him and of this
defendant puts himself upon the county

Geo. D. Shaw

april 1831

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filed april 10th 1831

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counsel to filed in this case - Book 6 -- page 105
to 273
dgment for defendant 448
/>

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COUNTY OF ST. LOUISLouis , SCT.


State of MissouriMissouri,

TO ANY JUDGE OR JUSTICE OF THE PEACE OF IllinoisIllinois
-- GREETING.

We, reposing special trust and confidence in your integrity and circumspection, do require and command you, that you
cause to come before you such person, or persons, as shall be named to you by JuliaJulia (a woman of color) SamuelSamuel MKinney
their attorney or agent, and him, her or them examine upon his, her or their corporal oath, (to be by you administerred,) touch-
ing their knowledge of any thing that may relate to a certain matter of controversy, now pending in our Circuit CourtCircuit Court ,
for the county of St. LouisSt Louis, wherein JuliaJulia (a woman of color) is plaintiff and SamuelSamuel MKinney
is defendant, on the part of the said plaintiff, and having reduced the said
depositions taken by you as aforesaid, into writing, you are required to send the same, together with this commission.
enclosed under your seal, to our said Circuit CourtCircuit Court , with all convenient speed.

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WITNESS, Archibald GambleArchibald Gamble , Clerk of our said Circuit CourtCircuit Court , at
the City of St. LouisCity of St Louis, this Third day of June In the year of our Lord one thousand eight hundred and twentythirty one

ArchibaldArchibald Gamble GambleArchibald Gamble

Clerk, C.C.
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JuliaJulia (a woman of color)
vs
SamuelSamuel MM Kinney KinneyM Kinney

In Vacation 3rd June 1831
Clerks office of the St LouisCircuit Court Circuit CourtCircuit Court

On the applciation of the attorney for the plaintiff it is ruled that
a Dedimus to any Judge or Justice of the peace of the state of
IllinoisIllinois to take the depositions of of witnesses to be read in evidence on
the trial of this cause on the part of the plaintiff

a True Copy of the Rule

ArchibaldArchibald Gamble GambleArchibald Gamble Clerk

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JuliaJulia
vs
SamuelSamuel MKinney

LeonardLeonard Rofo

Rofo

HenryHenry J Rofo

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JuliaJulia a woman of color
vs
SamuelSamuel M KinneyM Kinney

In the St louis Circuit Court

To JuliaJulia the above named plaintiff

Take notice that I Shall attend at the Post Office
in the Town of taples int he state of IllinoisIllinois on the
thirteenth day of July instant between the hours
of six O clock in the forenoon and six O clock in the afternoon of that day then and there to take the
depositions to be read in evidence on
the trial of the above cause when and where
you can attend

july 4 1831

SamuelSamuel M KinneyM Kinney

by

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I acknowledge the service of the within notice on me as attorney
for JuliaJulia the plaintiff as a service on the plaintiff

july 4, 1831

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JuliaJulia
vs
Sam M kinmey

Notice

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COUNTY OF ST.LOUISLouis , SCT.

State of MissouriMissouri,

To any Judge or Justice of the Peace of the State of IllinoisIllinois ---GREETING.

WE, reposing special trust and confidence in your integrity and circumspection, do require and com-
mand you that you cause to come before you such person or persons as shall be named to you by SamuelSamuel
MKinney- or JuliaJulia (a woman of Color) - their ___________ attorney
or agent, and him or them examine upon his, her or their corporeal oath (to be by you administered)
touching their knowledge of any thing that may relate to a certain matter of controversy, now pending in
our Circuit CourtCircuit Court , for the county of St. LouisSt Louis, wherein JuliaJulia (a woman of color)
is plaintiff and SamuelSamuel MKinney ------------ is defendant on the part of the said
defendant - and having reduced the said depositions so taken by you as aforesaid into writing,
you are required to send the same, together with this commission, enclosed under you seal, to our said Cir-
cuit Court, with all convenient speed.

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WITNESS, ARCHIBALD GAMBLE, Clerk of our said Circuit CourtCircuit Court ,
at the City of St. LouisCity of St Louis, this fourth day of July in the year of our Lord, one thousand eight hundred and thirty- one

Archibald GambleArchibald Gamble

Clerk, C.C.
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JuliaJulia (a woman of color)
vs
SamuelSamuel MKinney

In Vacation July 4th 1831
Clerks office of the St Louis Circuit CourtCircuit Court

On the application of the attorney for the defendant it is Ruled
that a Dedimus to any Judge or Justice of the peace of the StateIllinois
of IllinoisIllinois to take the depositions of witnesses to be read in evidence on
the trial of the above cause on the part of the defendant

a True copy of the Rule

Archibald GambleArchibald Gamble Clerk

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I WilliamWilliam R Smith a justice of the peace within and
for the County ofCounty of Morgan MorganCounty of Morgan and State of IllinoisIllinoisdo
Certify, that in pursuance of the within commission and notice
personally come before me at the Post office in in
the County and State last aforesaid JosephJoseph .
and Benjamin,L,Mathews who were there by me sworn and
examined, and such examination reduced to and
subscribed by them respectively in my presence, and their said
depositions are now herewith returned :-

Given under my hand and seal
at Taples in the CountyCounty of Morgan ofCounty of Morgan MorganCounty of Morgan and
State of IllinoisIllinois this 13th day of July AD 1831

WIll.R.Smith. Justice Peace

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Depositions of Witnesses produced and examined at
the post office in the Town of Staples in the county of morgan
and State of IllinoisIllinois before me a justice of the peace of
the county aforesaid in a certain cause now in the
Circuit Court of the county of Saint louis State ofMissouri MissouriMissouri
between JuliaJulia a woman of color plaintiff and SamuelSamuel MM Kinney
KinneyM Kinney defendant - on the part of the defendant
JosephJoseph J Bennett J BennettJoseph J Bennett of lawful age being produced sworn
and examined on the past of the defendant and sayeth
that this on their arrival
in pike county IllinoisIllinois slept at his cabin and remained
there a few weeks without having or renting the cabin for
any particular or specified time merely holding it as a
temporary shelter by his permission. And that he heard
his CarringtonCarrington as willJosephJoseph Carrington CarringtonJoseph Carrington frequently say that
they would not or had no intention of making a
slave of JuliaJulia the plaintiff in this cause in the state of
IllinoisIllinois and this say he not -

Joseph J BennettJoseph J Bennett

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I WilliamWilliam R Smith a justice of the peace as aforesaid do certify
that Joseph JJoseph J Bennett . BennettJoseph J Bennett the deponent was by me sworn to testify the
whole truth of his [ knolledge ] touching the matter in controversy in the
cause aforesaid. That the deponent was examined and his examination
reduced to and subscribed by said deponent in my
On the thirteenth day of July in the year of our Lord One thousand eight hundred and thirty onebetween the hours of six in the
morning and six in the after noon at the post office at
taples in the county and state aforesaid

Given under my hand and seal
the 13th day of July AD. 1831

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Benjamin L Mathews of lawful age being produced sworn and
examined on the part of the defendant aforesaid and sayth
that JuliaJulia the plaintiff in the above cause was taken to
MissouriMissouri and hired out to service in MissouriMissouri - that she
became sick in MissouriMissouri and remained sick for some time
-that she was taken back to New CarringtonCarrington in PikePike county
in IllinoisIllinois to be nursed and restored to health that
while at New CarringtonCarrington she was not employed in any
kind of work but was nursed and restored to health-
and that as soon as she was able to work she was taken to
Saint LouisSt Louis and sold - tha he was the individual
who took the plaintiff from MissouriMissouri to New CarringtonCarrington
when sick and that he heard New CarringtonCarrington say before
the plaintiff was [ brot ] back to her house that as soon as
JuliaJulia the plaintiff was recovered she would send her
back to MissouriMissouri and sold or hired out to some person
other than the one who had hired at that time and
as her reasons for doing so she said that Mr StuartStuart her
employer was not such a man as she wanted JuliaJulia to be
with - And that he has frequently heard both Carring
- ton and Joseph CarringtonJoseph Carrington say that they had no inten
-tion of making a slave of JuliaJulia in the state of IllinoisIllinois

Benjamin J Mathews

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I Will R Smith a Justice of the the peace within and for the county of
MorganMorgan State ofIllinois IllinoisIllinois as here by certify that Benjamin L Mathews
the deponent was by me sworn to testify the whole truth of his[ knolledge ]
the controversy in the cause aforesaid. That deponent was examined
and his examination reduced to meeting and subscribed by the said deponent
in my presence on the thirteenth day of July in the year eighteen hundred and thirty one. between the hours of six in the morning and six in
the afternoon at the postoffice in Taples in the county and state aforesaid
Given under my hand and seal the 13th day of July AD. 1831

WilliamWilliam R Smith

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Leonard of age deposeth &
that some time in the fall of
1830 that Josep G Carrington did put up
at my house, & had with him one
woman going to, MissouriMissouri for the purpose
as he said of hiring , & something about eight
or nine months after I seen him the
said CarringtonCarrington return or some other person with said
female who reported sick &

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WilliamWilliam Scholles of lawful age being sworn
deposeth & saith that sometime in the
year of 1830I saw Joseph G Carrington
this place with a woman of colour said
Carrington, said that he was going to
for the purpose of selling said woman
& that the said CarringtonCarrington asked
his opinion with regard to the right he
the had for doing, said
not know said CarringtonCarrington
woman of colour had at that time Resided
this state further saith some
time before the above he saw the
CarringtonCarrington this place with the
female going to for the purpose
of hiring the woman
of colour

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State ofIllinois IllinoisIllinois
Pike CountyPike County

The people of the state of IllinoisIllinois

& AndrewAndrew Philips ; Whereas I the undersigned,
a Justice of the peace, in, and for the county PikePike &
state of IllinoisIllinois, have received a
out of, and under the seal of the circuit court
in & for the county of St LouisSt Louis, StateMissouri ofMissouri MissouriMissouri
and to me directed for the examination of
, in a certain cause non pending and
mined in the said circuit court, between JuliaJulia
(a woman of colour) Plaintiff & SamuelSamuel J Mkinney
defendant and whereas, I am informed that your one
material witness for the Plaintiff, in the said
suit
suit; I therefore, by virtue of the said
require you and each of you
personally to be and appear before me at the court
house in the town of in the said county

of PikePike ,, on monday the 23rd day of July at
the hour of ten O Clock in the forenoon of said
day, then & there to be examined and to testify
the truth in relation to the said matter in
controversy; according to the best of your know
ledge, on the part and behalf of said plaintiff
Thereof fail not, under the penalty of the
what the law directs, Given under my
hand & sealthis at this18th day July AD 1831

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JuliaJulia a woman of colour
vs
SamuelSamuel Mkinney

Subpoena

Leonand Rop

HenryHenry Rop

Philips

Hillium Rop ( to )

(Deceased)

the within

[ subpeonu ]
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Servis 371/2
Sruart 1.25

Seth. B.

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State ofIllinois IllinoisIllinois
Pike County

ss

HenryHenry of of lawfull age being duly sworn
Deposeth and saith that some time in the
autumn or [ fore fourt ] of winter of 1829 in a conversation
which he had with Joseph G Carrington the said
CarringtonCarrington told him he had a Black girl he wanted
to hire out if he could safely do it in and
wished him to hire her he told him he would examine
the law and hire her if the law would
justify him afterwards.I became satisfied he
could not safely do it

HenryHenry Rop

Sworn and Subscribed before one
This 26th day of July A 1831

Justice of the Peace
PikePike county State ofIllinois IllinoisIllinois
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I do hereby certify, that the above depositions of LeonardLeonard
Rops.WilliamWilliam Rop and HenryHenry . Rops, were sworn to and signed by
the deponents, before me, and in my presence; and that the said Depositions
were completed by one on the twenty sixth day of July A 1831. at the office
of the clerk of the Circuit CourtCircuit Court in PikePike county and State ofIllinois IllinoisIllinois
between the hours of nine o clock in the forenoon, and five o clock in the
evening of said day. Given under my hand and seal this twenty
sixth day of July AD 1831

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Depositions of

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State of IllinoisIllinois
PikePike County CountyPike County

ss

I, WilliamWilliam Scholles clerk of the County
[ Commisioners ] Court, for said County
do hereby certify, that JamesJames whose name
appears the within certificate was on the day the
day the same was made, an acting Justice of the
Peace, in and for said County, regularly commission
and qualified, and that as such, full faith and
and of right ought to be given
to all his official acts

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In testimony have subscribed
my name and the seal of the
County [ Commisioners ] court of said county at
this day of July 1831

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COUNTY OF ST. LOUISLouis , Sct.

State of MissouriMissouri,

To the Sheriff of Saint LouisSt Louis County---Greeting.

You are hereby commanded to summon
that setting aside all manner of excuse and delay, he be and appear in proper person before the Judge
of our Circuit CourtCircuit Court , on the tenth day of August instant at the City of St. LouisCity of St Louis, then
and there to testify and the truth to say in a certain matter of controversy now pending in our said Court,
wherein JuliaJulia (a woman of color) is plaintiff, and
SamuelSamuel MKinney___ is defendant, on the part of the
plaintiff ; and have you then there this writ.

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Witness, Archibald GambleArchibald Gamble , Clerk of our said Circuit CourtCircuit Court ,
at the City of St. LouisCity of St Louis, this tenth day of August in the year of our Lord, one thousand eight hundred and thirty-one

Archibald GambleArchibald Gamble

Clerk, C.C.
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July term 1831
JuliaJulia
vs
SamuelSamuel Mkinney

for

plaintiff

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[missing figure]

not found

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COUNTY OF ST. LOUISLouis , SCT.

State of MissouriMissouri,

To the Sheriff of St Louis County--Greeting.

You are hereby commanded to summon John John Beat & JacobJacob
that setting aside all manner of excuse and delay, they be and appear in proper person before the Judge
of our Circuit CourtCircuit Court ,on theforthwithday of at the City of St. LouisCity of St Louis, then
and there to testify and the truth to say in a certain matter of controversy now pending in our said Court,
wherein JuliaJulia is plaintiff, and
SamuelSamuel Mckinney is defendant, on the part of the ; and have you then there this writ.

[missing figure]
WITNESS, ARCHIBALD GAMBLE, Clerk of our said Circuit CourtCircuit Court ,
at the City of St. LouisCity of St Louis, this 19th day of August in the year of our Lord one thousand eight hundred and thirty- One

A GambleArchibald Gamble

Clerk, C.C.
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[missing figure]

Served this writ on
per the 19th Aust 1831 Cooper not found


sheriff

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term 50
nouret 12
$ 621/2
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[missing figure]
July 1831
JuliaJulia
vs
SamuelSamuel M KinneyM Kinney

for


of

JacobJacob

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[missing figure]

In the circuit court of St louisSt Louis county

JuliaJulia a woman of colour
vs
SamuelSamuel M KinneyM Kinney

Bill of cash

1 subpence $//., 18 3/4
3 Oaths $//., 18 3/4
talking & Depositions [ contuing ] 5
jolis of yes wards cash @ 92 1/2
,,621/2
constable.s pe on remainy subsera - /,, 621/2
attenance of 3 ssitropes @ ,, 50th wash.. /,, 50
$ 4,, 12 1/2
alenths certificated seal ,, 50
that 4,,b21/2

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JuliaJulia
vs
SamuelSamuel Mkinney

Depositions

files opened
19th august 1831

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COUNTY OF ST. LOUISLouis , SCT.

State of MissouriMissouri,

To the Sheriff of St Louis County---Greeting.

You are hereby commanded to summon JamesJames G A G AJames G A MKinney
that setting aside all manner of excuse and delay, he be and appear in proper person before the Judge
of our Circuit CourtCircuit Court , on theforthwithday of at the City of St. LouisCity of St Louis, then
and there to testify and the truth to say in a certain matter of controversy now pending in our said Court,
wherein JuliaJulia plaintiff, and
JamesJames MKinney defendant, on the part of the
; and have you then there this writ.

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WITNESS, ARCHIBALD GAMBLE, Clerk of our said Circuit CourtCircuit Court ,
at the City of St. LouisCity of St Louis, this 19th day of Augst in the year of our Lord one thousand eight hundred and thirty- one

A GambleArchibald Gamble

Clerk, C.C.
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[missing figure]

Served this writ on Sam.
KinneyKinney on the 19th Augst 1831. in the city of St LouisSt Louis

50

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[missing figure]
July 1831
JuliaJulia
vs
Mkinney

for

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[missing figure]

St Louis Circuit CourtCircuit Court
JuliaJulia a Woman of Colour
SamuelSamuel M KinneyM Kinney

Action for freedom


Attorney for Plaintiff in the above entitledcause
case take there on the Third day of Octobernext between the hours of One and six of
the clocks of the after noon of said day at the store
of PhineasBlock in the town of Louisana in
the County ofCounty of Pike PikeCounty of Pike and State of MissouriMissouri the
deposition of witnesses will be taken to be read in evidence
in the trial of the above entitled case on the
defendants, where and when you may attend if you please

September 1831

on
defendant
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On this fifth day of September in the
year 1831, attorney
for the within named Plaintiff hereby
acknowledge service of a written notice
of which the is a copy

I acknowledge a copy of the
written notice was left with me

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St Louis Circuit CourtCircuit Court

JuliaJulia
vs
SamuelSamuel M KinneyM Kinney

notice to take
[ deposites ]

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COUNTY OF ST. LOUISLouis , SCT.

State of MissouriMissouri,

To any Judge or Justice of the Peace of the State of IllinoisIllinois ---Greeting.

WE, reposing special trust and confidence in your integrity and circumspection, do require and com-
mand you that you cause to come before you such person or persons as shall be named to you by JuliaJulia
(a woman of color) or SamuelSamuel MKinney - their attorney
or agent, and him or them examine upon his, her or their corporeal oath (to be by you administered)
touching their knowledge of any thing that may relate to a certain matter of controversy, now pending in
our Circuit CourtCircuit Court , for the county of St. LouisSt Louis, wherein JuliaJulia
is plaintiff and SamuelSamuel MKinney- is is defendant on the part of the said
plaintiff and having reduced the said depositions so taken by you as aforesaid into writing,
you are required to send the same, together with this commission, enclosed under your seal, to our said Cir-
cuit Court, with all convenient speed.

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WITNESS, ARCHIBALD GAMBLE, Clerk of our said Circuit CourtCircuit Court ,
at the City of St. LouisCity of St Louis, this twenty eighth day of September in the year of our Lord, one thousand eight hundred and thirty-one

Archibald GambleArchibald Gamble

Clerk, C.C.
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[missing figure]
JuliaJulia (a woman of color)
vs
SamuelSamuel M KinneyM Kinney

In Vacation 28th September 1831
Clerks office of the St Louis Circuit CourtCircuit Court

On the application of the attorney for the Plaintiff it is Ruled
that a Dedimus issue to any Judge or Justice of the peace of the StateIllinois
of IllinoisIllinois to take the depositions of witnesses to be read in evidence on the
trial of the above cause on the part of the Plaintiff

A True Copy of the Rule

Archibald GambleArchibald Gamble Clerk

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[missing figure]

The of appears
by the schedule
march 23d 1832

AndrewAndrew Philips

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[missing figure]
JuliaJulia
vs
Mkinney

filed opened
Oct14th 1831

A GambleArchibald Gamble

Phineas Block
for defendant
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[missing figure]

to be handed
to lawyer

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[missing figure]

COUNTY OF ST. LOUISLouis , SCT.

State of MissouriMissouri,

To the Sheriff of Saint LouisSt Louis County---Greeting.

You are hereby commanded to summon John BentJohn Bent - JacobJacob Cooper
and James G AJames G A MKinney
that setting aside all manner of excuse and delay, they be and appear in proper person before the Judge
of our Circuit CourtCircuit Court , on the 7th day of December next at the City of St.LouisCity of St Louis, then
and there to testify and the truth to say in a certain matter of controversy now pending in our said Court,
wherein JuliaJulia (a woman of color) is plaintiff, and
SamuelSamuel MKinney is defendant, on the part of the
plaintiff; and have you then there this writ.

[missing figure]
Witness, Archibald GambleArchibald Gamble , Clerk of our said Circuit CourtCircuit Court ,
at the City of St. LouisCity of St Louis, this 12th day of November in the year of our Lord one thousand eight hundred and thirty - one

Archibald GambleArchibald Gamble

Clerk, C.C.
View original image: Page  037
[missing figure]
November Term 1831
JuliaJulia
vs
SamuelSamuel MM Kinney KinneyM Kinney

+James G AJames G A MKinney 23

+JohnJohn Bent BentJohn Bent 15

+ JacobJacob Cooper 15

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[missing figure]

Executed this writ on John BentJohn Bent JacobJacob
Cooper 15 and James G AJames G A MKinney 2323 of November 1831 in St LouisSt Louis Ross
not found

John K WalkerJohn K Walker

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[missing figure]

150
121/2
1,621/2

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[missing figure]
JuliaJulia
vs
SamuelSamuel MKinney

The said defendant excepts to the depositions taken on the
part of the plainiff in the above case for the following
reasons

1 That said depositions were taken without legal notice
of the time and place of taking them

2 That it does not appear that said depositions were
reduced to writing in presence of the Justice of the peace

3 That it does not properly appear that the witnesses
were sworn

4 That the said depositions are not properly certified
or authenticated

AB Gamble

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[missing figure]
Julia
vs
M KinneyM Kinney

Exceptions to depositions

filed Decr 2nd 1831

A GambleArchibald Gamble
clk

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[missing figure]

State of IllinoisIllinoisMorganMorgan county

SS

I DennisDennis Rockwell clerk of the county
[ commisioners ] court of said county
do certify that WilliamWilliam R Smith
before whom the foregoing depositions
of Joseph J BennettJoseph J Bennett and Benjamin
F Mathews were taken, was on the thirteenth day of July Eighteen Hundred and thiry one a Justice of the peace within
and for the county of MorganMorgan ,
duly [ commisioned ], and serve
into office as required by Law.

[missing figure]
Given under my
hand & the seal of court
this fourteenth day of October Eighteen Hundred and thirty one.

DennisDennis Rockwell

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[missing figure]
JuliaJulia
vs
MKinney

Opened & filed

[ decs ]5th 1831

A gamble
Clk


Dept of
Joseph J BennettJoseph J Bennett
for defendant
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[missing figure]

COUNTY OF ST. LOUISLouis , SCT.

State of MissouriMissouri,

To the Sheriff of Saint LouisSt Louis County---Greeting.

You are hereby commanded to summon - James G. A. MKinney
John BentJohn Bent & JacobJacob Cooper
that setting aside all manner of excuse and delay, they be and appear in proper person before the
Judge of our Circuit CourtCircuit Court , on the Thirtieth day of march next at the
City of St. LouisCity of St Louis, then and there to testify and the truth to say in a certain matter of controversy now
pending in our said Court, wherein JuliaJulia is
plaintiff, and SamuelSamuel MKinney is defendant, on the part of the plaintiff; and have you then there this writ.

[missing figure]
Witness, Archibald GambleArchibald Gamble , Clerk of our said
Circuit CourtCircuit Court , at the City of St. LouisCity of St Louis, this Eighteenth day of February in the year of our Lord one thousand eight hundred and thirty- two

Archibald GambleArchibald Gamble

Clerk C.C.
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[missing figure]
March Term 1832
JuliaJulia
vs
SamuelSamuel MKinney

for

James G AJames G A MKinney

+ John BentJohn Bent

6

+ JacobJacob Cooper

27 on 30th march
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[missing figure]

Executed this writ on JacobJacob Cooper
27th July - on John BentJohn Bent 6th of March
1832in the city of St LouisSt LouisJames GJames G
MKinney not found

John KJohn K

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[missing figure]

12 1/2

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[missing figure]
JuliaJulia a woman of color
vs
SamuelSamuel M KinneyM Kinney

In the St louis Circuit Court
la said Defendants

Sir, on the 23rd day of March instant at the [ dencling ] house of mimead
Philips in the
County of PikeCounty of Pike & State of IllinoisIllinois at a place
near Philips ferry on the IllinoisIllinois River Between
the hours of 8 O clock am & 6 O clock
P.M. I shall take the deposition of witnesses
to be read in [ under ] in this cause

March 13th 1832

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[missing figure]
JuliaJulia
vs
M KinneyM Kinney

nature of taking
Depositions
Service this notice
on S. M. Kinney
by reading it to
him in the city of
Stlouis on the

14 - March 1832

John Walker
Shff


sum 500
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[missing figure]
JuliaJulia a woman of color
vs
SamuelSamuel M KinneyM Kinney

In St LouisCircuit Court Circuit CourtCircuit Court
for freedom

The said plaintiff comes & filesher depositions
to the reading of all the depositions taken &
filed in the part of the defendant &
specifies her reasons for her depositions.

1 That no legal notice has been given to said
plaintiff of the time & place of taking said
depositions

2 That said Depositions have not been taken
pursuant to notice

3 That said Depositions do not appear to have
been taken before any important authority

4 That said Depositions are within
authenticated as the law requires they should be


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[missing figure]
JuliaJulia
vs
SamuelSamuel M KinneyM Kinney

Depositions to defendants

Depositions filed

filedMarch 27th 1832

A GambleArchibald Gamble clk

overruled
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[missing figure]

This affiant beleives that the only witnesses by whom
Plaintiff can prove her right to freedom reside
in Pike CountyPike County IllinoisIllinois & he knows of no other
witnesses by whom the same facts can be proved
which she to prove by said many
& Philips & he believes from what
states to him that she knows of the matter

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[missing figure]
JuliaJulia
vs
M KinneyM Kinney

affidavit for
a continuance

filed april 11th 1832

AGambleclk

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[missing figure]

County Of St. LouisSt Louis-SCT.

Sate of MissouriMissouri,

To the Sheriff of St. LouisSt Louis county-Greeting.

You Are Hereby Commanded To Summon & James JJames J MKinney
John BentJohn Bent and JacobJacob Cooper
that setting aside all manner of excuse and delay, they be and appear in proper person
before the Judge of our Circuit CourtCircuit Court , on the 27th day of July next
at the City of St. LouisCity of St Louis, then and there to testify and the truth to say in a certain matter of
controversy now pending in our said Court, wherein JuliaJulia is
plaintiff, and SamuelSamuel MKinney is
defendant, on the part of the plaintiff
and have you then there this writ.

[missing figure]
Witness: Archibald GambleArchibald Gamble , Clerk of our said Circuit CourtCircuit Court ,
at the City of St. LouisCity of St Louis, this 29th day ofJune in the year of our Lord one thousand eight hundred and thirty two

ArchibaldArchibald Gamble GambleArchibald Gamble

Clerk C.C.
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[missing figure]
July Term 1832
JuliaJulia
vs
SamuelSamuel MKinney

for plaintiff

Rojo James SJames S MKinney

JohnJohn Bent BentJohn Bent 11

JacobJacob Cooper 2

on 27th July
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[missing figure]

Exceutive this writ on JacobJacob Cooper on & on John BentJohn Bent
the 18th day of July 1832 by reading it to them in
the city & county of SaintSt Louis LouisSt Louis- and JamesJames G
GJames G MKinney not found in my county

John KJohn K Walker WalkerJohn K Walker Sheriff


By

BrothertonBrotherton

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[missing figure]

senior $ 1.00
25
$ 1.25

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[missing figure]

COUNTY OF ST.LOUISLouis , SCT.


State of MissouriMissouri,

To any Judge or Justice of the Peace of the state of IllinoisIllinois--GREETING.

WE, reposing special trust and confidence in your itegrity and circumspection, do require and command you that you cause
to come before you such person or persons as shall be named to you by JuliaJulia a woman of color or by SamuelSamuel
MKinney --- their attorney or agent, and him or them examine upon
his, her or their corporal oath (to be by you administered) touching their knowledge of any thing that may relate to a certain matter
of controversy, now pending in our Circuit CourtCircuit Court , for the county of St. LouisSt Louis, wherein JuliaJulia
is plaintiff and SamuelSamuel MKinney
defendant on the part of the plaintiff and having so reduced the said depositions so taken by
you as aforesaid into writing, you are required to send the same, together with this commission, enclosed under your seal, to our
said Circuit CourtCircuit Court , with all convenient speed.

[missing figure]
WITNESS, Archibald GambleArchibald Gamble , Clerk of our said Circuit CourtCircuit Court , at the City of StCity of St Louis.
LouisCity of St Louis, this fifth day of July in the year of our Lord, one thousand eight hundred and thirty two

Archibald GambleArchibald Gamble

Clerk, C.C.
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[missing figure]

A farm of Heading Depositions
The Depositions of here insert the names of the
Deponents taken before me AndrewAndrew Philips
a Justice of the Peace within & for the
CountyCounty Pike of ? PikeCounty Pike & StateIllinois of IllinoisIllinois at his
dwelling house [ situate ] in said County
on the Bank of the IllinoisIllinois river at a
place called Philips Ferry between the
hours of eight O clock in the forenoon
& Six Oclock in the afternoon of that
day to be read in evidence in a certain
matter in controversy in the Circuit CourtCircuit Court
of St Louis County pending in which
JuliaJulia a woman of color is plaintiff
& SamuelSamuel MKinney is defendant on
the part of the plaintiff
of lawful age being sworn &

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[missing figure]
in the part of the plaintiff deposes &
says here insert the statement of the witness
at the end of deposition should be a
certificate in the following form
. I AndrewAndrew Philips a Justice of the Peace within
& for the CountyCounty Pike
of PikeCounty Pike & State of IllinoisIllinois do
hereby certify that the above named deponents
here insert their names were by me duly
sworn to testify the whole truth of their
knowledge touching the matter in controversy
aforesaid that their examination was
reduced to writing & by them respectively
subscribed in my presence on the day
at the place & between the hours in
that behalf first aforesaid

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[missing figure]

The depositions should be then sealed
as
follows.

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[missing figure]
JuliaJulia
vs
SamuelSamuel MKinney

In the clerk of the CircuitCircuit Court
CourtCircuit Court at at St LouisSt Louis, MissouriMissouri

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[missing figure]
JuliaJulia
vs
SamuelSamuel J Mkinney

The defendant excepts to the depositions of
and AnnaAnna Beckerdike filed by plaintiff
for the following

1 There was no notice of the time & place such depo-
sition given the defendant

2 There was no legal and sufficent notice of
the time and place of taking said depositions
given the defendant

3 That the said witnesses were not duly sworn

4 That the deposition are not taken according
to notice

5 That the depositions are not duly certified by
the justice of the peace

6th that the depositions are not sufficiently au
-thenticated

7 That there no sufficient evidence of the
official character of the justice of the peace
before the whom depositions were taken

ARGamble

View original image: Page  054
[missing figure]
JuliaJulia
vs
S J MKinney

Exceptions to depositions

filed july 1832

AGClk

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[missing figure]

COUNTY OF ST. LOUISLouis --SCT.


State of MissouriMissouri,

To the Sheriff of St. Louis County -- GREETING.

YOU ARE HEREBY COMMANDED TO SUMMON - James G AJames G A MKinney
John BentJohn Bent - JacobJacob Cooper
that setting aside all manner of excuse and delay, they be and appear in proper person
before the Judge of our Circuit CourtCircuit Court , on the 4th day of December next
at the City of St. LouisCity of St Louis, then and there to testify and the truth to say in a certain matter of
controversy now pending in our said Court, wherein JuliaJulia (a woman of color) is
plaintiff, and SamuelSamuel MKinney is
defendant, on the part of the plaintiff
and have you then there this writ.

[missing figure]
WITNESS: ARCHIBALD GAMBLE, Clerk of our said Circuit CourtCircuit Court ,
at the City of St. LouisCity of St Louis, this 2nd day ofNovember in the year of our Lord one thousand eight hundred and thirty- two

Archibald GambleArchibald Gamble

Clerk C.C.
View original image: Page  055
[missing figure]
View original image: Page  056
[missing figure]
November Term 1832
JuliaJulia
vs
SamuelSamuel MKinney

for plaintiff


+James G AJames G A MKinney 8


John BentJohn Bent


+JacobJacob Cooper 9


on 4th December
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[missing figure]

Executed this writ on GA MKinney
on the 8th Nov and on JacobJacob Cooper on
the 9th Nov 1832 by reading the same
to them in the County of St LouisCounty of St Louis
John BentJohn Bent not found in

my County

John R WalkerJohn R Walker Sheriff


By

J. Blood Dept Sheriff

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[missing figure]

$ 1.00
12
1.12

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[missing figure]
JuliaJulia a woman of color
vs
SamuelSamuel J MKinney

In the CircuitCircuit Court CourtCircuit Court , for the CountyCounty of St Louis
ofCounty of St Louis St LouisCounty of St Louis,, State of MissouriMissouri.

To JuliaJulia the above named plaintiff and GustavusGustavus A Bird AGustavus A Bird
BirdGustavus A Bird her attorney

YOU ARE HEREBY NOTIFIED, That Depositions of Witnesses to be read in
evidence in the above cause, on the part of the Defendant, will be taken, at
the office of Archibald Williams in the town of Quincy
in the County of Adams and State ofIllinois IllinoisIllinois, on the eighteenth day of Marchnext, between the hours of 8 o'clock in the
forenoon, and 6 o'clock in the afternoon. and also at the court house
in Pittsfield in the county of PikePike in the state of IllinoisIllinois
on the twenty seventh day of March next between the hours
of six Oclock in the forenoon and six Oclock in the afternoon
and if it be necessary to continue the taking of such depositions
at either of the above places heyond the day appointed for taking
them at such place the taking thereof will be continued from day to
day at the same place and between the same hours until the whole
shall be completed

ARGambleArchibald Gamble

for February 27th 1834
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[missing figure]

This notice duly servedFebruary 27th 1836 and I agree
that depositions taken in pursuance thereof may
be read in evidence in the suit of (who
is the child of JuliaJulia ) against SamuelSamuel JMKinney
subject to all exceptions that they would be able to,
if they were taken in that case in the form in which
they may be returned

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[missing figure]
JuliaJulia
vs.
MM Kinney KinneyM Kinney

notice degrement

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[missing figure]
JuliaJulia a woman of color
vsSamuelSamuel M KinneyM Kinney

Suit for freedom in StCircuit Court LouisCircuit Court
Circuit CourtCircuit Court MissouriMissouri

GustavusGustavus A Bird AGustavus A Bird BirdGustavus A Bird on behalf of Said Plaintiff
says he as one of the for the Plaintiff
of her as to her right to freedom & the witnesses
by whom she could prove that right & was informed
that the most material for her were Philips & AndrewAndrew Philips & the family
of said living in IllinoisIllinois- the affiant causes a notice
to be served on the defendant that on the 23rd day
of March last at the dwelling house of
Philips in Pike CountyPike County & StateIllinois ofIllinois IllinoisIllinois near a
place called Philips Ferry on the IllinoisIllinois river between
the hours of 8 O Clock A.M & 6 Oclock PM
of that day plaintiff wants take the depositions
of witnesses to be read in evidence in said cause
This affiant says Said notice was served on defendant
at St LouisSt Louis on the 14th day of March last &
that the distance from St LouisSt Louis to the residence
of said Philips is nextone hundred &
twenty miles - This affiant says that on the 29
day of March & pursuant to said notice he attended
at the place mentioned in said notice for the
purpose of taking said depositions that on
arriving there he found that said Philips
was dead - but this affiant proceeded to take
depositions at the late residence ofsaid Philips
on the day & between the hours specified in
said notice - that he took the depositions of
daughter of said
which depositions are here on file
& which depositions state facts which this affiant
show that said Plaintiff is entitled to her
freedom

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[missing figure]
and to which depositions on file the affiant refers
to show that they are material to the
This affiant says he had never heard of the death of
said Philips until after said notice
was given & until this arrived near his late residence & he beleives the plaintiff had never
heard of the death of said Philips [ untill ]
she was informed of his death by this affiant
This affiant further says that after taking Said
Depositions he left the Depositions with the
Justice before whom they were taken for the
purpose of having the official character of
the Justice attested by the certificate of the clerk
of the County Commissions Court of Pike County
& StateIllinois of IllinoisIllinois under the seal of Said Court & gave Said Justice the many
which he said was to defray the
and said Justice agreed that he could
cause said depositions to be authenticated &
put in the Post Office Pike CountyPike County
IllinoisIllinois directed to the Clerk of the St LouisCircuit Court
Circuit CourtCircuit Court by the 26th of March last
This affiant says that in the day Said Depositions
were filed he took them out of the Post Office
at St LouisSt Louis - that they came without
being endorsed under the seal of the Justice
& without being authenticated & without any
certificate under the seal of the County Commissions
Court. This affiant says that at the Court
of the Plaintiff he has taken unusual care
to prepare this cause for trial at this term
& he beleives it is no fault of Plaintiff as her
counsel that said depositions are not authenticated
This affiant beleives the depositions of said
can be procured properly
authenticated by the Term of this court

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[missing figure]

Depositions of Witnesses produced service and exam
ined on the 3 day October in the year of our Lord One Thousand
Eight hundred & thirty one, between the hours of One and
Six O Clock in the afternoon of that day, at the Store House of
Phineas Block in the Town of LouisianaLouisiana & County ofCounty of Pike PikeCounty of Pike in
the state of MissouriMissouri; before me S. N. , Justice of the Peace
within and for the County aforesaid in a certain cause now
defending in the Circuit Court of the County ofCounty of Saint Louis Saint LouisCounty of Saint Louis
in the State ofMissouri MissouriMissouri, between JuliaJulia woman of color
Plaintiff and SamuelSamuel M KinneyM Kinney defendant on the part of the
defendant

Emily Stewart of lawful age being producedsworn
and claimed on the part of the defendant deposith
saith that in December Eighteensometime about the first day
December eighteen hundred & Twenty nine a certain color
woman named JuliaJulia was hired by Dr. Abraham Stewart
for the term of twelve months from Joseph G Carrington
and at the end of Eight or nine months the said
coloured woman JuliaJulia was returned to CarringtonCarrington
on account of sickness

Emily Stewart

Sworn and Subscribed to before me, on the day, at
the peace, and within the hours first aforesaid

Justice of the Peace
View original image: Page  061
[missing figure]

Phineas Block of lawful age, being duly produced sworn
and examined on the part of the defendantdeposeth
and saith, that sometime in DecemberEighteen hundred
Twenty Nine, D A braham StewartStewart informed me that he
hired a certain [ colou ] woman named JuliaJulia for Twelve
months, and that he saw her frequently in the employm
ent of Sald StewartStewart

Phineas Block


Sworn and Subscribed to before me on the day
at the place and within the hours first aforesaid

Justice of the Peace
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[missing figure]

, a Justice of the peace within & for the
county of PikePike , in the State of Misssouri, do hereby certi
fy, that Emily Stewart, & Phineas Block, the deponents were
by me severally sworn to testify the whole truth of their
knowledge, touching the matter in controversy aforesaid
that they were examined, and their examination redu
-ced to writing, & by them, respectively subscribed in
my presence, on the day, between the hours, and at the
place in that behalf first aforesaid.

View original image: Page  062
[missing figure]

COUNTY OF ST. LOUISLouis --SCT.

State of MissouriMissouri,

To the Sheriff of St. Louis County--GREETING.

You are hereby commanded to summonJames G AJames G A MKinney
John BentJohn Bent - JacobJacob Cooper that setting aside all manner of excuse and delay; They be and appear in proper person before the
Judge of our Circuit CourtCircuit Court , on the Twenty Eighth day of Marchnext
at the City of St. LouisCity of St Louis, then and there to testify and the truth to say, in a certain matter of controversy
now pending in our said Court, wherein JuliaJulia is
plaintiff, and SamuelSamuel MKinney is
defendant, on the part of the plaintiff
and have you then there this writ.

[missing figure]
WITNESS: Archibald GambleArchibald Gamble , Clerk of our said Circuit CourtCircuit Court , at the City ofCity of St Louis
St. LouisCity of St Louis, this Twenty second day of February in the year of our Lord one thousand eight hundred and thirty- three

Archibald GambleArchibald Gamble


Clerk C.C.
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[missing figure]
March Term 1833
JuliaJulia
vs
SamuelSamuel MKinney

for plaintiff

James G AJames G A MKinney


John BentJohn Bent


John BentJohn Bent


on 28th March
View original image: Page  063
[missing figure]

Executed this writ on JacobJacob Cooper on
the 27th of July 1833& on JohnJohn Bent BentJohn Bent
2nd of March 1833 in St.LouisSt Louis county


John KJohn K Walker WalkerJohn K Walker

View original image: Page  064
[missing figure]

SamuelSamuel MKinney

Sir

You will take notice that to
friday,, I shall apply to the circuit court in their sent
the circuit court of St.LouisSt Louis county where in
I plaintiff and you are defendant

JuliaJulia woman of
color


March 1833
View original image: Page  065
[missing figure]

Served this notice on SamuelSamuel
MKinney on the 27th March 1833by reading it to him in
the city of St LouisSt Louis


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[missing figure]
JuliaJulia
vs
MKinney

notice

View original image: Page  066
[missing figure]
JuliaJulia a woman of
color
vs
SamuelSamuel MKinney

The plaintiff comes for a new trial in
this cause for the following reasons

1 Because the court erred in his instructions to the
Jury

2 Because the court in his instructions to the Jury
the presence of the Jury - by determining
a matter of fact which should have been left
to the Jury

3 Because the of the Jury was against Said

4 Because the verdict of the Jury was contrary to
the

View original image: Page  067
[missing figure]
JuliaJulia a woman
of colour
vs
SamuelSamuel MM Kinney KinneyM Kinney

for new trial
& reasons

filed april 4th 1833

A GambleArchibald Gamble clk

View original image: Page  067
[missing figure]

35 53
13 35 53
49 38 41
13 13 87
17 17 1587
14

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[missing figure]
JuliaJulia a woman of colour
vs
SamuelSamuel MM Kinney KinneyM Kinney

Gustavus A BirdGustavus A Bird on behalf of
JuliaJulia the above named plaintiff on his oath
says that he prays an appeal to the Supreme court
in this case & that his application for an appeal
on behalf of said JuliaJulia is not made for the purpose of any action
or delay but because this affiant wrily
believes said JuliaJulia is agreed by the decision & Judgement
of the St Louis Circuit CourtCircuit Court on which said
prays the appeal is prayed

G A BirdG A Bird


Sworn to in open
court april 8th 1833

A GambleArchibald Gamble clk

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[missing figure]
JuliaJulia
vs
M KinneyM Kinney

affidavit for appeal

filedapril 8th 1833

AArchibald Gamble GambleArchibald Gamble clk

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[missing figure]

appeal grantedBook 6 page 457

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[missing figure]
Best remembered that
JuliaJulia a woman of colour
vs
SamuelSamuel MKinney

Best remembered that on the
trial of the cause The Depositions of which the
following are were read in evidence on the part
of the plaintiff (here insert the Depositions of
Narris, Philips & Mr chills taken 23 march 1832 ameting the heading & certificates)

and on the part of the Defendant the Depositions
of which the following are capis where read in
.

BenjaminBenjamin Matthews of lawful age being produced sworn and examined
on the part of the defendant deposeth and sayth that JuliaJulia the plaintiff in the
whose cause was taken to MissouriMissouri and hired out to in MissouriMissouri that she
became sick in MissouriMissouri and remain sick for some time, that she was taken
back to Mrs CarringtonCarrington in Pike CountyPike County IllinoisIllinois to be nursed and restored to health
and trial as soon as she was able to work taken to Saint LouisSt Louis and sold
that he was the individual who brought the plaintiff from MissouriMissouri
to Mrs CarringtonCarrington
when sick

Emily Stewart of lawful age being produced sworn and
examined on the part of the Defendant deposith and saith
that some time about the first day of december eighteen hundred and Twenty nine a certain coloured
woman named
JuliaJulia was hired by Dr Abraham Stewart for the term of
Twelve months from Joseph G Carrington and at the
end of eight or nine months the said coloured woman
JuliaJulia was returned to CarringtonCarrington on
account of sickness

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[missing figure]
It was admitted that at the commencement of
of this suit the defendant was in posession of
of the plaintiff claiming her as his salve no
other was addressed

On Motion of the defendant the following
Instructions were given to the Jury
(here insert the three instructions given by the court)
The Jury found the Defendant not guilty
whereupon the plaintiff for a new
trial & filed the following reasons therefore
(here insert the reasons for a new trial)
The court overruled the motion for a new trial
& to its decision in doing so the plaintiff
& tenders this Bill which is signed sealed & made
part of the record

[missing figure]

View original image: Page  071
[missing figure]
JuliaJulia
vs
Sam M KinneyM Kinney

of be filed

april 8th 1833

A GambleArchibald Gamble clk

View original image: Page  072
[missing figure]
JuliaJulia a woman of Color
vs
SamuelSamuel MKinney

Suits for Freedom to
in St Louis CircuitCircuit Court
CourtCircuit Court MissouriMissouri

In the above named
in each cause
Take notice that I shall proved to take depositions
to be read in each of said causes on the team by
first day of November instant at the dwelling
house of AndrewsAndrews Philips at Philips Ferry on the IllinoisIllinois
river in the CountyCounty Pike of PikeCounty Pike & StateIllinois of IllinoisIllinois
and at the Court house in the town of
in Pike CountyPike County aforesaid on the twenty third
day of November instant between the hours
of 8 O Clock AM and Six O CLock PM
of each of said days and I Shall continue
to take depositions at each place from day to
day (Sundays ) between the same hours
in each day until I shall have taken as
many as I deem necessaryNov 11th 1899

for said JuliaJulia &


of
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us

nature of taking

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Executed this notice by recording it to SamuelSamuel J
McKinney in the city of St LouisSt Louis on the 11th day of November 1833

JohnJohn K Walker K WalkerJohn K Walker Sheriff


by




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[missing figure]

COUNTY OF ST.LOUISLouis , SCT.

State of MissouriMissouri


To any Judge or Justice of the Peace of the State ofIllinois IllinoisIllinois
--GREETING.

WE, reposing special trust and confidence in your integrity and circumspection, do require and command you that you cause
to come before you such person or persons as shall be named to you by JuliaJulia a woman of Color - or by
SamuelSamuel M.Kinney their attorney or agent, and him or them examine upon
his her or their corporal oath (to be by you administered) touching their knowledge of any thing that may relate to a certain matter
of controversy, now peinding in our Circuit CourtCircuit Court , for the county of St. LouisSt Louis, wherein JuliaJulia a woman of color
is plaintiff and SamuelSamuel MKinney is
defendant on the part of the Plaintiff and having so reduced the said depostions so taken by
you as aforesaid into writing, you are required to send the same, together with this commission, enclosed under your seal, to our
said Circuit CourtCircuit Court , with all convenient speed.

[missing figure]
WITNESS, Archibald GambleArchibald Gamble , Clerk of our said Circuit CourtCircuit Court , at the City of StCity of St Louis.
LouisCity of St Louis, this Eleventh day of November in the year of our Lord, one thousand eight hundred and thirty-three

Archibald GambleArchibald Gamble

Clerk, C.C.
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[missing figure]

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writing depositions -/200 and at 12th hundred 33 cts
3 non $1, 50
2 Subpoenas 37
Serving 2 Subpoenas 50
3 Certificates & 75
Witness fees 200
Clerks fee certificate & Seal 50

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[missing figure]

COUNTY OF ST. LOUISLouis , SCT.

State of MissouriMissouri,

To any Judge or Justice of the Peace of the State of IllinoisIllinois
--GREETING.

We, reposing special trust and confidence in your integrity and circumspection, do require and command you that you cause
to come before you such person or persons as shall be named to you by Harrit an Infant of color (who sues by G A BirdG A Bird
her next friend) or by SamuelSamuel J MKinney their attorney or agent, and him or them examine upon
his, her or their corporal oath (to be by you administered) touching their knowledge of any thing that may relate to a certain matter
of controversy, now pending in our Circuit CourtCircuit Court , for the county of St. LouisSt Louis, wherein Harrit an infant of Color (who sues
by G A BirdG A Bird her next friend) is plaintiff and SamuelSamuel J M KinneyM Kinney is
defendant on the part of the Plaintiff and having so reduced the said depositions so taken by
you as aforesaid into writing, you are required to send the same, together with this commission, enclosed under your seal, to our
said Circuit CourtCircuit Court , with all convenient speed.

[missing figure]
WITNESS, Archibald GambleArchibald Gamble , Clerk of our said Circuit CourtCircuit Court , at the City of StCity of St Louis.
LouisCity of St Louis, this Eleventh day of November in the year of our Lord, one thousand eight hundred and thirty three

Archibald GambleArchibald Gamble

Clerk, C.C.
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JuliaJulia
vs
SamuelSamuel MKinney

Supreme CourtSupreme Court Third Judicial District of the State of MissouriMissouri
October Term 1833
Monday 21st October 1833
Court met pursuant to Adjournment-present all the Judges

Appeal from ST Louis Circuit CourtCircuit Court
Now at this day come again the parties aforesaid by their
respective attorneys and the court now here being sufficiently advised of and
concerning the premises consider that the Judgment aforesaid in form aforesaid
by the said Circuit CourtCircuit Court rendered be reversed and for nought held and Esteemed
and it is ordered by the court that this cause be remanded to the said CircuitCircuit Court
CourtCircuit Court for further proceedings therein in conformity with the opinion of this
Court delivered in this case and it is further considered by the Court that the
said JuliaJulia the appellant recover [ againt ] the said SamuelSamuel MKinney the appelle
in this case her costs and charges by her about the prosecution of her appeal
in this behalf expended and that she have thereof Execution

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[missing figure]
JuliaJulia a Woman of Color
vs
Sam M Kinny

Error to the circuit Court of St. Louis County

This was an action commenced under the [ Statute ] for freedom
verdict & [ Judgment ] against JuliaJulia the plaintiff- The bill of exceptions [ shews ] the
following case, that M Kinny the defendant bought the plaintiff as a Slave from
one Sucinda CarringtonCarrington - that in the year 1829MrsCarringtonCarrington lived in the StateKentucky
of KentuckyKentucky that she then had in her the plaintiff JuliaJulia as a slave, that
she then & there determined & declared her intention to be to remove & take with
her JuliaJulia to the State ofIllinois IllinoisIllinois, that a witness in this cause applied to her to buy
JuliaJulia telling MrsCarringtonCarrington that she could not hold JuliaJulia in IllinoisIllinois as a
Slave, that if she took her there she would be free- Mrs C refused to sell JuliaJulia ,
said she would not keep JuliaJulia in IllinoisIllinois but intended to hire her out in MissouriMissouri-
Accordingly Mrs C moved to IllinoisIllinois, brought with her said JuliaJulia , arrived
in PikePike county Ill about the 27th or 28th of October, settled herself there, purchased land
& she kept JuliaJulia there with her till about the 1st of December the same year exercising
the ordinary acts of ownership & dominion over her which are usually exercised by
masters over their slaves- That in the meantime Mrs CarringtonCarrington hired JuliaJulia about
two days to some person to work, which work was performed and that she received pay
therefor, that about the 1st of December in the same year MrsCarringtonCarrington sent JuliaJulia
to LouisianaLouisiana MissouriMissouri a distance of about 30 miles and hired her out that JuliaJulia lived
in MissouriMissouri sometime, became sick, and that Mrs C, then sent for JuliaJulia took her home
into PikePike county in Ill. where she was kept till she recovered her health - that then
Mrs C, took or sent JuliaJulia to StSt Louis LouisSt Louis and sold her to S M KinneyM Kinney the defendant- several
instructions were asked by the defendant which were given and Excepted to, the defendant
also moved for a nero trial, which was refused- The first instruction given by the Court
is that if the Jury believe from the evidence that the plaintiff JuliaJulia was taken into the
State ofIllinois IllinoisIllinois by her owner without any intention on the part of such owner to make
that State the residence of JuliaJulia that the plaintiff is not entitled to recover in this

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action, we will consider this instruction before we notice the others - the plaintiff claim
to freedom is based on the 6th article of the constitution of the state of IllinoisIllinois which
declares that neither slavery nor involuntary servitude shall hereafter be introuduced
into this state otherwise than for the punishment of crimes whereof the party shall
have been duly convicted,-the article then goes on to make some provision with regard to
hiring persons bound to service in other states and concludes by saying any Violation
of this article shall effect the emancipation of such person from his obligation to service
we see by this constitution that the very introduction of Slavery works an Emancipation
of the slave and it is argued that if we give this constitution a literal construction no one
can travel through that state with his slaves without emancipating them - It is true
that a literal construction would lead directly to this result. Every law should be
adjudicated on with a view to the end and object thereof, the object of the constitution
of IllinoisIllinois was not to prevent persons owning slaves in KentuckyKentucky from passing through
IllinoisIllinois with their slave property to MissouriMissouri, but to prevent the relation of master and
slave from existing in that state by an inhabitant and resident thereof. We are farther-
more of opinion that all persons who are citzens of any of the states have a right by the
constitution of the United StatesUnited States to pass through IllinoisIllinois with any sort of property that
they may own in the state where they migrate from. - The 2nd Section of the 4th article
of the [ constution ] of the U.S. says that the citzens of each state shall be entitled to
all the [ privilegs ] and immunities of citizens in the several states we are of opinion
that it is the undoubted right of every citzen of the United StatesUnited States to pass freely through
every other state with his property of ever description including negro slaves without
being in anyway subject to forfeit his property for having done so provided he does
not subject his property by a residence to the action of the laws of the state in which
he may so reside- another view of the subject is that out of the general words of
the IllinoisIllinois constitution of necessity exceptions must be raised, though it is true
that slavery shall not be introudced in that state under penalty of forfeiting the
property yet it can be introudced so far and to permit persons passing through the state
as Emigrants or mere travellers to carry with them their slave property and to retain
in them their their right to such property while they retain the character of Emigrants
or travellers otherwise there could be no emigration through the state with slave
property which is a thing it cannot reasonably be supposed the constitution of IllinoisIllinois
intended to forbid, How long the character of Emigrant or traveller through the state
may last cannot by any genral rule be determined, but it seems that reason does
require it should last so long as might be necessary according to the common mode
of travelling to accomplish a trandit through the state, if any accident should happen
to the emigrant which in ordinary cases would make it reasonable and prudent
for him to suspend his journey for short time we think he might do so without
incurring a forfeiture if he resumed his Journey as soon as he safely could, something
more than the more convenience or ease of the emigrant ought to intervene to save
him from a frofeiture something of the nature of necessity should exist before he would
or ought to be exempt from the forfeiture - if swollen streams of water which could
not be crossed without danger should intervene, serious sickness of the family, broken
wagons & the like should exist, these would be good causes of delay so long as they exist
if the Journey is resumed as soon as these impediments are removed provided also
due diligence is used to remove them - In the case before us the owner of the

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The slave was not an Emigrant but went into IllinoisIllinois with an avowed view to make that
state her home, she took up her residence there with her slave in her possession & kept the
slave there for upuwards of one month, and treated the slave in all respects as slaves are
treated in states where slavery is allowed, these acts of the owner surely amounted to the
introduction of slavery in Ill: unless therefore the case can be brought within some reason-
-able and Equitable exception to be engrafted on the constitution of IllinoisIllinois the palintiff
will be entitled to exact the forfeiture of Emancipation- In this case we see nothing in the
nature of accident to prevent the owner from taking the plaintiff to MissouriMissouri immediately -
The excuse set up is that the owner was a widow and might not have had the means of
[ immedide ] transportaion of the slave to missouri, that she was a new comer in the country &
might be poor &therefore unable to do it, that some reasonable time ought to be allowed to
her to provide a residence for herself and family and that one month in this case is not
too much, we are of opinion that the excuse to raise an exception must be something more
than the mere convenience or inconvenience of the owner. - But the instruction assumes
that if the owner did not intend to make IllinoisIllinois the residence of the slave then there is no
violation of the constitution, Is it true that if a person says he does not intend to do an act
& yet does it that the act is not done- the constitution of Ill: does not regard the intention
to introduce or not to introduce slavery but prohibits the act- If a person says he
does not intend to introduce slavery yet if he does introduce it defacts can the innocent
intent save him from the forfeiture, we think it casnnot, unless he can also show that his
caseraises a reasonable and necessary exception. But in this case the evidnece is that the
owner did intend and infact did introduce slavery in IllinoisIllinois but declared that she did
not intend to continue it for any length of time but that she would take the slave to MissouriMissouri
and there hire her out, but suppose the owner did not intend to make Ill: the place of
the slaves residence permanently but only for one month, yet slavery is introduced and
continued for the mere convenience of the owner without any circumstances which raise
a just or even a resonable exception in her favor. - The case of WinneyWinney vs. WhitesideWhitesides
decided by this court has been cited to prove that what the owner intended is to be a criterion
to govern the question of freedom or slavery - that was a case where the owner of a slave
removed to the northwestern territory now Illionis, with the slave with the intent to make
that country his residence, and he did in fact make it his residence as well as that of
his slave also- The ordinance of CongressCongress for the Government of that territory declares
there shall be neither slavery nor involuntary servitude in the Territory - This court
decided that if the owner went there with a slave with intent to make that place his
permanent residence and the residence of his slave and did in fact do so that the slave
was by such residence free But the court did not decide that the slave was free by reason
of the intent being declared - The second instruction given assumes that the slave
is not entitled to freedom because she was taken to IllinoisIllinois and remained there till she was
cured of sickness, we will give no opinion on this point as we consider the case fully
decided on the first and 3rd instructions. - The third instruction is, that the plaintiff
is not entitled to recover under the second section of the 6th Article of the constitution of
of Ill. - The section delcares that no person bound to labor in any other state shall
be hired to labor in this state except within the tract reserved for the salt works It then
concludes as before stated that any violation of this article shall effect the emancipation

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of such person from his obligation to service, whether this instruction intends to decide
that the facts testified are true or untrue or only decides that the proof and case made does
not in law entitle the party to recover we do not exactly know, it seems however that
the instruction is wrong because it decides both the fact and the law - But if the instruc-
tion only assumes to decide the law yet it is wrong, the evidence is that after the slave was
fairly introduced into IllinoisIllinois and settled for the time being but with an intent on the
part of the owner to remove the slave at some future time to MissouriMissouri, the owner did hire the
slave to a person to labor for one or two days & received the pay for the hire - The court instructed
the Jury that this hiring is not a hiring within the prohibition above cited, We suppose the
circuit court thought the degree or quantity too small- We believe the object of this prohibi-
tion was to prevent slave labor from becoming a substitute for white or free labor throughout
the state, the constitution makers have therefore prohibited the thing in every possible
degree, here was a hiring of a person bound to labor in KentuckyKentucky whilst in KentuckyKentucky,
brought into IllinoisIllinois (not to reside there say, if you will) and hired to labor for one or
two days by the owner, what difference can it make if the hiring had been for 100 days,
We see none except in the degree or quantity of time. - With regard to the motion for a new
trial we think the court erred in refusing it, the reasons assigned for the new trial are
that the verdict is against law & Evidence, the Evidence is sufficient to bring the case within
the operation of the constitution - The Judgement of the Circuit CourtCircuit Court is reversed, the
cause is remanded for a new trial

M M Girk
GeorgeGeorge Tompkins

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I think the Circuit CourtCircuit Court erred in giving the 3rd instruction - assuming to decide the facts
as well as the law of the case; & therefore concur in reversing the Judgment - The 1st & 2nd
instructions were in my opinion properly given. The claim to freedom under the provisions
of the IllinoisIllinois Constitution must be founded either upon a residence of the Slave, or a hiring
of the slave to labor what shall amount to a residence or a hiring against the provisions
of the constitution must depend upon the facts & circumstances of each particular case.
A bare removal into the State can form no ground on which to set up the claim: Es-
pecially when it is [ shewn ] that the removal is not made with a view to residence. The
intention of the owner as previously declared is the only evidence that can exist in
such a case. To hold then that it matters not whether the owner intends to make IllinoisIllinois
the residence of his slave or not is to exclude (as it appears to me) the only evidence that can
exist where the claim is founded on a bare removal to the State - the intention with which
a thing is done, gives color & character to almost every transaction, the emigrant who
journeying to MissouriMissouri unfortunately gets his leg broken, or being detained by serious
sickness keeps his slaves with him in IllinoisIllinois for weeks or months until he recovers
sufficiently to resume his Journey will not thereby forfeit his property in his slaves, and
why ? because his residence for a week a month or a winter was unintentional and
accidental & the slaves were detained there without any intention of his part of making
it the place of their residence so the owner of a slave who in passing through IllinoisIllinois
permits the slave at night to brush his landlord's boots, or make his fire, or shuck his corn
for such reward as the landlord may think proper to give would not surely be adjudged
to forfeit his slave under the provisions of the 2nd sec of the 10th Article of the Constitution
and why ? because the owner did not intend in taking his slave to IllinoisIllinois or in Jour
-neying through, or sojourning in the State to hire him to labor - for it will not be contended
that the master did not intend that the slave should perform the particular service &
receive therefor the Stipulated reward; that is brush the boots or make the fire &

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receive therefor the 12 1/2 cents or the half pint of whiskey - thus it seems to me that the facts
& circumstances in every case are to be weighed with the intention of the parties acting therein
& to be charged therefor. The introduction of slavery or the attempt to introduce it is
regarded in some sort as a criminal act & is punished by a forfeiture of the property intro-
duced- we must then look to the intention of the party introducing the slave to determine
the degree of guilt & see if the Spirit of the Constitution has been violated since it is clear
it's letter cannot be enforced any other doctrine will convert the kind & tender nursing
by the master of his sick & helpless slave into a sort of crime

R. WashR Wash .

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[missing figure]

State of MissouriMissourisct

J Joseph C BrownBrown Clerk of the Supreme CourtSupreme Court for the
third Judicial District of the State of MissouriMissourido certify that the above is a
true copy of the Judgment rendered by said Court at October term thereof in the year Eighteen Hundred and thirty three in the case of JuliaJulia appellant and SamuelSamuel
M KinneyM Kinney appellee and of the opinions of the Court delivered in said cause at
the term aforesaid at the same now remain of Record in my office

[missing figure]
Given under my Hand and the seal of the
said SupremeSupreme Court CourtSupreme Court at office in the city
and county of StSt Louis LouisSt Louis in the District afore-
said this Sixteenth day of November in the year of our Lord One thousand Eight Hundred and thirty three

JosephJoseph C BrownBrown Clerk

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No 66
March term 1831
JuliaJulia --- a woman of color
vs
SamuelSamuel M KinneyM Kinney

Transcript from Supreme CourtSupreme Court

Filed 16th November 1833

ArchibaldArchibald Gamble GambleArchibald Gamble Clerk

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[missing figure]

Depositions of witnesses taken before
me AndrewAndrew Philips a justice
of the peace within and for the
County of PikeCounty of Pike and state of
IllinoisIllinois at the dwelling house of AndrewAndrew
Philips at Philips Ferry on the IllinoisIllinois
River in the County ofCounty of Pike PikeCounty of Pike and
State aforesaid on the twenty first
day of November in the year
of our Lord Eighteen Hundred
and thirty three between the
hours of Eight O Clock in the
forenoon and six o clock in the
afternoon of said to be heard
in evidence in two certain cases
now pending in the CircuitCircuit Court CourtCircuit Court
for the County of St LouisCounty of St Louis and
State of MissouriMissouri in
one of which JuliaJulia of colora
woman of color is plaintiff and
SamuelSamuel M KinneyM Kinney is defendant

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and in the other HarrietHarriet an infant
of color who was
by G. A Bird her next friend is
plaintiff and SamuelSamuel J M KinneyM Kinney
is defendant pursuant to the
Anexed Commissions and notice
taken on the part of the plaintiff
in each cause

Nancy BrightNancy Bright of lawful age
being produced sworn and examined
on behalf of the plaintiff in each
of said causes deposeth and
that on the Twenty seventh or twenty
eighth day of October A D 1829[ Mis ] Lucanda
CarringtonCarrington arrived with her family in
the state of IllinoisIllinois- she said she came from
KentuckyKentucky & intended to settle on Illnois
She brought with her Julia & Harriet
the Daughter of Julia as she was called
[ Mrs ]CarringtonCarrington remained at Philips
ferry one without intending
her and in one or two days
after her arrival she went about
a mile & a half between this place
& went into a house called Bennits
hence where she spent the winter on

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[missing figure]

on the last part of deponent was
then being at Philips Ferry had known
Mrs CarringtonCarrington in KentuckyKentucky soon after Mrs
CarringtonCarrington arrived in IllinoisIllinois she told
Deponent that She Mrs CarringtonCarrington
had every thing to & that if Depon-
int should at any time want the plaintiff
JuliaJulia to work for her she could hear her
& could pay her for Julias work in
any thing she had to spare JuliaJulia the
Plaintiff worked for me one or two
days & I paid for her work in
soap. Mrs Carringtons came
for the soap & said then mother
had sent them for the soap for Julias
washing. I frequently saw Julia &
Harriet with Mrs Carringtons family
in Pike CountyPike County IllinoisIllinois between the
time of her arrival & christmas not
following - Mrs CarringtonCarrington told deponent
She had been offered a grand price for
said Julia & Harriet in KentuckyKentucky
but she did not want to sell them
while JuliaJulia was in IllinoisIllinois she was
engaged in Mrs Carringtons business
& obeyed her commands as slaves
generally do some time about
christmas Julia & Harriet were sent to MissouriMissouri

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[missing figure]
to be hired out in
Mrs CarringtonCarrington has lived in IllinoisIllinois since
her arrival in 1829. & soon after she
purchased land as she informed me in this
County & on the County of MorganCounty of Morgan
I heard the defendant
M KinneyM Kinney say he had purchased said
Julia & Harriet from JosephJoseph Carring
ton & that he intended to bar JosephJoseph Carrington
& CarringtonJoseph Carrington selling
Harriet & Julia for slaveswhen they
were free

Nancy BrightNancy Bright

Sworn & Subscribed to before
me on the day between the
hours & at the place first aforesaid

AndrewAndrew Philips


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[missing figure]

WilliamWilliam Scholle of lawful age being present
& sworn on the part of the plaintiff
in cause deposeth & saith
that he has been accquainted withMrs
CarringtonCarrington since her arrival
in the state of IllinoisIllinois inOctober 1829
She spent the fall & Winter in this
county about a mile & a half below
this in March or February she settled
on a piece of land adjoining the
one she
Miss Carrington brought with her
a negro woman JuliaJulia who had
a child called HarrietHarriet about 4 or
five years old Mrs CarringtonCarrington

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[missing figure]

kept said Julia & Harriet in IllinoisIllinois
until some time before Christmaswhen
they were sent to Lousiana in MissouriMissouri
& hired out as I understand from
Mrs CarringtonCarrington & her son JosephJoseph
The evening before Christmas Mrs
CarringtonCarrington had a daughter married
JuliaJulia was sent for as I understand
from Mrs Carringtons family & I think
from Mrs CarringtonCarrington to assist in
cooking for
was at the & saw JuliaJulia
engaged in services about the house
of Mrs CarringtonCarrington

In the summer or fall of 1830
I saw JuliaJulia at the house of Mrs
CarringtonCarrington in IllinoisIllinois She was
then said to be unwell
I think about September 1830 Mrs
CarringtonCarrington & one of her sons & one
of her daughters stayed all night
at my fathers in IllinoisIllinoisJuliaJulia
one of the plaintiffs was with
Mrs CarringtonCarrington & family They had
been engaged as Mrs CarringtonCarrington
then said at one JohnJohn B BJohn B
Mathews in spreading -
JuliaJulia was thenapparently well

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[missing figure]
and had been engaged in spreading
as Mrs CarringtonCarrington said
BenjaminBenjamin Mathews a daughter of Mrs CarringtonCarrington
in the summer
& fall of 1830 he lived in MorganMorgan County
CountyMorgan County IllinoisIllinois distant about 12 or
14 miles from where Mrs CarringtonCarrington
lived HarrietHarriet was always in IllinoisIllinois
with JuliaJulia her mother
when JuliaJulia came from MissouriMissouri
to a third the aforesaid
JuliaJulia while she was in IllinoisIllinois was
in the service of Mrs CarringtonCarrington
& there to her between
Mrs Carrington & Julia & Harriet
that relation which generally
subsists between Master & Slave

Sworn & Subscribed to
before me on the day between the hours
& at the place first aforesaid

AndrewAndrew Philips J S

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[missing figure]

State of IllinoisIllinois

Pike County

I AndrewAndrew Philips a
Justice of the Peace within & for said
State & County do certify that the
deponents Nancy BrightNancy Bright & WilliamWilliam
Scholle were by me duly sworn to testify
the whole truth of knowledge
touching the matters in controversy
between the parties aforesaid in each
of the above suits that then
wereby mereduced to writing
& by the deponents respectively subscribed

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[missing figure]

in my presence on the day between the
hours & at the place on that behalf
Just aforesaid pursuant to the
commisions & notice witnesses
my hand at Phillips Ferry Pike CountyPike County
IllinoisIllinoisNovember 21st 1833

AndrewAndrew Philips J S


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[missing figure]

StateIllinois ofIllinois IllinoisIllinois
Pike County

I WilliamWilliam Scholle clerk of
the County Commisions court for the CountyCounty Pike
of PikeCounty Pike & StateIllinois of IllinoisIllinois do certify that
AndrewAndrew Philips whose signature is subscribed
to the foregoing certificate is
at the date of said certificate on
acting Justice of the peace within & for
the county of PikePike & State ofIllinois IllinoisIllinois
duly commissioned & qualified at such
& that full faith & credit is due
to his acts as such

[missing figure]
In testimony whereof I the said
clerk do here to subscribe my name
& the seal of said Court
at office at in said county
the twenty first day of November
in the year of our Lord
Eighteeen Hundred & thirty three

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[missing figure]
JuliaJulia
vs
Sam M KinneyM Kinney
HarrietHarriet
vs
Sam M KinneyM Kinney

Depos of
Nancy BrightNancy Bright
for
plaintiffs

opened sfiled
nov 25 1833

A GambleArchibald Gamble Clerk


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[missing figure]
JuliaJulia
vs
SamuelSamuel J M KinneyM Kinney

Exceptions to Depositions

The Dept excepts to the depositions of
Nancy BrightNancy Bright and WilliamWilliam Scholle filed in this case

1st Because then was no legal notice given of the time
and place of taking depositions

2d That the depositions were not taken in pursuance of
the notice given
3d That the depositions are not properly certified.


for
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[missing figure]
JuliaJulia
vs
M KinneyM Kinney

Exceptions to [ Depo ]

Filed 6th December 1833

Archibald GambleArchibald Gamble Clerk

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[missing figure]
State

State of Illinois
Pike CountyPike County

JohnJohn B BJohn B Mathews of lawful age
being produced sworn examined on the part
& behalf of the said Defendants, Deposeth & saith

Mrs CarringtonCarrington came to this County in the fall
of the year 1829, when the weather was very
cold - her horses ran away soon after getting
here & under all the circumstances, she sent
her negros to MissouriMissouri as soon as was practic
able even before she made any settlement
in this [ Country ], Julia a woman of Colour
& her her child HarrietHarriet are the Negros I
refer to - They were carried to MissouriMissouri
in the Month of November 1829. By JosephJoseph Carrington
CarringtonJoseph Carrington , the son of Mrs CarringtonCarrington
The said JuliaJulia never did any labour at
my house or for me at fear or at
any other thing - at the time aforesaid
there was no other man but myself in the
Neighbourwood in which Mrs CarringtonCarrington
then lived of the name of Mathew, at the
time aforesaid when Mrs CarringtonCarrington came
to this county. The ice was very
badly in the Mississippi RiverMississippi River, it was
dangerous to cross the River.

I am well acquainted with the general
character of WilliamWilliam Scholle - It is very
bad - I do not think him entitled to face
credit as a witness

I am & have been for nine years past
well acquainted with the charge
s of NancyNancy , now Nancy BrightNancy Bright
& formerly the reputed wife of
Philips - her character is very bad

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[missing figure]
I would not believe her statements, made
under oath as a witness, from a knowl
edge of her character.

The said JuliaJulia came back to Mrs CarringtonCarrington
during the christmas holidays 1829 leav
ing her said Child in MissouriMissouri - She
was taken back to MissouriMissouri/ in about 2 days
after Christmas aforesaid J B Mathews
I M.E. Rattau one of the Justices of the
peace within & for the county of PikePike
do hereby certify that J. B. Mathews, the
deponent was by me sworn to testify the whole
truth of his knowledge touching the matter
in controversy the case aforesaid that
the deponent was examined & his exam
ination reduce to writing & subscribed
& subscribed by said Deponent in my
presence on the 27th day of march 1834
between the hours of Ten O Clock AM &
3 O Clock PM at the court house in
Pittsfield in the county of PikePike & state
of IllinoisIllinois

Given & certified this 27th day of March 1834

M.E. Rattau I. P.

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[missing figure]

of lawful age being produced
sworn & examined on the part of the said Defen
dant, Deposeth & saith

I was present at AndrewAndrew -Philips'
in Pike CountyPike County at a time when the Deposi
tions of Nancy BrightNancy Bright & WilliamWilliam Scholle were
taken by Mr BirdBird to be used as evidence
in this case- Mr. BirdBird wrote the Depo
sitions in many respects differently from
what he was directed by the deponents, &
at the request of the Deponents he would
not correct the depositions saying for
excuse that they were the same in

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[missing figure]

meaning with the true answers. This deponent
believes the Depositions as taken by the
said BirdBird had a very aifferent mean
-ing
from that which the Deponents
intended they should have

Elvin his

X

McWorthy
mark
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[missing figure]

I ME Rattau an acting justice of PikePike county and state
of Ill do hereby certify that Elvin McWorthy the
deponent was by me sworn to testify the whole truth of
his knowledge touching the matter in controversy in the
cause aforesaid that deponent was examined and his
examination reduced to writing and subscribed by said
deponent in my presence on the 27th day of March D 1834 Between the hours of 8 o clock A.M. and 6 o clock
P.M. at the court house in Pittsfield Pike CountyPike County
and state of Ills

given and certified the 27th of March 1834

ME Rattau

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[missing figure]

I ME Rattau an acing justice of the peace in & for the
county of PikePike & State ofIllinois IllinoisIllinois do certify that in pursuance
of the within commission & notice came before me at the court
house in Pittsfield in Pike County & State ofIllinois IllinoisIllinois Joseph J
Burnett WillamWillam Burnett J boston Wills John A wiveron
NathanNathan Philips John BJohn B Mathews & Elvin Mcworthy
who were there by me sworn and examined and such
examination reduced to writing and subscribed by them
respectively in my presence and there said depositions
are now here with returned given at Pittsfield
in the county of PikePike and State of Ills
this 27th day of march AD 1834

ME Rattau

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[missing figure]

State of IllinoisIllinois
Pike CountyPike County

It is hereby certified, that
Mecarel E. Rattau, Esbr, on the twenty sev-enth day of March in the year of our Lord eighteen hundred of thirty four
was & is an acting Justice of the
peace within & for said county of Pike
& State of Ilinois duly commissioned &
acting as such, & that full faith & credit
are due to his acts as such-

[missing figure]
In testimony where J W. Ross
clerk of the county court court
of said county have herewith
subscribed any & affixed
the seal of said court at
Pittsfield their 27th day of March A.D 1834

W Ross. Clerk

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[missing figure]
JuliaJulia
vs
Sam J M KinneyM Kinney

Opened filed
March 31st 1834

A GambleArchibald Gamble clk


for Defendant
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[missing figure]

Depositions of witnesses proudced sworn & examined at
the court house in Pittsfield in the county of PikePike & StateIllinois ofIllinois
IllinoisIllinois before me E Rattau an acting Justice of the
peace in & for the county & State aforesaid in a certain cause now
depending in the circuit court in & for the county of St LouisSt Louis
and StateMissouri ofMissouri MissouriMissouri between JuliaJulia a woman of color and
Plaintiff and SamuelSamuel J M KinneyM Kinney Defendant on the part
of the defendant.

Joseph J Bennet of lawful age being produced sworn
and examined on the part of the defendant deposeth & saith
that Lucunda CarringtonCarrington served into Pike CountyPike County IllinoisIllinois
sometime in the full of 1829& brought with her a woman of
color [ caled ]JuliaJulia and a small negro give the daughter of said JuliaJulia
the weather was cold & stormy & the ice was in the [ Missippi ] river so as to make it dangerous crossing it That
she Mrs CarringtonCarrington applied to this deponent and obtained
leave to stay in one of his houses until she coulg get on
to MissouriMissouri That about the time Mrs CarringtonCarrington stopped
in Pike CountyPike County aforesaid her horses strayed off that she this
deponent was acquainted with Mrs CarringtonCarrington
during the the said negros remained in said PikePike County
CountyPike County & that she always manifested great anxiety to
have them taken out of the state of IllinoisIllinois and that
she did send them on to MissouriMissouri as soon as her horses were
found and the MississippiMississippi could be crossed with
any kind of safety.

That he is acquainted with the general character of NancyNancy Bright
BrightNancy Bright & could not from her general character believe her
under oath That the said Nancy BrightNancy Bright was the respected
wife of Numrod Philips and lived with him as such till
his death when it was ascertained that her proper name
was Nancy MorrisNancy Morris & that she was not the wife of said
Philips she married a Mr Bright

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[missing figure]
and further this deponent saith not

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[missing figure]

I ME Rattau an acting justice of the peace in and for the
county of PikePike and state of Ills do certify that Joseph
J Bennet the deponent was by me Sworn to testify the
whole truth of his knowledge touching the matter in
controversy in the cause aforesaid that the deponents
was examined and his examination reduced to
and subscribed by [ sd ] deponent in my presence
on the 27th day of March D 1834 between the hours
of 8 o clock AM and 6 o clock PM at the court
house in Pittsfield in the county of PikePike and state
of Ills given and certified the day last aforesaid

ME Rattau

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[missing figure]

WilliamWilliam Bennett of lawful age being produced sworn &
examined deposeth & saith that Lucinda CarringtonLucinda Carrington got
a house of his father in the fall of 1829 for a short time
until she could travel on to MissouriMissouri That she Mrs Car
rington was moving as he then understood from KentuckyKentucky to MissouriMissouri
That she had with her a negro woman called JuliaJulia and her
child called HarrietHarriet that the weather so cold as to
make it very difficult for movers to travel that
It was also understood that the crossing of the [ Missippi ]
was dangerous because of ice.

That Mrs CarringtonCarrington was extremely anxious to get on
to MissouriMissouri as soon as the weather moderated & her
horses were found & the river could be safely crossed
Joseph CarringtonJoseph Carrington her son carried said negro to
MissouriMissouri

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[missing figure]

I ME Rattau an acting justice of the peace
in and for the county of PikePike and State of

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[missing figure]

Ills do certify that WilliamWilliam Bennet the
deponent was by me sworn to testify the whole
truth of his knowledge touching the matter in
controversy in the cause aforesaid, that
deponent was examined and his examination
reduced to writing and subscribed by said depo
nent in my presence on the 27th day of MarchAD 1834 between the hours of 8 o clock AM
and 6 o clock PM at the court house in Pittsfield
in the county of PikePike and state of Ills
Given and certified the day last aforesaid

ME Rattau

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[missing figure]

of lawful age being produced sworn & examined
on the part of the defendant deposeth & saith
That he was present at AndrewAndrew Philips in PikePike county
State of IllinoisIllinois when the depositions of Nancy MorrisNancy Morris &
AnneAnne Philips were taken in the above cause on the part of
the plaintiff the depositions were written by Mr BirdBird
the plaintiff's attorney the deposition of NancyNancy Morris MorrisNancy Morris
was taken in the name of NancyNancy Philips & where she came
to sign it she said that was not her name that her name was
Nancy MorrisNancy Morris and signed it accordingly

That when he Mr BirdBird had written several answers the
Witnesses objected that they were not correctly written
& Mr BirdBird said it was the same thing in substance and
did not alter them that Mr BirdBird was in the neigh
-bourhood several days before the taking of the depositions
and that deponent saw [ sid ] Bird & Nancy Morris out on
the river bottom together killing wild ducks before
the depositions were taken and that he this deponent
was a while with them & then left them trying to get
a duck out of the water which he this deponent shot
that Nancy MorrisNancy Morris was some times called by that name
and at other times NancyNancy Philips & that she is now

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[missing figure]
called NancyNancy Bright BrightNancy Bright having married a man of that
name but from whom she is now - divorced & that AnneAnne
Philips is now [ maried ] to a man of the name of
That he has been accquainted with Nancy MorrisNancy Morris for
twenty years and that her character has always
that time been bad that he is well acquainted with
the general character of WilliamWilliam Schoell and
that he could not prove that character believe him
under oath

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[missing figure]

I ME Rattau an acting justice of the peace in and for PikePike County
CountyPike County and state of [ Ill ] do hereby certify that the
deponent was by me sworn to testify the whole truth of his know-
ledge touching the matter in controversy in cause afore said, that
deponent was examined and his examination reduced to writing, and
subscribed by said deponent in my presence on the 27th day ofMarch AD 1834 between the hours of eight in the morning and
six in the afternoon at the court house in Pittsfield
PikePike County CountyPike County and state of Ill

Given and certified this 27th day of March AD 1834

ME Rattau

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[missing figure]

John A Windsor being produced sworn & examined deposeth
& saith that he was present last fall at AndrewAndrew Philips' in
Pike CountyPike County State of IllinoisIllinois when the deposition of WilliamWilliam Shull
was taken in the above cause on the part of the plaintiff that it was written
by Mr BirdBird the plaintiff attorney That deponent saw
Mr BirdBird pay Mr Shull a dollar or upwards for his attend
ance as a witness and heard said BirdBird tell him he would
also pay his bill for his nights lodging to Mr Philips
and that Mr lawful fee for attendance would
have been fifty cents

John A Windsor

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[missing figure]

I M.E. Rattau an acting justice of the peace in and for PikePike County
CountyPike County and state of Ill do hereby Certify that John A Windsor
the deponent was by me sworn to testify the whole truth

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[missing figure]

of his knowledge touching the matter in controversy in
the cause aforesaid that the deponent was examined
and his examination reduced to writing and subscribed by
said deponent in my presence on the 27th day of march AD 1834 between the hours of 8 o clock in the AM
and 6 in the PM at the court house in Pittsfield PikePike
county and state of Ill, given and certified the
27th of March 1834

M.E. Rattau

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[missing figure]

NathanNathan Philips of lawful age being produced sworn
and examined deposeth & saith that he is accquainted with
Nancy MorrisNancy Morris and that he would not beleive her underoath
if she was interested or prejudiced in the case that she is
the same person that is now called Nancy BrightNancy Bright & that
he heard her express herself in an unfriendly manner
towards Mrs CarringtonCarrington before her deposition was
taken in the above cause on the part of the plaintiff

NathanNathan Philips

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[missing figure]

I M.E. Rattau an acting Justice of the peace in and
for the county of PikePike and state of
Ill do here by certify that NathanNathan Philips
the deponent was by me sworn to testify the
whole truth of his knowledge touching
the matter in controversy in the cause
aforesaid that the deponent was
examined and his examination reduced
to writing and subscribed by said deponent
in my presence on the 27th day of marchAD 1834 Between the hours of 8 o clock A.M. and
6 o clock in the P.M. at the court house in Pittsfield
PikePike county state of Ill given and certifi
-ed the 27 day of March AD 1834

M.E. Rattau

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[missing figure]
JuliaJulia a woman of color
vs
SamuelSamuel J M KinneyM Kinney

In the circuit court for the county
of St LouisSt Louis State ofMissouri MissouriMissouri

To JuliaJulia the above named plaintiff and GustavusGustavus A Bird
A BirdGustavus A Bird her attorney

you are hereby notified that depositions of witnesses to
to be read in evidence in the above cause On the part of the defend
ant will be taken at the office of Archibald Williams in the
town of in the county of AdamsAdams & state of IllinoisIllinois on the eighteenth day of March next between the hours of 8 o clock in the forenoon and
6 O clock in the afternoon and also at the court house in Pittsfield
in the county of PikePike in the state of IllinoisIllinois on the twentyseventh day of March next between the hours of six o clock in the forenoon and six
o clock in the afternoon and if it be necessary to continue the taking of
such depositions at either of the above places beyond the day appointed
for taking them at such place the taking thereof will be continued from
day to day at the same place and between the same hours until the whole
shall be completed

H B Gamble att for Dept

February 27. 1834
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[missing figure]

COUNTY OF ST.LOUISLouis ,SCT.

State of MissouriMissouri,

To any Judge or Justice of the Peace of The State of IllinoisIllinois
--GREETING.

WE, reposing special trust and confidence in your integrity and cricumspection, do require and command you that you cause
to come before you such person or persons as shall be named to you by JuliaJulia a womam of color or SamuelSamuel J
M. Kinney their attorney or agent, and him or them examine upon
his, her or their corporal oath (to be by you adminsitered) touching their knowledge of any thing that may relate to a certain matter
of controversy, now pending in our Circuit CourtCircuit Court , for the county of St. LouisSt Louis, wherein JuliaJulia a woman of color
is plaintiff and SamuelSamuel J M KinneyM Kinney is
defendant on the part of the Defendant and having so reduced the said depostions so taken by
you as aforesaid into writing, your are required to send the same, together with this commission, enclosed under your seal, to our
said Circuit CourtCircuit Court , with all convenient speed.

[missing figure]
WITNESS, Archibald GambleArchibald Gamble , Clerk of our said Circuit CourtCircuit Court , at the city of StSt Louis.
LouisSt Louis, this twenty seventh day of February in the year of our Lord, on thousand eight hundred an thirty four.

Archibald GambleArchibald Gamble

clerk, C.C.
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[missing figure]

COUNTY OF ST. LOUISLouis ,SCT.

State of MissouriMissouri,

To any Judge or Jusitce of the Peace of The State of MissouriMissouri
--GREETING.

WE, reposing special trust and confidnece in you integrity and cirumspection, do require and command you that you cause
to come before you such person or persons as shall be named to you by JuliaJulia a woman of color or SamuelSamuel
J M KinneyM Kinney their attorney or agent, and him or them examine upon
his, her or their corporal oath (to be by you adminstered) touching their knowledge of any thing that may relate to a certain matter
of controversy, now pending in our Circuit CourtCircuit Court , for the county of St. LouisSt Louis, wherein JuliaJulia a woman of color
is plaintiff and SamuelSamuel J M KinneyM Kinney is
defendant on the part of the Defendant and having so reduced the said depositions so taken by
you as aforesaid into writing, you are required to send the same, together with this commission, enclosed undre your seal, to our
said Circuit CourtCircuit Court , with all convenient speed.

[missing figure]
WITNESS, Archibald GambleArchibald Gamble , Clerk of our said Circuti Court, at the City of StCity of St Louis.
LouisCity of St Louis, this twenty seventh day of February in the year of our Lord, one thousand eight hundred and thirty- four.

Archibald GambleArchibald Gamble

Clerk, C.C.
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[missing figure]

STATE OF ILLINOIS,
Adams COUNTY,


Sct.

I, HenryHenry H. Snow Clerk of the County Commissioners
Court for the county aforesaid, do hereby certify that James HJames H Raleton
whose name is subscribed to the foregoing certificate was at the time of subscribing
the same, an acting Jusice of the Peace within and for the county of AdamsAdams
aforesaid, duly commissioned and qualified, and that full faith and credit is and
ought to be given to all his official acts as such.

[missing figure]
In testimony whereof, I have hereunto set my hand and
affixed the Seal of the County Commission
court this 19th day of MarchA.D. 1834.

HenryHenry H Snow

Clerk.
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[missing figure]

State of IllinoisIllinois
AdamsAdams county

The deposition of witness produced sworn
& exmanined at the office of A
Williams Esq & in the town of in the
said county of AdamsAdams in the state of IllinoisIllinois
before me a justice of the
peace within & for said conty in a certain
cause now depending in the circut court
for the county of St LouisSt Louis state of MissouriMissouri
between JuliaJulia a woman of colour
plaintiff & SamuelSamuel J M KinneyM Kinney , Defendant
on the part of the said defendant

HenryHenry Baitman of lawful age being
deposeth & saithproduced sworn & ex
amined on the part of the said defend-
ant deposeth & saith, in answer to Inter
rogatories

Interrogatory
1st And you acguainted with the parties
in the of this suit named &
so at what time did you become acguaninted

Answer - I am not acquainted with defendant
Mrs Carringtion came into PikePike county IllinoisIllinois
near to Philips ferry in the neighbourhood
in which I then lived & brought with her
a woman of color named JuliaJulia , who
I suppose to be the Plaintiff to this suit
on or about the 15th day of November 1825, She the said JuliaJulia continued
there with Mrs CarringtonCarrington about
two weeks during which time I was acqu
ainted with her. At the end
of which time she was taken by JosephJoseph
Carring since deceased (the son of Mrs Carringtion)
to MissouriMissouri & there hired out to labour, since that time I have not been ac-
quaninted with her or seen her more than
once.

Interrogatory
2nd When & where did your see her afterwards

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[missing figure]

Answer to
2nd. Interrogatory About the time of Christmas Holidays of
the year 1829. I saw her at Mrs Carring
tonsaforesaid.

Question 3rd. At what time did she return to MissouriMissouri
again, & who went with her.

Answer She returned the monday after Christ
mas & Joseph CarringtonJoseph Carrington aforesaid
went with her

Question 4th. Did her little Daughter go with
her to MissouriMissouri at that time

Answer No The child went with her when
She first was taken to MissouriMissouri &
had not been brought back to
IllinoisIllinois

Question 5th. Do you know why JuliaJulia was not
taken to MissouriMissouri immediately
after Mrs CarringtonCarrington brought her
to the neighbourhood of Philips
ferry

Answer - About the time she came there her
(Mrs Carrington's) horses ran away &
were gone about a week during
which time JosephJoseph Carring (her only son
able to do business) & myself were
hunting for them - It was also
understood that The [ Missippi ]
River could not be safely crossed
at that time on account of ice
in it.

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[missing figure]

Question 6th. Was or was not Mrs CarringtonCarrington about the
time anxious to send the said JuliaJulia
to MissouriMissouri without delay

Answer She manifested much anxiety to send
her, & did send her as soon as was
practicable

Question 7th. Are you acquainted with the gener
-al character of NancyNancy Bright BrightNancy Bright ,

Answer - I have been acquainted with her
general character for four years

Question 8th. From your knowledge of her
Character, would you beleive her
evidence given under oath

Answer In a case where she has prejudice
I beleive she would be as apt to sware
falsely as to sware the truth

Question 9th. Is the said NancyNancy Bright BrightNancy Bright the same
person who was formerly reputed to be
the wife of Philips & did she
live with said Philips as his wife

Answer - She is the same person & she did
live with the said Philips as his
wife

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[missing figure]

Question 10th. Do you know what was her proper name
when she lived Philips

Answer I do not but I have understood It was
Nancy MorrisNancy Morris

Question 11th. Was the said NancyNancy friendly with Mrs
CarringtonCarrington

Answer In the years 1829 & 1830. when I was last
personally acquainted with her she
was very unfriendly with Mrs Carring
ton

HenryHenry Baitman

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[missing figure]

IJamesJames A AJames A Ralston a Justice of the Peace within & for
the county of AdamsAdams & StateIllinois ofIllinois IllinoisIllinois, do
here by certify, that HenryHenry Baitman, the Deponent
was by me sworn to testify the whole truth of
his knowledge touching the matter in contro
versy in the case aforesaid That the Deponent
was examined & his examination reduced
to writing & subscribed by said Deponent
in my presence on this Eighteenth day of March Eighteen hundred & thirty four, between
the hours of Ten o clock in the [ fournoon ] & of
Two o clock in the afternoon at the office of
A Williams Esq in the town of in the
County of Adams & StateIllinois of IllinoisIllinois
Given & Certified by me this 18th day of March in the year 1834.

James AJames A . Ralston

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[missing figure]

State of IllinoisIllinois
Adams County

I JamesJames A AJames A Ralston Jus-
tice of the peace within & for the County
of Adams, & StateIllinois of IllinoisIllinois, do Certfy that
in pursuance of the within commissions &
notice, Came before me, at the office of
Archibald Williams in the town of
& County & state last aforesaid, HenryHenry
Baitman, who was there by me sworn &
examined & such examination reduced to
writing, & subscribed by him in my
presence & his said depositions is
now herewith returned.

Given at in the County
of Adams & state of IllinoisIllinois, this
18th day of March 1834

James AJames A .Ralston

for taking the aforegoing Deposition H
Advanced by defendant,

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[missing figure]
JuliaJulia
vs
M KinneyM Kinney

for Deft

opened & filed
March 26 1834

A GambleArchibald Gamble clk

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[missing figure]

COUNTY OF ST.LOUISLouis ,SCT.

State of MissouriMissouri,

To any Judge or Justice of the Peace of the State of IllinoisIllinois
--GREETING.

WE, reposing special trust and confidence in your integrity and circumspection, do require and command you that you cause
to come before you such person or persons as shall be named to you by JuliaJulia (a woman of color) or by SamuelSamuel M KinneyM Kinney
or her or his attorney or agent, and him or them examine upon
his, her or their corporal oath (to be by you administered) touching their knowledge of any thing that may relate to a certain matter
of controversy, now pending in our Circuit CourtCircuit Court , for the county of St. LouisSt Louis, wherein JuliaJulia is
plaintiff and SamuelSamuel M KinneyM Kinney is
defendant on the part of the Plaintiff and having so reduced the said depositions so taken by
you as aforesaid into writing, you are required to send the same, together with this commission, enclosed under your seal, to our
said Circuit CourtCircuit Court , with all convenient speed.

[missing figure]
WITNESS, Archibald GambleArchibald Gamble , Clerk of our said Circuit CourtCircuit Court , at the City of StCity of St Louis.
LouisCity of St Louis, this tenth day of April in the year of our Lord, one thousand eight hundred and thirty-four

Archibald GambleArchibald Gamble -

Clerk, C.C.
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[missing figure]

Farm of heading & certifying Depositions
â The depositions of witnesses taken before me
â A P. a Justice of the peace within & for the county
" of PikePike and state of IllinoisIllinois at the Court house
â in the town of Pittsfield in said county on the
(here insert the day, or days when the depositions
shall be taken) between the hours of eight
O clock in the [ founoon ] & Six O clock in the
afternoon of the same day (or days)between
the hours ofto be read in evidence in a
certain cause pending in the court &
between the parties in the -
commission mentioned

A B of lawful age being produced sworn &
examined on the part of the plaintiff
deposeth & saith here insert the statement
of witnesses-. The witnesses must sign his
disposition & it must be written in presence
of the Justice & at the foot of each
deposition the Justice
must state the date
as follows sworn & subscribed
before me

This 17th day of april 1834APIP.

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[missing figure]

At the fact of all the depositions must be a
certificate in the following form

I A P a Justice of the peace within & for the county of
PikePike & StateIllinois ofIllinois IllinoisIllinois do certify that the above
deponents were by me duly sworn to testify the
whole truth of their knowledge touching the
matter in controversybetween the parties afore-
said that then examinations were reduced
to writing & by them respectively subscribed
in my presence on the days between the hours
& at the place in that behalf first aforesaid

A P J P

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[missing figure]

Nature has been on the defendant that
the plaintiff will take depositions at the
court house in the town of Pittsfield in the
county of PikePike & State ofIllinois IllinoisIllinois on the
17th the day of april 1834between the hours
of 8 o clockA.M.& 6 o clock PM. of
that day & that she will continue
taking depositions there from day to day
between the same hours of each day
as is necessary

The depositions must be taken at the
very place must be begun on the
day between the hours named in
the notice to

G A BirdG A Bird

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[missing figure]

The depositions of witnesses taken before me
Mearel. E. Rattau a justice of the peace within and for
PikePike County CountyPike County and state of Ill at the court house
in the town of Pittsfield in said county on the seventeenth day of April AD 1834 between the hours of 8 o clock
AM and 6 PM of the same day to be [ red ] in
evidence in a certain case pending in court between the
parties in the commission mentioned

AbramAbram of lawful age being produced and sworn
& examined on the part of the plaintiff Deposeth & saith
Question are you acquainted with Mrs Lucunda CarringtonCarrington and
if so how long (answer) before she came to the Ill
and since within one or two weeks after she came
Qn when did she come to the Ill
Anâ in octâ AD 1829
2 did or did she not bring A woman of color named
JuliaJulia and a child named HarrietHarriet .
Ans, she did and they was at my house frequently
that fall and winter

2 Did Mrs CarringtonCarrington treat them as salves
Ans My understanding was that they was subject to Mr.
Carringtons control and in my presence was treated as
slaves

Ques, How long did Mrs. CarringtonCarrington keep those slaves in
Ill. before she carried them to MissouriMissouri

Ans I cannot state the time But I recollect of
saying that she had as well be careful as she
might, get herself in difficulty By keeping slaves too long in the IllinoisIllinois

Ques How long more you resided in the Ills

ans about nine years come fall in this county
Ques Do you know of Julias any feat for at
Mr for Mr Carrington

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[missing figure]
Julia
vs
M KinneyM Kinney

opened & filed
april 28 1834

A GambleArchibald Gamble Clk

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Ann Bickerdike of lawful age being Produced
and sworn on the plaintiff Deposeth and
sayeth Question state if you please when
Mrs CarringtonCarrington Came to the Ills and whether
or not that she [ brot ] with her JuliaJulia
and HarrietHarriet persons of Color

Ans she came here the last of oct 1829
and did Bring JuliaJulia and HarrietHarriet with her
Question did Mrs CarringtonCarrington treat JuliaJulia as
a slave. Ans JuliaJulia the plaintiff did
obey Mrs CarringtonCarrington in my presence and Mr
CarringtonCarrington called her her properly that is
She Mrs CarringtonCarrington & family was at my fathers from wednesday till
friday during which time JuliaJulia obeyed
Mrs CarringtonCarrington and did her work like any
one elses slave so far as i know
Question have you been acquainted with slavery
and know how they are treated by their
master & mistresses. Ans I have lived in a slave
state 15 or 20 years. Question do you know
of JuliaJulia washing for Mr MorrisMorris Ans I do
know that she washed for Mr Morris
State as near as you can how long Julia & Harriet
was in the Ill before they were sent to
the MissouriMissouri in the fall of of 1829Ans
I dont know exactly it might have been one month
and further the deponent saith not

Ann Bickerdike

X

mark
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I M.E. Rattau A justice of the peace in and for the county and state
aforesaid do certify that Ann Bickerdike was by me
sworn and examined on the part of the plaintiff as touching
the matter where in JuliaJulia a woman of [ coulor ]is plaintiff
and SamuelSamuel J M KinneyM Kinney Defendant and her examination
reduced to writing by me on the 18th day of April AD1824
between the hours of 8 o clock AM and 6 PM of
the same day at the court house in

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Pittsfield Pike CountyPike County Ill

M.E. Rattau J.P.

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of lawful age being produced and
sworn on the part of the plaintiff Deposeth
and sayeth Question will you state the time
as near as you can when Mrs CarringtonCarrington Came to this
county Ans Sometime in Oct (the Latter Part)
in AD1829 Question Do you know that Mrs
CarringtonCarrington [ brot ] with her JuliaJulia a woman of
Colour and her Child HarrietHarriet . Ans I do know
that She did Question Did you work for Mrs CarringtonCarrington in AD1830
if you did how long Ans One month and a half
which work was done between the first of July1830
and first of Sept1830 Question Did Mrs CarringtonCarrington
loose her Child in the time spoken of about the work
Ans She did Question. Do you know of Julias having
been at Mrs CarringtonCarrington in AD1830 and if so how
long Ans She was there But I cannot tell how
long Question was JuliaJulia at Mrs CarringtonCarrington while
the Child was sick. Ans I either saw her
at Mrs Carringtons while the child was sick or
afterwards (Question) Did you see JuliaJulia at
Mrs Carringtons in the year 1830 for 4 weeks or not. Ans
I think Not. Question Do you or not know
that JuliaJulia was at Mr Carringtons in AD1830
more than eight weeks Ans I do not
Question was or was not JuliaJulia to your Knowledge
at Mr Carringtons in AD1830 more than six
weeks. Ans, I do not know
Question Do you know that JuliaJulia was not
at Mrs Carringtons more than six weeks
in AD1830Ans I dont know that she was
there that long Question at what time do
you see JuliaJulia at Mrs CarringtonCarrington 1830
Ans I dont remember

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Ans JuliaJulia & some of the family stayed all night at my
house and in the morning word came for JuliaJulia to go
over to Mathises and spreadsome flaxthat Mrs
CarringtonCarrington had got of and she went
Question are you acquainted with Haston Wells

Ans I am
Ques what is his character as to truth and
verasityin his neighbourhood in general

AnsIt is not good so far as I know
it isnot goodbad

Question Do you recollect of Mrs CarringtonCarrington loosing her
horses shortly after she came here Ans, I did and I went and two of
the boys where I heard they were but when I got
there the horses had been there, just before, and had
left and was not found at that time

Ques How long did you understand her horses was lost
before she found them

Ans one week or ten days or about that time
Ques Are you acquainted with Nancy BrightNancy Bright , and if you
are what is her general character in relation to truth
and verasity

Ans I never heard it disputed or Doubted, untill
lately in taking Depositions in this case
now in Consideration

Ques are you acquainted with J.B.Mathis

Ans Yes

Ques Do you know that he married Mrs Carringtons
daughter the winter after she came here

Ans It is so he did and they have lived together
ever since and further the Deponent saith
not

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I M.E. Rattau a justice of the peace in and for PikePike
county and state of Ills do certify that the above
deponent was by me sworn to testify the truth in

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Question in what time did Mrs CarringtonCarrington
loose her child in AD1830 Ans I dont remem
ber in what time of the year it was. Question
was it between July and Sept1830 Ans
it was. (Question) at what time of 1831
did Mrs CarringtonCarrington send JuliaJulia to St LouisSt Louis and
sell her. Ans I dont know. Question Did
or did not Mrs CarringtonCarrington keep JuliaJulia in the
Ill till it was much talked that she
would [ loose r ] or She JuliaJulia would or had got her
freedom. Ans There was a talk of it
in 1829. Question Hpw long did Mrs CarringtonCarrington
keep JuliaJulia in the Ills in 1829Ans I
cannot tell how long. Question was JuliaJulia sick
when Brought from MissouriMissouri in 1830 and if so how
long did she remain sick Ans She so She
was, but I dont know how long she remained sick
and further the deponent saith not

Thomas Thomas K

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I M.E. Rattau a justice of the peace in and for PikePike
county and state of Ills do certify that
was by me sworn and examined on the part of the
plaintiff as touching the matter now under consideration
wherein JuliaJulia (a woman of colour) is plaintiff and
Sam J M KinneyM Kinney is defendant, and his examina
tion reduced to writing by me on the 18th day of
April between the hours of 8 AM and 6 PMof
the same day AD1834 done at the court
house in Pittsfield County & State aforesaid

M E Rattau JP

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State of Ills
CountyCounty of Pike ofCounty of Pike PikeCounty of Pike

I M.E. Rattau A justice of the
peace in and for the county of PikePike and State
of Ills do certify that the above deponents was by
me sworn to testify the whole truth of their knowledge
touching the matter in controversy between the parties

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relation to the [ mater ] in suit where in JuliaJulia a
woman of Colour is plantiff and Sam J M KinneyM Kinney
Defendant and his examination reduced to writing
by me and signed by him in my presence on the
17th day of April at the court house in Pittsfield between the hours of 8 AM
and 6 PM of the same day in AD1834

M E Rattau

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WilliamWilliam Shoell of lawful age being produced
and sworn & examined on the part of the plantiff
Deposeth and saith

Question Are you acquainted with Mrs CarringtonCarrington and if you are
how long have you been acquainted

Ans Ever since the fall of 1829 when she first
came to this state. I saw her the day after
her arrival at Philioes Ferry

Ques Did she bring with her, a woman of [ coulor ] named JuliaJulia and
HarrietHarriet her daughter

Ans she did or at least she told me so

Ques Did Julia & Harriet live with Mr CarringtonCarrington
and were they treated as slaves

Ans they were treated as slaves But Mrs CarringtonCarrington
was very kind to them, and they was subject
to her control & her Commands in my presence and
I was frequently there

Que how long did Mrs CarringtonCarrington keep them Julia & Harriet here
before she sent them to MissouriMissouri

Ans she Brought them here in Oct and some
time after sent them as I understood to
MissouriMissouri and I saw her at Mrs Carringtons
the day before christmas at Mrs Carringtons
daughters wedding and she assisted in preparing
the dinner &c and I have no doubt but that she
stays at least one month in the IllinoisIllinois before
she was sent away the first time

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Ques how long she stay the second time before
she went back; Ans I think one week at least

Ques did you see JuliaJulia working at Mrs Carringtons after
she came over from MissouriMissouri, Ans I saw her
assisting in for the wedding as before
stated

Ques Is J B Mrs Carringtons

Ans he married Mrs Carringtons daughter Minerva

Quest Where did he live in the summer and fall
of 1830 and how far from Mrs CarringtonCarrington

Ans in Morgan CountyMorgan County this state and about
12 or 15 miles distant from Mrs CarringtonCarrington

Ans Did you understand from Mrs CarringtonCarrington
when she first came to this state the
intended to settle herself in this state

Ans I did understand that she was wishing
to settle here and consequently I went with
them to show them the county as they might
make a choice

Ques was it cold weather when Mrs CarringtonCarrington
arrived and was there ice in the river

Ans the weather was not cold and no ice
in the river I with my sister cross the
river into Morgan CountyMorgan CountyIlls and stay two
or four days and recrop back again and the
river was yet clear of and the
weather not disagreeable and further the
deponent saith not

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I M E Rattau a justice of the peace in and for Pike CountyPike County
and state of Ills do hereby certify that WilliamWilliam
Scholl was by me sworn and examined on the part
of the plaintiff as touching the matter in suit
wherein JuliaJulia a woman of [ coulor ] is plaintiff
and Sam J M KinneyM Kinney is defendant and his examinat
on reduced to writing by me on the 17 day of [ Aprile ]

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aforesaid that 4 their examination were reduced
to writing by me and respectively subscribed in my
presence on the days of the 18 and 19th of april
between the hours of 8 am and 6 pm of the same
days1834 at the place and in that behalf
first aforesaid

ME Rattau

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AD1834 between the hours of 8 o clock AM and
6 PM at the Court house in Pittsfield PikePike CoIll

M E Rattau

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Nancy BrightNancy Bright of lawful age being produced and sworn
and examined on the part of the plaintiff Deposeth
and sayeth

Question are you [ accquainted ] with Mrs CarringtonCarrington
and if so how long Ans yes I have been long
before she came to this state from and
ever since she came to this county I have
seen her frequently at my house

Question Do you recollect how long Mrs CarringtonCarrington
has been in this state. Ans she came
to this county sometime in Oct D 1829
to my house, but did not unload her
furniture there but she got a Cabin of
one Mr Bennet about one mile & a half
below where I lived where she went to and
she remained there till near spring

Question Do you know that Mrs CarringtonCarrington [ Brot ]
JuliaJulia a woman of col, and HarrietHarriet her daughter
in to this state with her Ans I do know
that they came with them and was called her properly

Question Did Mrs CarringtonCarrington treat Julia & Harriet
as slaves Ans JuliaJulia went by Mrs CarringtonCarrington
orders and Mrs CarringtonCarrington told me that JuliaJulia the
Black Woman and her Daughter (Mrs CarringtonCarrington ) Minerva might work for me
for & c and they both was
in my employ and I paid Mrs CarringtonCarrington

Ques How long did Mrs CarringtonCarrington keep JuliaJulia and
HarrietHarriet in this state before she sent them
to MissouriMissouri; Ans some where near four
weeks, then I saw no more of her till near
christmas and then they took her they soJuliaJulia to MissouriMissouri

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Question Question how long did they keep Julia & Harriet
here when they was over at christmas times
Ans one week or ten days

Quest did not Mrs CarringtonCarrington tell you after her arrival that she wanted
to settle in the Ills Ans yes she told me
shedidintended to

Ques Did or did not Mrs CarringtonCarrington offer to purchase
the ferry of Mr Philips and offered this
girl JuliaJulia in payment for the same
Ans she did if JuliaJulia was willing

Question how was Mrs CarringtonCarrington in a habit of
treating JuliaJulia in KentuckyKentucky Ans about
like her own Children

Question did Mrs CarringtonCarrington hire JuliaJulia to you to work
for you Ans She did and I paid Mrs CarringtonCarrington
for the same

Question will you explain the reason why you have
been called Nancy Morris & Nancy Bright

Ans My former husband was named David
Morris and after wards in 1832 I was
married to George Bright

Question Do you recollect what the weather was
about the time that Mrs CarringtonCarrington came
to Pike CountyPike County Ill and for two weeks
afterwards Ans it was tolerable
pleasant weather and and no ice to stop the
Navigation of the river.My Daughter

Question Do you recollect of Mrs Carringtons horses
straying from her shortly after she came here
Ans yes after she moved into Bennets Cabbin

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awhile her son JosephJoseph came to our house
enquiring after them and I understood
that they found them in a few days
after wards and I saw them riding then
and further the deponent saith not

NancyNancy Bright BrightNancy Bright

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I M.E. Rattau a justice of the peace in and for the
county and state aforesaid do certify that
Nancy BrightNancy Bright was by me sworn and examined
on the part of the plaintiff as touching the
matter wherein JuliaJulia a woman of colour is
plaintiff and SamuelSamuel J. M KinneyM Kinney is defendant
and her examination reduced to writing by me
on the 17th day of Aprile1834 Between the
hours of 8 o clock AM and 6 o clock P.M. at
the court house in Pittsfield Pike CountyPike CountyIlls

M.E. Rattau

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AndrewAndrew Philips of lawful age being produced and
sworn and examined on the part of the plaintiff
deposeth and sayeth

Question Do you know when Mrs CarringtonCarrington first
came to the Ill if so state

Ans The last days of oct in the year of 1829

Ques Did or did she not bring with her JuliaJulia
a woman of colour and her Child HarrietHarriet

Ans I saw the JuliaJulia the plaintiffwith the family
after they came here and it was said that
She JuliaJulia came with them

WillWill you state how long Mrs CarringtonCarrington kept JuliaJulia
and her Child in this [ stat ] before she sent them
to MissouriMissouri the first time

Ans I cannot state any length of time precisely
but I understood that they were sent to this

before christmas and [ brot ] back again about

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Chrismas to Mrs Carringtons daughters wedding

Question Did or did not Mrs CarringtonCarrington say when she
arrived in the IllinoisIllinois that she came to settle
in the state, Ans I so understood from report that
she intended to settle in the Ills

WillWill you state as near as you can the time Mrs Carring
-ton moved into Bennetts cabbin Ans the last days
of oct 1829Question state if you please whether
or not that Mr CarringtonCarrington tried to enter your ferry
in Nov 1829. Ans I was informed on the 19th or 20thNov by my father that Mrs CarringtonCarrington son JosephJoseph
had gone over to the MorganMorgan ride to get the numbers of the landing
of my ferry and accordingly I started on to Spring
=field to enter the land and I understood that
Joseph CarringtonJoseph Carrington went as far as JacksonJackson ville
on his way to enter the said ferry but found I was
too far ahead and he turned Back home

Stat if you please how far lived from
Mrs CarringtonCarrington in the opinion & number of 1830Ans in in the spring of 1830
Mrs CarringtonCarrington moved onto the Quincy road in Pike CountyPike County and
Beny Mathis over to morgan county distant about
10 or 15 miles from Mrs CarringtonCarrington

Ques, Is or is not BenjBenjamin Mathis Mrs Carringtons son
in law - Ans it is said that he married
daughter and they do live together

Ques, state if you please NancyNancy Brights general
character as to truth and verasity
Ans as to common report I don't know of any
thing against it

Ques State if you please the general Character
of Hart, Wells for truth and verasity
Ans as to the above Question I cannot say
Question How far does Haston Wells live from you
Ans about four miles distant

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Question how long has Haston Wells lived within that
distance of you, and How long have you been
acquainted with him Ans within that distance
about 3 years, and I have been acquanted with
him partially some years before I came to this
State Question have you or not ever heard any
thing general for or againist his character for truth
and verasity Ans I cannot say

Question What is WilliamWilliam Bennetts character in his
neighborhood as to truth and verasity. Ans I do not consider
it very good and further the deponent saith not

AndrewAndrew Philips

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I M.E. Rattau a justice of the peace in and for pike county and state
of Ills do certify that AndrewAndrew Philips was by me sworn and
examined on the part of the plantiff as touching the matter
where in JuliaJulia a woman of colour is plaintiff and SamuelSamuel J. M KinneyM Kinney
is defendant and his examination reduced to writing by me
on the 18th day of aprile 1834 between the hours of
8 o clockAM and six P.M. at the court house
in PittsfieldPikePike county Ills.

M>E. Rattau JP

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Mr Mrs JaneJane Philips of lawful age being produced and
sworn and examined on the part of the plaintift
Deposeth & saith Question how long have you
been [ acquanted ] with Mrs CarringtonCarrington . Ans ever since
the fall of 1829 the 1st of Nov. Do you know
of her having with her Julia & Harriet of [ coulor ]
Ans I saw them with them were they
Mr. Carringtons slaves. Ans they was so called
Ques Do you know of Julias having worked for
Mr Ans I saw her at
washing and I saw Mrs Carringtons children come
and receive soap in pay as Mr Norrris said for washing

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State as near as you can how long JuliaJulia
and HarrietHarriet was in this state before they
were sent to MissouriMissouri Ans Sometime after
Mrs CarringtonCarrington came here in the fall I saw JuliaJulia
and HarrietHarriet going by my house it was said to MissouriMissouri
and some time about ChristmasJuliaJulia was at Mrs
Carringtons daughters wedding report said so

Question Did you seeJuliaJulia at mrs Carringtons in
1830 and if so what time in that year
Ans in the fall when Mrs CarringtonCarrington lost her
child. (Question,) Dis or did not Mr. BirdBird and
Nancy BrightNancy Bright hunt ducks together in the Ills
Bottom Ans the [ watter ] was up in
the garden at my house and Mr BirdBird shot at
a duck and Mr Norrises as was then dog seen unto the watter
after it and It[ allamed ] my child so Mr Norris
out to call her dog out of the watter so
as to pacify my child and this is all that I know
of the duck hunting and further the deponent
saith not

JaneJane his

X

mark Philips
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I M.E. Rattau A justice of the peace in and for PikePike
county and state of Ills do certify that Mrs JaneJane
Philips was by me sworn and examined on the part of the
plantiff as touching the matter in suit wherein
Julia (A woman of colour is plantiff and SamuelSamuel J
M KinneyM Kinney is dept and her examination reduced to
writing by me on the 18th day of April between the
hours of 8 AM and 6 pm of the same day
1834 at the court house in Pittsfield PikePike Co
Ills

M.E. Rattau

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JuliaJulia a woman of [ coulor ]
against
Sam J M KinneyM Kinney

Fee Bill

Plantiff Dr To M.E. Rattau J P
To fees for Taking Depositions

To ensuing 2 subpoenas 18 3/4 ea 37 1/2
To ensuing 2 attachments 18 3/4
To - - 6 1/4 43 3/4
To writing 7 depositions amounting
in all to 2 thousand word
To at 12 1/2 for every 12 - words 3. 37 1/2
To writing 8 certificates 2. 00
Justices fees - $ 6. 56 1/4
Constables for serving 7 subpoenas 87
on all 32 5 35
for
with on the same 1.10
3. 32 1/2
7 50 $ 3.50
amount in all $ 13. 38

I certify the above to be a true Bill
of costs for taking depositions as above
named on the 17th & 18th days april 1834

M.E. Rattau JP

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of Gustavus A BirdGustavus A Bird
in full of the above for Bill may 7th 1834

M E Rattau

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JuliaJulia a women of color
against
Saml. L. McKinney

Bill of
Cost
$ 13.38 3/4

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County of St. LouisCounty of St Louis, sct.

State of MissouriMissouri,

To the Sheriff of St. Louis County-Greeting.

You are hereby commnaded to summon John SimondsJohn Simonds Jr CharlesCharles Colhors
Wm. Risley JosephJoseph Zabor
that setting aside all manner of excuse and delay,t he be and appear in proper person
before the judge of our Circuit CourtCircuit Court ,forthwith
at the city of St. LouisSt Louis, then there to testify and
the truth to say in a certain matter of controversy now pending in our said Court,
wherein JuliaJulia is plaintiff and
Saml Mc Kinney defendant on the
part of the plaintiff and have you then there this writ.

[missing figure]

Witness, Archibald GambleArchibald Gamble , Clerk of our said Circuit CourtCircuit Court , at the
City of St. LouisCity of St Louis, this 26th day of Apl an the year of our Lord one thosuand eight hundred and thirty four

Archibald GambleArchibald Gamble

Clerk C.C.
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March Term 1834
JuliaJulia a woman of color
vs
Saml Mc Kinney

For plff

John Sim and 25

Chas Collens

25

Wm Risley

25

JosephJoseph Tabon

25forthwith
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Executed this writ on John SimondsJohn Simonds Jr
on Charles CollinsCharles Collins & on Wm Risley & on
JosephJoseph Talor by reading it to them in
the county of St LouisSt Louis the 25 April in 1834

JK WalkerWalker sheriff

Servis $ 2.00
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[missing figure]

County of St. LouisCounty of St Louis, sct.

State of MissouriMissouri,

To the Sheriff of St. Louis County-Greeting.

You are hereby commanded to summon Silas Drake &
Joseph Labor that setting aside all manner of excuse and delay, they be and appear in proper person
before the Judge our our Circuit CourtCircuit Court , on the forthwith
at the City of St. LouisCity of St Louis, then and there to testify and
the truth to say in certain matter of controversy now pending in our said Court, wherein JulieJulie is plaintiff and
SamuelSamuel McKeriney defendant on the
part of plaintiff and have you then there this writ.

[missing figure]
Witness, Archibald GambleArchibald Gamble , Clerk of our said Circuit CourtCircuit Court , at the
City of St. LouisCity of St Louis, this first day of May in the year of our Lord one thousand eight hundred and thirty four

A GambleArchibald Gamble

Clerk C.C.
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[missing figure]
JulieJulie
vs
Wm. Keriney

for

Silas Drake


Joseph Labor


forthwith


for plaintiff
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[missing figure]

this writ on Silas
Drake and for When on the
1st May1884
from St. LouisSt Louis.


for $ 1,00
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[missing figure]

County of St. LouisCounty of St Louis, Sct.

State of MissouriMissouri,

To the Sheriff of St. Louis County-greeting.

You are hereby commanded to summon JamesJames P Spencer PJames P Spencer SpencerJames P Spencer Henry FrancisHenry Francis that setting aside all manner of excuse and delay, he be and appear in proper person
before the Judge of our Circuit CourtCircuit Court ,forthwith
at the City of St. LouisCity of St Louis, then and there to testify and
the truth to say in a certain matter of controversy now pending in our said Court,
wherein JuliaJulia is plaintiff and
SamuelSamuel T McKeriney is defendant on the
part of the plaintiff and have you then there this writ.

[missing figure]
Witness, Archibald GambleArchibald Gamble , Clerk of our said Circuit CourtCircuit Court , at the
City of St. LouisCity of St Louis, this 1st day of May in the year of our one thousand eight hundred and thirty four

AArchibald Gamble GambleArchibald Gamble

Clerk C.C.
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[missing figure]
March Term 1834
JuliaJulia
vs
ST McKenney

for the plff

JamesJames P Spencer P SpencerJames P Spencer


HenryHenry Francis FrancisHenry Francis

forthwith
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[missing figure]

Executed this writ on James PJames P Spencer . SpencerJames P Spencer
by reading it to him in St. Louis CountyMay 2nd 1834Henry FrancisHenry Francis not found in my county

John


by

John K WalkerJohn K Walker Shff
by IsaacIsaac

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[missing figure]

Service 50
62 1/2

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JuliaJulia a woman of colour
vs
SamuelSamuel McKensey

The plaintiff moves the court
and grant a new trial to the case

1 Because the courtthe jury

2 Because the jury found contrary to the evidence

3 Because they found contrary to the of evidence


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JuliaJulia a woman of color
vs
Sammul Me KenneyKinney

reasons for New Trial

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[missing figure]

1 That if the jury believe from the evidence that the plaintiff
JuliaJulia was taken into the State ofIllinois IllinoisIllinois by her owner with-
out any intention on the part of such owner to make
the State ofIllinois IllinoisIllinois the residence of said
JuliaJulia that the plaintiff is not entitled by such remov-
al into that State to recover in this action

2 That the taking of the plaintiff into the State ofIllinois IllinoisIllinois
by her owner
for the purpose of curing her of
sickness and with the intention of returning herinto MissouriMissouri when she should be recovered of such
illness does not entitle her to recover in this action

3 That the plaintiff is not entitled in this case according to the
evidence to recover her freedom under the 2nd section of the 6th
article of the constitution of the State ofIllinois IllinoisIllinois

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1 and 2 Instructions given
by the court in the
case of
JuliaJulia vsMc Kinney

No 1

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[missing figure]
To instruction given by the court in case of
JuliaJulia vsMcKinneyMcKinney

No 2

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[missing figure]

State of IllinoisIllinoisCounty Ss

The depositions of Lenard, WilliamWilliam
and HenryHenry J., of the County and State aforesaid, witnesses pro-
duced, sworn and examined, before JamesJames , a Justice
of the Peace, in, and for the said County and State, who met on the
twenty fifth day of July, at the office of the clerk of the
Court in , in the County and State aforesaid, but not being
able to complete them on that day. the further taking of said deposi-
tions, was adjourned to the next day at nine o'clock in the
forenoon at the same place, at which time and place the said
depositions were completed as herewith enclosed, and were taken
in , out of, and under the
seal of the Circuit Court of the county of St. LouisSt Louis, and State of MissouriMissouri, bearing
date on the third day of June in the year of our Lord one thousand eight hundred and thirty one, to the said Justice directed, to be used as evidenceof a
certain suit at common law, now pending and undetermined in the said
Circuit Court of the said CountyCounty of St Louis ofCounty of St Louis St. LouisCounty of St Louis. Wherein JuliaJulia a woman of colour
is Plaintiff and SamuelSamuel McKinneyMcKinney is defendant, on the part of the Plaintiff
the said Lenard and WilliamWilliam and HenryHenry J., being first July
sworn according to law, did and say as follows.

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[missing figure]

We the Jury find for the
plantiff