Jane, a woman of color v. William Dallum
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The Negro woman JennyJenny in the possession of
Majr. WilliamWilliam confined in the Jail.
of the CountyCounty of St Louis of St. LouisCounty of St Louis. Lived for ten or twelve
years in the Town of Russellville Logan County
KentuckyKentucky. where there resided. She lived to hereof kept
House and was known by the name of free JennyJenny .
She was considered as a free woman I always under
-stood she had been emancipated by her master the
Richard Dec'd or his sonIt was
an established rule with to liberate
all his slaves at a certain age. at which age of
understood JennyJenny was emancipated.
was alive at the time JennyJenny had her own time,
and was exercising the priveleges of a free person.

G. N. Call


Sworn to & subscribed
16th day of April Before

J C Garner JP

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To the Circuit CourtCircuit Court for the CountyCounty of St Louis ofCounty of St Louis St. LouisCounty of St Louis.

This petition of JaneJane , a woman of colour, re
-presents to this honorable count, that she, as she believes,
is entitled to her freedom on the following grounds: she
was formerly the slave of Col.Dallam, of MarylandMaryland, and
by him taken to the State ofKentucky KentuckyKentucky, where she resided within a few years since; that before her said
master removed her he informed her that he had man-
her, such manumission to take effect at a
future nine, and she believes that said manumission
was by deed and that the deed is now of record in the
proper office in MarylandMaryland, where it can be obtained. She
also states that some time after her in KentuckyKentucky.
She was by her said master actually freed and discharged
from all service and obedience, he giving her complete
and perfect personal liberty and power to do with her-
self what she pleased and requiring from her neither
services nor wages for her time. That from that time
until the time of her master's death, a period of from
ten to fifteen years, the She lived as a free person, with
the consent of her master as aforesaid and in the same
town or neighborhood with him. That she was brought
to St. louis byWilliamWilliam DallamDallam a son of her said master, who afterwards went to KentuckyKentucky, and that she is now claimed by
him as his slave, and restrained of her liberty and at
this time confined in jail by the order of a certain
Munday, who she believes acts asthe agent

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of the said WilliamWilliam DallamDallam . The said JaneJane also states
that she is confident that if she shall be allowed to
institute suit for her freedom as a poor person that
she will be able to establish her right thereto by
legal evidence, and she therefore prays that she may
be allowed to sue as a a poor person and that their
honorable Court will assign her counsel to
prosecute her suit for her. And she will ever pray &c
Jane

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Jane
Petition to sue for freedom.

Filed April 15th 1831

A GambleArchibald Gamble
Clk

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St. LouisSt Louis, to wit

Third Judicial Circuit


In the CircuitCircuit Court CourtCircuit Court , July Term 1831.

JaneJane , a woman of color, by MurrayMurray , assigned to her by the
Court as attorney, complains of WilliamWilliam DallamDallam in a plea
of trespass. For that whereas the said WilliamWilliam on the first day of July in the year eighteen hundred and twenty nine
with force and arms made an assault upon the said
JaneJane , to wit at the County of St. LouisCounty of St Louis aforesaid and then
and there beat, bruised, wounded and ill treated the said
JaneJane , and then and there imprisoned the said JaneJane and
kept and detained her in prison there, without any
reasonable or probable excuse whatever, for a long
time, to wit, from that time aforesaid until the
time of the beginning of the suit. And he said JaneJane avers
that before and at the time of the committing of the grie-
vances above stated and set forth she was a free per-
son, and she avers that she still is a free person and
that the said WilliamWilliam DallamDallam at and before the said
time held and detained her, said JaneJane , and still does
hold and detain her, said JaneJane ,in slavery and other
wrongs to the saidJaneJane , the said WilliamWilliam then and
there did, against the peace of the state of MissouriMissouri
and to the damage of the said JaneJane in the sum of
five hundred dollars, and therefor she sues.

Jas. L. Murray
atty. for plff.

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The defendant not found in my county9th July 1831

John KJohn K . Waler Shff

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No 22

StLouisSt Louis Circuit CourtCircuit Court
July Term 1831

JaneJane , woman of color
vs
WilliamWilliam DallamDallam

Suit for Freedom
Trespass
The clerk will please issue
summons.

MurrayMurray


Filed

10th May 1831


Archibald GambleArchibald Gamble

Clerk
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County of Saint LouisCounty of Saint Louis

so

The State of MissouriMissouri

To the Sheriff of the county of Saint LouisSt Louis Greeting

We command you to summon WilliamWilliam DallamDallam that he be and
appear before the Judge of our circuit court at the next July 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 July next then and there to answer unto JaneJane
a woman of color in a plea of trespass to the damage of the said plaintiff
in the sum of Five Hundred dollars and have you then there this writ

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Witness Archibald GambleArchibald Gamble Clerk of our said
CircuitCircuit Court CourtCircuit Court at office this Tenth day of May in the year one thousand Eight Hundred and thirty one

Archibald GambleArchibald Gamble Clerk

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County of Saint LouisCounty of Saint Louis

so

The State of MissouriMissouri

To the sheriff of the county of Saint LouisSt Louis Greeting

We command you as we have heretofore commanded you to summmon WilliamWilliam DallamDallam
that he be and appear before the Judge of our Circuit CourtCircuit Court at the next November term
thereof to be held of the city of St LouisSt Louis within and for the county of Saint LouisSt Louis on the
Fourth Monday of November next then and there to answer unto JaneJane a woman of
color in a plea of trespass to the damage of the said plaintiff in the sum of Five Hundred dollars and have you then there this writ.

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Witness Archibald GambleArchibald Gamble Clerk of our said Circuit CourtCircuit Court at
office this Twenty third day of September in the year one thousand Eight Hundred and thirty one

Archibald GambleArchibald Gamble Clerk

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No 22

Saint Louis Circuit CourtCircuit Court July Term 1831

JaneJane a woman of color
vs
WilliamWilliam DallamDallam

alias WillWill toNov 1831

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WilliamWilliam DallamDallam not found in my country 12th Nov 1831

John K WalkerJohn K Walker Shff


50cts
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StateMissouri ofMissouri MissouriMissouri

Sct

At Circuit CourtCircuit Court be and held at the CityCity of St Louis ofCity of St Louis St LouisCity of St Louis within and for the the CountyCounty of Saint Louis ofCounty of Saint Louis Saint LouisCounty of Saint Louis in the third Judicial Cicuit of the StateMissouri ofMissouri MissouriMissouri
on the fourth monday of March being the twenty
eighth day of said month in the Year of our
Lord one eight hundred and thirty one
were present the Honorable WilliamWilliam C. CarrCarr
Judge of the third Judicial Circuit of the StateMissouri ofMissouri
MissouriMissouriJohn K. WalkerJohn K Walker Esquire Sheriff of the
CountyCounty of Saint Louis ofCounty of Saint Louis Saint LouisCounty of Saint Louis and Archibald GambleArchibald Gamble Clerk

Friday 15th of April 1831

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JaneJane
vs
WilliamWilliam DallamDallam
Friday 15th of April 1831

James L Murray Esquire
presents to the Court the petiti-
on of JaneJane a woman of color praying that she may be permitted to institute
suit against WilliamWilliam DallamDallam for establishing her
right to freedom and that she may be permitted
to sue as a poor person. thereupon the Court perm-
itted the said JaneJane to sue as aforesaid an direct
that an action of assault and Battery and false
imprisonment be brought in the name of the said
JaneJane and assign the said James L. murray as her
counsel and it is ordered by the Court that the said
WilliamWilliam DallamDallam permit the said JaneJane to have reas-
onable liberty of attending her counsel and the
Court when occasion may require it and that the
said petitioner shall not be taken or removed out
of the Jurisdiction of this Court or to be subject to any
severity of treatment on account of her said applic-
ation for freedom
The foregoing is a true Copy
of the Orders of the St Louis Circuit CourtCircuit Court
made at the March Term thereof 1831

Archibald GambleArchibald Gamble Clerk

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Russellville Ky
Apl 3.

James L Murray Esqr.
atty at law St. LouisSt Louis

Missouri_

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Dear Sir,

A few days since Mr. E.M. Ewing
placed in my hands a letter addressed to
him by you and the subject of the right
to freedom of Jane & Charlotte by virtue
of Deed of Manumition from Col
Richd. Dallam. He knowing that I hav-
ing been employed here to procure the
liberation of some negroes of the same
formerly referred your request for informed
to me. I have since your letter was
laid before me seen one of the men
whose freedom I have by suit obtained
here & he informs me that JaneJane is
the daughter of Peg. CharlotteCharlotte is the daugh-
ter of PhillisPhillis . Upon examining a copy of
the Deed of Manumition made by Col.
Richd Dallam of slaves in the State
of MarylandMaryland in the year 1787. I find
that PhillisPhillis & Peg were among the slaves
so set free & their increase. I immagine
there can be no doubt Jane & Charlotte
have a right to their liberty. I have
here for my own use as certified copy
of Deed & several suits depending for
the recovery of several of the same
family or I would forward it to you
I have also recently procured from MaryMary

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=land a copy of the law of that state (at the time of the Execution of the Deed)
certified under the great seal of that state
This I should be happy to furnish you also but
cannot now. It would be very practicable
for you to obtain a copy of the Deed by
addressing a letter to J. D. atty at
law, Bell_air Harford Cty. MarylandMaryland and
also a copy of the whole law of that state
covering these cases by addressing JamesJames atty at law at Anapolis MarylandMaryland. The
necessity of the production of this law will you know be put in issue by any proper
defence of yoursuit.
There is a number of other negroes taken
to Mi_ by Richd. B Dallam & J. who are
alike entitled to thier freedom Viz
WilliamWilliam , MillyMilly , Grace, MatildaMatilda , Lernon, AndrewAndrew
& Abm most of which females have chil
-dren but their names are not now here
known. I have taken some pains to in-
vestigate the title of these unfortunate
people to theirfreedom & entertain no doubt
of their right. If aid should become necessary
from this country I should be
perfectly willing to contribute & charge no
unreasonable fees. Yours with due res
pect & .

Thos. M. Smith


Jas L. Murray Esqur.