Tenor Washington v. Henry Scott and John Emerson
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To the Honorable the Circuit Court of the County of St LouisCounty of St Louis

Your Petitioner Tenor WashingtonWashington
a woman of Color respectfully presents that she
was born a slave that in the year 1830 she was
in the possession of and belonged to one CajabalCajabal Gill GillCajabal Gill
who some time in that year sold and disposed of
her to one JeremiahJeremiah Johnston JohnstonJeremiah Johnston who after purcha-
sing her took her with him to Lebanon in
the state of IllinoisIllinois his place of residence where
he kept her in a state of servitude for about
one year after which period she was transferred
to the possession of Henry ScottHenry Scott and brought
to the city of St LouisSt Louis in the State of MissouriMissouri
that said is the step son of said Johnston
and now claims her as his property. And your
petitioner prays that she may be permitted to
bring a suit as a poor person against said
ScottScott for the purpose of trying her right to feedom.

Tenor WashingtonWashington

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State of MissouriMissouri
County of St LouisCounty of St Louis Ss

Before me Archibald GambleArchibald Gamble Clerk
of the Circuit CourtCircuit Court for said County personally
appeared WilliamWilliam Mull a free white male
over the age of twenty one years of age and made
oath that he knows the above petitioner
that he knew her when in the possession of
CajabalCajabal Gill GillCajabal Gill above named who before selling
her to said JeremiahJeremiah Johnston JohnstonJeremiah Johnston offered to dispose
of her to this affiant who declined purchasing her
at the price he asked that he knew of her be-
ing afterwards in the possession of said Johnston
who as he understood had bought her and that
she lived as this affiant believes in a state
of servitude with said Johnstorn for twelve months

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at Lebanon in the State of IllinoisIllinois

sworn to & subscribed this
14 August 1832

Archibald GambleArchibald Gamble Clerk

Wm

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Tenor WashingtonWashington
vs
Henry ScottHenry Scott

Petition to sue in
form a pauperis

filed Augst 15th 1832

A GambleArchibald Gamble Clk

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Tenor WashingtonWashington
vs
HenryHenry

Before me Archibald GambleArchibald Gamble Clerk of
the Circuit Court of said County personally appeared
WilliamWilliam Mull and made oath that he knows
the plaintiff in the above cause and has known
her for some time that said plaintiff was the
property of a man named CajabalCajabal Gill GillCajabal Gill who
at one time offered to sell her to this affiant
that afterwards as affiant has been informed &
believes said Gill sold her to one JeremiahJeremiah Johnston
JohnstonJeremiah Johnston with whom as affiant knows she resided
for one year in the State of IllinoisIllinois of which
said Johnston is a Citizen. That said plaintiff
has for some time back resided in the family
of affiant that this affiant at her request
has endeavored to ascertain the place of abode
of said Gill for the purpose of procuring his testimony
in this cause that in the month of May
last affiant wrote to KentuckyKentucky making inquiry
about said Gill, that it has not been until
within a few days back that affiant has ascertained
that said Gill resides at present in Carrolston
IllinoisIllinois. That the plaintiff is an ignorant person
incapable of managing her suit or taking the necessary
steps to prepare for trial and relied upon
affiant to aid her in that behalf that affiant
was obliged to be absent in the State of IllinoisIllinois
on business and was necessarily absent this day
when the case was called for trial. That affiant
believes the deposition of said Gill can be procured
at the next Term of this Court. This affiant
further states that since the nonsuit taken
in this suit to day said ScottScott came to the house
of affiant and told said plaintiff that the case
having now been decided he would not give
her another chance but would send her

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down the forthwith which this affiant
believes said ScottScott will do unless restrained by
this court.

Sworn to & subscribed
this 13 August 1832

A GambleArchibald Gamble Clerk

Wm. Mull

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Tenor WashingtonWashington
vs
Henry ScottHenry Scott

affidavit of
Wm. Mill

filed
Augst 15th 1832

A GambleArchibald Gamble Clk

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No 18

Saint Louis Circuit CourtCircuit Court
November Term 1832

Tenor WashingtonWashington
vs
Henry ScottHenry Scott & Jn. Emerson

Action of Trespass
Suit for freedom

Filed 16th August 1832

Archibald GambleArchibald Gamble Clerk

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Judgment by Default 1 cent Damages Book 6 page 448

Archd GambleArchibald Gamble Clerk

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State of MissouriMissouri
County of St. LouisCounty of St Louis
ss.
In the Circuit CourtCircuit Court
November Term 1832

Tenor WashingtonWashington a woman of color
by her attorney complains of Henry ScottHenry Scott and John
Emerson of a plea of trespass for that on the first day of August in the year Eighteen hundred and thirty two
at the County aforesaid and before, and at the time
of the committing of the grievances hereinafter mentioned
the said Tenor was and still is a free person and
the said defendants with force and arms on the day
and year last aforesaid at the County aforesaid an assault
on her the said Tenor then and there did make
and her the said Tenor then and there did beat, strike
wound and illtreat and her the said Tenor then and
there did confine and imprison for a long space of
time to wit for the space of twelve hours and other
wrongs to the said Tenor then and there did to the great
injury of the said Tenor and said Tenor in fact saith that
the said defendants then and there held and detained
and do still hold and detain her in slavery and
the said Tenor saith that she is injured and hath
sustained damage to the amount of three hundred
dollars and therefore she sues &c.


Attorney for pltff

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County of Saint LouisCounty of Saint Louis ss
The State of MissouriMissouri

To the Sheriff of the county of Saint LouisSt Louis Greeting

We command you to summon Henry ScottHenry Scott and John Emmerson that they be
and appear before the Judge of our Circuit CourtCircuit Court at the next November term
thereof to be held at the city of Saint LouisSt Louis within and for the county of SaintSt Louis
LouisSt Louis on the fourth Monday of November next then and there to answer unto
Tenor WashingtonWashington of a plea of Trespass to the damage of the said plaintiff of
Three 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 Sixteenth day of August One thousand Eight Hundred and thirty two

Archibald GambleArchibald Gamble Clerk

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Executed this writ by reading it & the declaration
to Henry ScottHenry Scott & offering to read it & the declaration
to John Emerson which he refused to hear saying
he would ahve nothing to do with the matter
turned his back and walked off after I had
commanced reading to him the declaration
Executed as above stated in the city of St LouisSt Louis
on the 16th day of August 1832

JohnJohn K Walker KJohn K Walker WalkerJohn K Walker shff
by JJames Brotherton BrothertonJames Brotherton

Service $ 200