Saint LouisSt Louis County ss HarrietHarriet an infant under twenty one years
of age by G AG A Bird BirdG A Bird , her next friend complains of
SamuelSamuel T M KinneyT M Kinney of a plea of trespass assault
& Battery & false imprisonment for that heretofore
to wit on the first day of May 1831 at St LouisSt Louis
in County the said Defendant with
force & arms & assault did make upon the said
plaintiff & her the said plaintiff did then &
there beatbruise & illtreat & her the said
plaintiff then & there imprison any
legal reasonable on probable cause & kept
detained her imprison therefore a long
of time from the day last aforesaid
untill this time & other wrongs then & there did
against the peace & dignity of the State aforesaid
and said plaintiff says that before & at the
time of the committing the said severalgrievances
the said plaintiff was & still is as free person and that
the said defendant held & detained & still
holds detains said plaintiff in slavery
By means of which premises the said plaintiff
says she has sustained Damage to three
hundred Dollars & therefore she sues

Served this writ on SamuelSamuel S.
M KinneyM Kinney by offering to read
it & the declaration to him on the
2nd day of July 1833 in the city of
St LouisSt Louis which he refused to
hear read

HarrietHarriet by GA Brid
her next friend
vs
SamuelSamuel T M KinneyT M Kinney

Declaration in
trespass assault & battery
& false imprisonment
& for

Damages $ 300

We command you to summon SamuelSamuel
T M KinneyT M Kinney that he be and appear before
the Judge of our Circuit CourtCircuit Court at the term Term
thereof to be held at the city of S LouisS Louis within
and for the County of S LouisCounty of S Louis on the fourth
Monday of July next then and there to answer
HarrietHarriet an infant under twenty one years of
age (by GustavusGustavus A Bird A BirdGustavus A Bird ) of a plea of trespass
assault and battery and false imprisonment
to the damage of said plaintiff of three hundred
dollars and have you then there this writ

And the said Defendant SamuelSamuel by
GambleArchibald Gamble his attorney comes and defends the force
and injury when &c and says he is not guilty
of the said wrongs and injuries in the declaration
set forth in manner and form as the said
plaintiff hath above thereof complained
against him and of this he puts himself
upon the County

death of S.T.M Kinney P. LucindaCarringtonCarrington enters appearance as defendant sub to court & Judgt
for 1cent damages Book 7 page 482

HarrietHarriet
vs
Samuel T Mc KinneySamuel T Mc Kinney

plea not guilty

The Deft excepts to the depositions of NancyNancy Bright
BrightNancy Bright and WilliamWilliam Scholle filed in this case

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

2d Because the depositions were not taken in pursuance of the notice given

3d That the depositions are not properly certified

HarriettHarriett
vs
Mc Kinney

Exceptions to Depositions