Mary Farnham vs. Samuel D. Walker
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To the Honorable LukeLuke E Lawless . Edward LawlessLuke E Lawless , Judge of the third
Judicial Circuit in the State of MissouriMissouri,

The petition of MaryMary FarnhamFarnham , aged about 21 or
22 years of age respectfully represents: That she was
born in Ste Genevive, in this state in the family of one JohnJohn B
BJohn B . Bossier, and that she was held as a slave by him
until some time in 1830 â when she was brought
to St. LouisSt Louis by said Bossier, and sold as a slave
to one Russel Farnham, who held her as slave
in his own family in St. LouisSt Louis, & that said FarnhamFarnham shortly
after buying her moved with his family to the Lower
Rapids on the Mississippi RiverMississippi River, where he resided
& where your petitioner was held as a slave,
in his family and at fort EdwardsEdwards for more
than from the fall of 1831 until about the
fall of 1832 Your Petitioner is informed and believes
that having been held as a slave at those places
in beyond the northern boundary of the state of
MissouriMissouri & the other, in the state of IllinoisIllinois with said
FarnhamFarnham , who had his permanent residence there
then, she is now entitled to her freedom.
Your petitioner states that said FarnhamFarnham came to St LouisSt Louis
and did here in october 1832. That since said Farnham's
death she has been sold as a slave by P. Chouteau JrChouteau Jr ,
as administrator of said FarnhamFarnham to one RandolphRandolph
in St. LouisSt Louis; who sold your petitioner, as a slave to
one SamuelSamuel D. Walker, who now holds your petitioner as
a slave in St. LouisSt Louis, said WalkerWalker , being a resident of
LouisianaLouisiana, & having recently Come to St. LouisSt Louis; Your petition
-er therefore, prays your honor to be permitted to institute a
suit as provided for by law, & that your petitioner be permitted
to sue as a poor person; &c & as in duty bound your
petitioner will ever pray âc.

St. LouisSt Louis
May 25th 1835>

MaryMary FarnhamFarnham by
her atto: I F. Darby

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MaryMary Farnham being duly Sworn upon her oath
States that the facts stated in the foregoing petition are
true to the best of her Knowledge & belief

Sworn to & subscribed before
me

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John F. DarbyJohn F Darby being duly sworn upon his oath, states that he believes
the facts stated in the foregoing petition of mary FarnhamFarnham are true-
avers as he is informed said mary FarnhamFarnham is permitted by the persons
claming her is a slave, from comand & swearing to the affidavit said above written

Sworn to and subscribed before me this 25th May 1835

Archibald GambleArchibald Gamble Clerk

John F DarbyJohn F Darby

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I L. E. LawlessL E Lawless , Judge of the third Judicial circuit
do hereby order that said petitioner mary FarnhamFarnham ,
be permitted to institute a suit to establish her right to
freedom against SamuelSamuel D. Walker & that she be permitted
to sue as a poor person, and as I assign her as
Counsel â to conduct & manage said
suit - St LouisSt LouisMay 1835 and it is
further ordered, that the petitioner havereasonable liberty to
attend her counsel and the Court whoen occasion may
require; and that the petitioner shall not be taken or removed
out of the jurisdiction of the court, nor be subject to
any severity because of her application for freedom.

L E LawlessL E Lawless

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State of MissouriMissouri,
Third Judicial Circuit
Ss.

In St. LouisSt Louis circuit court.
July Term 1835

MaryMary FarnhamFarnham , who is permitted to
sue as a poor person, by DarbyDarby her attorney Com-
plains of SamuelSamuel . D. Walker, of a plea of trespass

For that whereas, heretofore to wit, on the twenty third day of may in the year of our Lord eighteen hundred and thirty five said defendant at
the county aforesaid with force and arms made
an assault upon the said defendant at St. LouisSt Louis in

in the county aforesaid there and then beat bruised and illtreated
said plaintiff,
and then and there
imprisoned the said plaintiff, and kept and detained
her in prison, there, without any reasonable or probable cause
whatsoever for a long space of time, to wit for the space
of two days, there next following, contrary to the laws of
the land, and against her will, and the said plaintiff
avers, that before and at the time of the committing the grievances
she was and still is a free person, and that the defendant
held and detained her & still holds and detains her,
in slavery. To the damage of said plaintiff of Eight
Hundred Dollars.

DarbyDarby p. q.

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County of Saint LouisCounty of Saint Louis Ss
The state of MissouriMissouri

To the Sheriff of the County of Saint LouisCounty of Saint Louis
Greeting

We command you to summon SamuelSamuel D Walker that he be and appear before the
Judge of our Circuit CourtCircuit 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
mary FarnhamFarnham who is permitted to sue as a poor person of a plea of Trespass To the damage of
said plaintiff of Eight 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 Twenty fifth day of May in the Year of our Lord one thousand Eight Hundred and thirty five

Archibald GambleArchibald Gamble Clerk

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I L. E LawlessL E Lawless Judge of the third Judicial circuit do hereby order that said petitioner mary FarnhamFarnham be permitted to institute a suit
to establish her right to freedom against SamuelSamuel D Walker and that she be permitted to sue as a poor person and I assign her as counsel
to conduct and arrange said suit and it is further ordered that the petitioner have reasonable liberty to attend her counsel and the
court when occasion may require and that the petitioner shall not be taken or removed out of the juridiction of the court nor be subject to any
severity because of her application for freedom L. E LawlessL E Lawless -
A True Copy of the order of the Judge_ Archibald GambleArchibald Gamble Clerk

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SamuelSamuel D Walker not found in my County
June 27th 1835

J BrothertonJames Brotherton Shff
by G Hammand Dept

nonest 50 cts
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No 48

In St Louis Circuit CourtCircuit Court
July Term 1835

MaryMary FarnhamFarnham
vs
SamuelSamuel D. Walker

This an action in form of
assault & Battery & false
imprisonment â

Issue a writ for deft.

DarbyDarby p. q.

Filed 25th May 1835

Archibald GambleArchibald Gamble Clerk

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Discontinued Book 7 page 410