William StubsWilliam Stubs a man of color represents
that he was born of free parents in the
county of CampbellCampbell in the state of VirginiaVirginia
and that by the laws of VirginiaVirginia his mother
being free it his birth he was bornfree and
is now entitled to his freedom and he futher
states that being bornfreeand entitled to his
freedomsuesWilliamWilliam who then resided
in the said county of CampbellCampbell
to emigrate to the state of MissouriMissouri
your petitioner to accompany the said
WilliamWilliam Bard to the city of St LouisSt Louis That about
four years since with the said
Bard in the city of St LouisSt Louis & that the said
Bard for that to this has resided in the
city of St LouisSt Louis and and held your
petitioner in slavery your petitioner therefore

prays that your honor will grant him
tosue as a poor person in order to establish
his right to freedom and that your honor
shall order as the state a such
to his during the of
said suit

This day the petitioner personally offers
before word being first duly sworn and much
with by it
tosue made oath that the facts contained and
stated in the said petition are true to the
best of his knowledge and belief

The within named petitioner is allowed to
sue as a poor person, for the purpose
of establishing his freedom, and
I do hereby assign Geo FStrother as his Counsel
and that the petitioner have reasonable liberty
to attend Counsel and the Court, that he be
not removed out of the jurisdiction of this state
Court and that he be not subject to any
severity on account of his application for
freedom

WilliamWilliam Stubs StubsWilliam Stubs
vs
WilliamWilliam Bard

Petitioner for to
suit to establish
right to freedom

St Louis County to wit WilliamWilliam Stubs StubsWilliam Stubs com
plains of WilliamWilliam Bard of a
For that the said WilliamWilliam Bard on the
first day of January in the year one thousand eight hundred and thirty seven with force
and arms made an assault upon the said WilliamWilliam Stubs
StubsWilliam Stubs to wit at the county of St LouisSt Louis and
then and there imprisoned the said Willi
am Stubs and kept and detained him in person
there without any reasonable cause or whatsoever
for a long space of time to wit for the space
of three months the cost following contrary to the
laws of that state and against the will of the
said William StubsWilliam Stubs and the said WilliamWilliam Stubs
StubsWilliam Stubs was that before and at the time of the
committing the said grievances he was and still
is a free person and that the said WilliamWilliam
Bard held and still holds him in slavery and
other wrongs to the said William StubsWilliam Stubs there
and then did against the peace of this state
and to the damage of the said William StubsWilliam Stubs
thousand dollars and therefore he prays

``The within named petitioner is allowed to sue as a poor person of establishing his freedom, and I do hereby asign
George F StrotherGeorge F Strother as his counsel, and that the petitioner have reasonable liberty to attend counsel and the court, that he be not
removed out of the jurisdiction of this court and that he be not subject to any severity on account of his application for free
dom. LL E Lawless .EL E Lawless .LawlessL E Lawless JeCt.Ct.6th June 1837.''

We command you to summon William BurdWilliam Burd , if he be found in your county to appear
before our Honorable Circuit CourtCircuit Court on the first day of the next term thereof to be begun and held
at the city of St LouisSt Louis within and for the county aforesaid on the second Monday of July next
then and there to answer unto William StubsWilliam Stubs of a plea of trespass on the case, to the damage of
said plaintiff of one thousand dollars, and have you then there this writ.

Excuted this writ on the 7th day of June 1837 in the County ofCounty of St Louis
St LouisCounty of St Louis by reading it & the order & by offering to read the petition affidavit
& declaration to William BurdWilliam Burd the defendant who refused to
hear them read and acknowledged the service thereof

WilliamWilliam Stubs StubsWilliam Stubs
vs
William BurdWilliam Burd

This is an of his
false imprisonment
not bought by
of the judge to establish
right to freedom the
clerk will

And the said defendant by GambleArchibald Gamble his attorney
comes and defends the force and injury when and says he
is not guilty of the said supposed wrongs and injuries
above laid to his charge in manner and form as the said
plaintiff hath above thereof complained against him
and of this he puts himself upon the country

And for further plea in this behalf the said defendant
says that the said plaintiff ought not to have or main

tain his aforesaid action against him because he says
that at the time of the committing of the grievancestres
pass in the declaration mentioned he the said plaintiff
was a slave without that that at the said time the
said plaintiff was a free person as he has in his said
declaration alledged and this the said defendant is ready
to verify wherefore he prays judgment &

WilliamWilliam Stubs StubsWilliam Stubs
vs
William BurdWilliam Burd
pleas
Not guilty

Pleas with & Judgt by nildecitbook 8 page 417

The petition of William StubsWilliam Stubs and
LewisStubbs would respectfully represent to
your Hon that they are about to be removed
out of the Jurisdiction of this Court, Your
petitioners would further state that since their
suits for freedom has been instituted that
they have been removed out of the jurisdiction
of this Court and they verily believe that they
will be again removed beyond the jurisdiction
of your Hon Court unless Your Hon
will interfere and lend the aid of Your Hon
for their Your petitioners therefore
pray that they may be brought before
your Hon and hired out as directed
by the laws of the state and as in
duty bound they will ever, pray

WilliamWilliam Stubs StubsWilliam Stubs &
Lewis Stubs
vs Petition
WilliamWilliam Burd

BurdWilliam Burd