William Stubs, a man of color v. William Bard
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To the Honorable LukeLuke E Lawless ELuke E Lawless LawlessLuke E Lawless Judge
of the CircuitCourt of the county of StSt Louis LouisSt Louis

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

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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

WilliamWilliam his mark Stubs

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St LouisSt Louis county to wit

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

Sworn to and subscribed
before me this 5th June AD 1837

J W WalshW Walsh Justice

WilliamWilliam his mark

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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

6 June 1837

L EL E Lawless LawlessL E Lawless

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WilliamWilliam Stubs StubsWilliam Stubs
vs
WilliamWilliam Bard

Petitioner for to
suit to establish
right to freedom

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St Louis Circuit CourtCircuit Court July term 1837

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

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``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.''

A true copy of the order endorsed upon the petition

AttestJohn RulandJohn Ruland Clerk C.C.

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County of St LouisCounty of St Louis Ss
The State of MissouriMissouri

To the Sheriff of the county of St LouisSt Louis
Greeting:

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.

Witness John RulandJohn Ruland , Clerk of our said court with
the seal thereof hereto affixed at office in the city of
St LouisSt Louis this seventh day of June eighteen hundred and thirty seven

John RulandJohn Ruland Clerk

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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

JamesJames Brotherton BrothertonJames Brotherton Sheriff
By JJ Gordon D GordonJ Gordon D DJ Gordon D Shff

Service $ 1.00
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No 133

St Louis Circuit CourtCircuit Court
July Term 1837

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

&

Filed 7th June 1837

John RulandJohn Ruland Clerk

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WilliamWilliam Stubs BurdBurd

WilliamWilliam StubsWilliam Stubs

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 &

HH R Gamble RH R Gamble GambleH R Gamble for
Dft

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No 133

July Term 1837

WilliamWilliam Stubs StubsWilliam Stubs
vs
William BurdWilliam Burd
pleas
Not guilty

Plff a slave

Filed 13th July 1837

John RulandJohn Ruland Clerk

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Pleas with & Judgt by nildecitbook 8 page 417

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To the HonLukeLuke E Lawless EdwardLuke E Lawless LawlessLuke E Lawless Judge of the
eighth Judicial Circuit CourtCircuit Court within & for the CountyCounty of St Louis
of St LouisCounty of St Louis & State of MissouriMissouri

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 his mark Stubs
Lewis his mark Stubs

Sworn to & subscribed in open
court 27th July 1837

John RulandJohn Ruland Clerk

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WilliamWilliam Stubs StubsWilliam Stubs &
Lewis Stubs
vs Petition
WilliamWilliam Burd

BurdWilliam Burd

Filed 27 July 1837

John RulandJohn Ruland Clerk