St. Louis County ss - To the HonorableLukeLuke E Lawless ELuke E Lawless LawlessLuke E Lawless
Judge of Said Court in Chancery Sitting
Your Orator SamuelSamuel Stokes a man of color
humblycomplaining[ sheweth ] unto your
Honor that about sixteen years past your
Orator & his wifewerefree persons & their
child CharityCharity & grand child Mary Daughter
of Charity were slaves belonging to the
Estate of WilliamWilliam Stokes deceased & the
said CharityCharity & her child MaryMary werethen
offered for sale by the administrator as
execution of said Estate your orator stated
that he & his wife felt at that time
great anxiety to make such arrangements
as to secure the freedom of their child &
Grand child aforesaid but they were unable
at that time to buy them- that having
great confidence in the responsibility
& integrety & human feelings of John and
WilliamWilliam Finneywhom your orator prays may be
made defendants to this Bill he applied
to the said Finneysdescribing to them his
feelings & in relation to said CharityCharity
& her daughter & besaughtthem to purchase
said CharityCharity & her child MaryMary then about
a year old - your orator states that the
said Finneys agreed with your orator
to purchase said CharityCharity & MaryMary if they
could do so at a reasonable price & to
hold them as slaves untilsaid your
orator could pay them the price for which
they should be sold which your orator
agreed to do as soon as he could and as
soon as said price was paid said

Finneys agreed to transfer said CharityCharity
& her future increase & said MaryMary to saidyour orator who agreed to liberate
them At the time of this agreement it
was distinctly understood that the only
means your orator had of making payment
was by the Labor of himself and wife &
that said Finneys did not wish to make
any speculation but that so soon as
said Finneys should be renumerated for
the price they should pay for said
CharityCharity & her child in there by the hereof
said CharityCharity many paid by your
orator or the salaries of said CharityCharity or
by any other means they were to relinquish
to your Orator for the purposes aforesaid
all claim to said CharityCharity & her future increase
and to said MaryMary declaring that in
making the contemplated purchase all
they desired was to be saved from Lass
and to serve the cause of Liberty and
humanity - Your Orator says that soon
after this agreement & understanding said
CharityCharity & her child wereoffered for sale
at Public auction to the highestbidder
that your Orator said CharityCharity & Child &
said John FinneyJohn Finney and many other
bidderswere present - that the sale
commenced & John FinneyJohn Finney was a bidder
that among the bidderswasBeriahBeriah Cleland
ClelandBeriah Cleland . That when said Clelandbid
said CharityCharity proclaimed that she was
unwilling that any one should buy her
but JohnJohn Finney & WilliamWilliam FinneyJohn Finney - for they
had aggreed to purchase her with a
view to secure her freedom & that of
her child - when this declaration

was made John FinneyJohn Finney declared to the
bidders that his object in buying said
CharityCharity & Child was to provide for them
freedom .He then bid for said CharityCharity &
Child the sum of three hundred &
twenty five dollars the object of said Finney
appearing to be so human & disinterested
no one after this bid against him.
Said CharityCharity & her Child, whowere itnot
for the understanding that said Finney
intended to emancipatethem at the time
of said sale would have readily
had to from five hundred to seven
hundred Dollars. Your orator states that
he & his wifelabored hard & submitted to
great privations to redeem these said child
& grand child from slavery and paid
over to said John & who
bought said slaves in partnership all
the money they could acquire as fast
as they could make it untill they paid
said Finneys for the redemption of their
child & grand child at different terms
the sum of two hundred & twenty nine
Dollars. Your orator states, that he raised
& maintainedMaryMary his grand child from
the time she was about a year old until
she was old enough to be servicable to said
Finneys when they took of her
& put her to theirservice. That said
CharityCharity about two or three years after the
Finneys purchased had a child named
John now living withJohn FinneyJohn Finney .
That while said CharityCharity was unable to
Labor from pregnancy as sicknessshewas
sent to your orator who cheerfully

nursed & maintained her wishing the said
Finneys should be at as little trouble &
as possible with her child & believing
that they would act towards him withgood
faith. your orator States that after the
birth of his grand son John he took him
& raied him untill he was able to be
useful to said Finneys when they took
possession of him & engaged him in their
service- Your orator states that his grand
daughter MaryMary has told is married & has
latelygivenbirth to a child which she had
last & that during her sickness & confinement
she was sent to your Orator to be
supported & maintained Your Orator states
that said Finney sold said CharityCharity to
one Gratial for two hundred & fifty dollars
& that she in. Your
orator States that said Finneys after
getting from him & his wife in cash $229
and for the sale of said CharityCharity $250
amounting in all to the sum of $479
and having your orators grand Children
MaryMary & John supported & maintained
during their helpless years of their infancy
& nursed & maintained when they were
sick or unable to work now claims said
MaryMary & John as slaves for life & refuse
to conveythem to your orator so that he
may setthemfreeor to emancipatethem
themselves- they now refuse to refund the
money paid by your orator as aforesaid
or in any way to pay him for raising
& maintaining his grand children as aforesaid
ornursing & taking care of them
in sickness all of which actings & doings
are against equity & good
conscience. Your orator says that it is not
in his power to state particularly the dates
& amount of cash payment made by him

to said Finneys as aforesaid, nor the
time when they soldCharityCharity as aforesaid
Your Orator States that said Finneys sold
said CharityCharity aginst his consent & thusly
rendered it impossible that the contract
between your orator & them could be performed
In consideration whereof & in as
much as your orator is sum debts at
lawhe prays the interposition of this
court that said Finneys maybesummoned
to answer this Bill that they may be
compelledseverally on their corporal oath to
answer all the allegations of this Bill &
particularly the following

1 Were you not in partnership in making the
purchase of CharityCharity & her child MaryMary as
isabove stated

2 Did you not agree with said SamuelSamuel to
make said purchase for the purposes as
above stated if not what was said &
what was the understanding between you &
said SamuelSamuel prior to & at the time of said
purchase

3 Hasnot said SamuelSamuel paid to you for the
purpose in the Bill stated the sum of two
hundred & twenty nine Dollars if not what
sum has he or his wife paid- set out the
amount & date of such payment & the cause
or consideration for which it was paid

4 Have you or either of you any memorandum
or entries made in writing orhaveyouever
had any such in your possession in relation
with to the Terms on which you purchased
said CharityCharity & child oreither of them or
of any payments made by said SamuelSamuel or any
one for him on account of said CharityCharity
or MaryMary or other of them

if so set forth copies of any such memorandums
or entries if in your possession or within
your power if not state what were those
memorandums or entriesaccording to the
best of your recollection

5.Did you not sell said CharityCharity to one
Gratial as above stated & when & for what
sum If not to whom did you sell her
did you sell as a slave for life or for
a term of years & for what sum

6.Has not said SamuelSamuel raised & maintained
his grand daughter MaryMary & his grand son
John in infancy while their services were
valueless- Have not you had their
serviceswhenever they were valuable. Has
not said SamuelSamuel supported & mantained
said CharityCharity MaryMary & his grand son John
generally whom they were sick or
unable to work and have you not
had then service when you required them
as stated in said Bill if not state
the whole truth according to the best of
your knowledge & belief how long said
CharityCharity MaryMary & John have served what
they would have hired for during the times
they were in your service or under your
control and what would be a reasonable
compensation to said SamuelSamuel for his
support & manitance of said CharityCharity
& her children during infancy & sickness
& their inability to labor provided said
SamuelSamuel was intittled to pay therefore

7.Did not you or either of you at the sale
of CharityCharity & her child made as aforesaid
declare to the bidders present that if you
brought said CharityCharity & her her child you
would secure to them their freedom

If not what did you say in relation
to your motives in purchasing or the
freedom of Said CharityCharity or MaryMary or
either of them

8.Did you not purchase said CharityCharity &
MaryMary for the sum of there hundred &
Twenty four Dollars if not for what
sum did you purchased them

9 After it was understood that you came
to secure to CharityCharity & Child their freedom was there
any further bid against you

10 Would not said CharityCharity & child probably
at the time of sale probably have sold
for a much larger sum than you
bid for them had you not stated your
intention of securing their freedom
Your orator prays that said Finneys
may be compelled to emancipate said
children of said CharityCharity under form of
law or to bring them to your orator
so that he may liberate them or if
this cannot be done that they may
be complled to refund to your orator
the sum of four hundred dollars and
Sixty nine Dollars andtheinterest and to
pay your orator a reasonable compensation
for the support & maintainance of his
daughter & her said childern and if your
orator has not prayed the proper relief
he prays for such further & other relief
as he may be entitled to upon principles
of equity & he willever pray to

SamuelSamuel Stokes
vs
JohnJohn Finney & WilliamWilliam
FinneyJohn Finney

Original Bill in
Chanceryfor relief
The Clerk will
please issue a
summons

We command you to summon John FinneyJohn Finney and WilliamWilliam
Finney if they be found in your County,
that they be and appear
before the Judge of our Circuit CourtCircuit Court , sitting as a Court of Chancery on the first day of the next term thereof, to be held
at the City of St. LouisCity of St Louis, within and for the County of St. LouisCounty of St Louis, on the second Monday
of November next, then and there to answer unto the Bill of Complaint filed against them by SamuelSamuel Stokes
a colored man for relief in the matter of his children
to the damage of said plaintiff
dollars And have you then there this writ.

Dismissed by order of Court at complts cost Ch. Recd No 2 p 153

SamuelSamuel Stokes
vs
John FinneyJohn Finney & Wm. Finney

Subpoena in Chancery
BirdBird Complt.

Executed this writ in the county of St LouisSt Louis by reading
it to John & on the 27th day of October 1838 and by delivering a copy of the bills as
furnished by the clerk to John FinneyJohn Finney