Brunetta Barnes, an infant of color, by and through her next friend, Peter Charleville v. John Berry Meachum
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State of MissouriMissouri
County of Saint LouisCounty of Saint Louis ss

In Saint Louis Circuit CourtCircuit Court
November Term 1840

Brunetta BarnesBrunetta Barnes , an infant of colour under the age of
twenty one years to wit of the age of fourteen years, admitted
to the here as a poor person by PeterPeter CharlevilleCharleville her next friend
of Saint LouisSt Louis and State of MissouriMissouri, complains of Berry Meach-
um of the state and county aforesaid of a plea of trespass and
false imprisonment for that the said defendant heretofore
to wit on the first day of January in the year Eighteen hun-dred and forty, at the county aforesaid, in and upon the
said plaintiff did make an assault: and her the said plaintiff
did then and there beat and evilly treat, and then
and there did imprison, keep, detain confine and hold
the said plaintiff in confinement and slavery: and still
continues to imprison the said plaintiff and to keep detain
and hold her in confinement, and has ever since then im
prisoned the said plaintiff and kept detained and
held her in confinement and slavery to wit at the
county aforesaid, contrary to the laws of the state
and against the will of said plaintiff. And the
aid plaintiff avers that she was, at the time of the
committing of the grievances aforesaid, and before
that time, and has ever since then continued to be
and still is a free person and that the defendant
then and there held, and has ever since continued
to hold, and still holds her the said
plaintiff in slavery to wit at the county afore-
said - and then and there did other wrongs to the
said plaintiff against the peace government &
dignity of the state and contrary to the form of
the statute in such case made & provided. To the
damage of the said plaintiff in the sum of
one thousand dollars and therefore she brings
suit& so forth

Gantt & Strother
for plaintiff

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In St. Louis Circuit CourtCircuit Court
November Term 1840-

Brunetta BarnesBrunetta Barnes , by
PeterPeter CharlevilleCharleville her next
friend
Trespass and false
imprisonment -
vs
BerryBerry Meachum MeachumBerry Meachum

Damages $1000

Let a summons issue

Gantt &Strother
p. q.

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County of St. LouisCounty of St Louis, ss.
The State Of MissouriMissouri,

To the Sheriff of St. Louis CountyâGreeting:

We command you to Summon BerryBerry Meachum MeachumBerry Meachum if he be
found in your County that he be and appear
before the judge of our Circuit CourtCircuit Court , 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 third Monday
of November next, then and there to answer unto BrunettaBrunetta Barnes
BarnesBrunetta Barnes who sues by PeterPeter Charliville her next friend
of a plea of trespass& false imprisonment
to the damage of said plaintiff of one thousand
dollars: And have you then there this writ.

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Witness, John RulandJohn Ruland . Clerk of our said Court,
with the seal thereof hereto affixed at office,
City of St. LouisCity of St Louis, this Thirty first day ofAugust in the year of our Lord eighteen hundred and forty

John RulandJohn Ruland

Clerk.
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I acknowledge myself bound for all costs that may accrue in the above cause.

Witness my hand and seal, at St. LouisSt Louis, this day of 184

L.S.

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contd BK 13 p 12 - Sub & Judgt for plff noml damages & Judgt of of liberation BK 13
p 326

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No. 121

St. Louis Circuit CourtCircuit Court
November Term 1840

BrunettaBrunetta Barnes BarnesBrunetta Barnes by PeterPeter
CharlevilleCharleville her next friend
vs
BerryBerry Meachum MeachumBerry Meachum
Summons

Trespass & false imprisonment
Damages - 1000

Gantt & Strotherpq

Filed August 31, 1840

John RulandJohn Ruland Clerk

Free
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Executed this writ in the County ofCounty of St Louis
St LouisCounty of St Louis by offering to read it and the
declaration to BerryBerry Meachum MeachumBerry Meachum
the 1st day of September 1840. which
he refused to hear

Service 1.00

Marshall BrothertonMarshall Brotherton Sheriff
By W. S. McKnight Depty

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Know all were by these presents that we
John BerryBerry Meachum MeachumBerry Meachum as principle and Geroge
- as security are indebted unto
the State of MissouriMissouri in the sum of seven
hundred fifty dollars for the payment whereof
we bind ourselves our executors andad-
ministrators by these presents. Sealed
with our seals and dated this first day of August eighteen hundred forty.

The condition of this recognizance is such
that whereas BrunettaBrunetta Barnes BarnesBrunetta Barnes has filed her
petition in the St Louis Circuit CourtCircuit Court &
procured an order to sue said MeachumMeachum for
freedom: Now if the said Brunetta
the petitioner, shall during the pendency of the
suit have resonable liberty of attending her
counsel and the Court and shall not be
removed out of the judiction ofsaid court,
and shall not be subjected to any seventy on
account of her application for freedom; then
this obligation shall be void else it shall
remain in force.

JohnJohn B BJohn B Meachum

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George Trask

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Filed August 1st 1840

Jn RulandJohn Ruland Clk

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BrunettaBrunetta Barnes BarnesBrunetta Barnes
vs.
J. B.Meachum

St. Louis Circuit CourtCircuit Court

Nov. T. 1840

And the defendant
by his attorney comes and defends the
wrong & injury when &c. and says he
is not guilty of said supposedtrespas-
ses wherewith he is charged in man-
ner and form as in the declara
tion set forth &.c., and of this he
puts himself upon the county &.c.

And for further plea he says that
the said plaintiff was at the time when &.c.,
the slave of him the defendant & this he is
ready to verify wherefore he prays
&.c.

SpaldingSpalding & TiffanyTiffany
attys for dft

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St. Louis Circuit CourtCircuit Court

BrunettaBrunetta Barnes BarnesBrunetta Barnes
vs.
MeachumMeachum

pleas

SpaldingSpalding & TiffanyTiffany
attys

Filed November 17th 1840

Jn RulandJohn Ruland Clerk

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BrunettaBrunetta Barnes BarnesBrunetta Barnes
(by her next friend)
vs
John BerryBerry Meachum MeachumBerry Meachum

In the St Louis Circuit CourtCircuit Court
March Term 1841

Replication

And the said plaintiff as to
the first plea of the said de
fendant by him in this behalf pleaded & whereof he
hath put himself upon the Country doth the like

And as to the second plea of said defendant
the plaintiff says that the by reason of any
thing in the said plea contained ought not to he
barred from having and maintaining her said
action thereof against said defendant, because
She says that at the time of the commit
ting of the trespass in the said declaration men
tioned, plaintiff was and still is a free person
and not the slave of defendant as in the said
plea is alleged, and this the said plaintiff
prays may be enquired of by the country.

ThomasThomas
Atty for plff

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BrunettaBrunetta Barnes BarnesBrunetta Barnes (by
next friend)
vs
John BJohn B . MeachumMeachum

Replication to pleas

ThosThomas .
atty for pltt

Filed March 9th 1861

Jn RulandJohn Ruland Clerk