HumblyHumbly complaining showeth unto Your Honor
your petitioner MaryMary Robertson RobertsonMary Robertson of the County ofCounty of St Louis
St LouisCounty of St Louis & State of MissouriMissouri, that she is at the
present time held in slavery in the County aforesaid
by Ringrose DRingrose D Watson . WatsonRingrose D Watson , that she has fresh grounds
on which she claims her right to freedom viz, that
on or about the seventh day of March AD 1841
she was taken by her (then) master & owner AmosAmos L Carson LAmos L Carson .
CarsonAmos L Carson from the County & State aforesaid to the
State of IllinoisIllinois, that she was there retained
in Slavery by her last mentioned owner, contrary
to her own, but according to his request
that she was in the Town of Alton & State ofIllinois
IllinoisIllinois, retained by the last mentioned owner for several
months, to wit from the time aforesaid until on or about the 24th day of July AD, 1841 & kept
at labor in every respect as a slave by the said
CarsonCarson during the said time, & Contrary to the Laws
of said State by which she obtained her right
to freedom, that on or about the said 24th day of July she was sent back to the County of St. LouisCounty of St Louis
& State of MissouriMissouri & held in slavery by the said WatsonWatson ,
from whom she was claims her right to freedom
Now therefore your petitioner prays that your
Honor will grant unto your petitioner, leave
to sue as a poor person in order to establish
her right to freedom & your petitioner will ever
pray & c & c.

Sworn and subscribed to
before me this 13th day of Sept. 1841
Alphonse Witmore
Justice of the Peace

The written named Mary RobertsonMary Robertson
is by me allowed to
sue as a poor person to establish her right to freedom
& I assign HenryHenry LL Cobb .CobbL Cobb as her counsel
and I further order & declare
that she have reasonable
liberty to attend her counsel
& the Court; that she be not removed out of the jurisdiction
of the court & be
not subjected to any severity on account of her application
for freedom-
As witness my hand at
ChambersChambers this 10th Sep 41

Petition for leave to sue

Mary RobertsonMary Robertson complains of RingroseRingrose D Watson
D. WatsonRingrose D Watson of a plea of trespass, for that the
said defendant on the tenth day of August A.D. 1841 with force & arms &c. made an assault
upon the said plaintiff, to wit at the County
aforesaid & then & there beat bruised & ill-treated
her the said plaintiff & then & there
imprisoned her the said plaintiff, & kept &
detained her in prison there, without any
reasonable or probable cause whatever, for a
long space of time to wit for the space of
twelve hours then next following, contrary
to the laws of the State & against the will of
the said plaintiff And the said Plaintiff
further avers, that the said plaintiff
before & at the time of the committing of the
grievances was and still is a free person
and that the defendant held & still holds
the said plaintiff in slavery, And other wrongs
to the said plaintiff then & there did, contrary
to the peace & dignity of the State
and to the damage of the said plaintiff
of five hundred dollars & therefore the
said plaintiff brings suit, by.

Declaration in Trespass
Damages $ 500.00

We command you to summon Ringrose D. WatsonRingrose D Watson 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, on the third Monday
of November next, then and there to answer unto MaryMary Robertson
RobertsonMary Robertson of a plea of trespass
to the damage of said plaintiff of five hundred
dollars: And have you then there this writ.

The within named Mary RobertsonMary Robertson is by me allowed to
sue as a poor person to establish her right to freedom,
& I assign HenryHenry L CobbL Cobb as her counsel, and I
further order and direct that she have reasonable liberty to attend her counsel & the Court; that she be not removed out of the jurisdiction of the Court & be not
subjected to any severity on account of her
application for freedom- as witness my hand

at chambers this 10th Sep.'41

Executed this writ in the CountyCounty of St Louis
of St. LouisCounty of St Louis on the 15th Day of September 1841 by reading it and the declaration
and petition and also the order
made by the Honorable Judge
to Ringrose D WatsonRingrose D Watson the in the
County of St LouisCounty of St Louis on the
defendant

Trespass dams $500:

Colt. P.2.

to 81

73

Filed 5th September 1841

Contd Bk 13 p 358 Petition [ transfc ] to present shff & order to hire her out p 376 Denied
Plffs cost. 14 p 330.Jan 15/44
. Mo. to reinstate filed Jany 25/44.
aff in support of same
Bk 14 p 366. Mo to set aside & reinstate sustd Bk 14 p 370.ContdB 15 p 245. Verdict
for Deft Nov 27th 184415 p 338

Warrant to the
Sheriff
against Mary RobertsonMary Robertson
and the person in whose
possession she may
be found.

Filed October 7 1841

Executed this writ in the County of St LouisCounty of St Louis
by summoning Louis Du Breuil as within commanded
& had the body of MaryMary the within
named plaintiff in open Court the7th Oct 1841.

Your petitioner Mary RobertsonMary Robertson
to whom your Honor granted leave
to sue as a poor person at the next
term of the Circuit CourtCircuit Court in order
to obtain her freedom humbly complains
that she is now confined in the jail
of St. Louis County & is about to be sold
by the constable of said County to satisfy
executions against her pretended owner
AmosAmos L Carson LAmos L Carson . CarsonAmos L Carson , & that she has reason
to believe & does believe that after
said sale she is about to be removed out
of the jurisdiction of the St. Louis CircuitCircuit Court
CourtCircuit Court, & her removal will result from said sale
For which reason she prays that
Your Honor will cause your petitioner
to be brought up before
your Honor by a warrant under
the hand of your Honor according
to the statutes in such case
& provided.

You are hereby commanded to seize Mary RobertsonMary Robertson a person
of color, wheresoever she may be
found in the State of MissouriMissouri
and bring her before the Judge of our Circuit Court of the County of StCounty of St Louis.
LouisCounty of St Louis in our eighth Judicial Circuit at the Court house in the
City of St LouisCity of St Louis in said County at
ten o'clock A.M. on Thursday
the seventh day of October in the year of our Lord one thousand eight hundred and forty one, and do you moreover
summon the person in whose
possession she may be found to
appear before our said Judge
at the said time and place
& house you then there this writ-
We being moved hereunto by the affidavit
hereto annexed- In testimony
whereof witness the hand
of our said Judge at ChambersChambers
in the County aforesaid.

Louis Du Breuil summoned to appear before the
HonorableSt Louis Circuit CourtCircuit Court on the eighth day of October in the year A.D. 1841 in the matter
pending before said Court on the petition and affidavit
of one HenryHenry L CobbL Cobb .
stating that MaryMary negress is a petitioner for
freedom and is detained in custody &c HumblyHumbly
showeth that that he is constable of St LouisSt Louis Township on second day of August in
the year AD 1841 a unit of attachment was found by
Alphonso WitmoreAlphonso Witmore Justice of the Peace in and for
the county of St LouisSt Louis at the suit of BenjaminBenjamin Woods
and against one Amos L CarsonAmos L Carson
directed to your respondent and ordering him
to attach the said CarsonCarson by all and his
goods and chattels to the amount therein specified &
named, and that on the second day of August
your respondent did levy the said writ upon a MaryMary this good the said negro goodwoman as
the property of the said CarsonCarson and that afterwards by
due course of law, a judgment was obtained in
said suit against the said CarsonCarson and a writ
of fieri facias delivered on the 25th day of September 1841 by the said Justice
into the hands of your respondent directing
him to the amount therein specified
and out of the good of the said
CarsonCarson and on the and your respondent
these said in such cases provided
who sold in the Township of St. LouisSt Louis on
the 7th day October, and was proceeding to sell
the same when He was summoned to appear
before your Circuit and he delivered up
the said negress up to the sheriff of St Louis County
He therefore prays the court that he may go
day that such order relative to the property
may taken as may hold him harmless. &c
Louis De Breuil

De Breuil's case
on Warrants &c.

Filed October 9 1841

order to Shff Bk 13 p 2- contd BK 13 p 13- Shff ordered to hire out
petitioner Bk 13 p 39

And the said defendant
1. by Crockett & Gist his Attorneys comes and
defends the said injury when &c
and says that he is not guilty of the said
supposed trespass above laid to his charge or any or either of them or any part thereof
in manner and form as the said pltff
hath above thereof complained against
him and of this he the said defendant
puts himself upon the County

2. And for a further plea in this behalf
the said defendant says that at the time
of the institution of said suit the said
plaintiff was and still is a slave, and
this the said defendant is ready to verify

3. And for a further plea in this behalf
the said defendant says that at the
time of the institution of said suit the said
plaintiff was and still is a slave, the
property of Amos L CarsonAmos L Carson and this
the said defendant is ready to verify

Crockett & Gist Filed December 2nd 1841

And the said plaintiff
as to the plea of the said defendant by him
first above pleaded and whereof he hath
put himself upon the County, doth the like. And the said plaintiff, as to the said pleas
of the said defendant, by him secondly and thirdly
above pleaded says that she the said plaintiff
by reason of anything, by the said defendant
in those pleas alleged, ought not to be barred
from having, and maintaining her aforesaid
action thereof, against the said defendant
at the said times, where &c of his own wrong
and without the cause; by him in his said
second, and third plea alleged, committed the
said trespasses in manner and form, as the
said plaintiff, hath above in her said
declaration complained against the said
defendant, and this she the said plaintiff
prays may be inquired of by the County &c.

Similiter to 1st &
Replication to 2d & 3 Pleas

You are hereby commanded, that setting aside all manner of excuse and delay, you appear
before the Judge of our Circuit CourtCircuit Court , on the30th day of August 1842
at the city of St. LouisSt Louis, then and there to
testify, and the truth to say, in a certain matter of controversy now pending in our said Court,
wherein Mary RobertsonMary Robertson
plaintiff and Ringrose Watson defendant on the part of Mary RobertsonMary Robertson and herein you are in no wise to fail.

ElijahElijah HaydenHayden copy

Executed this writ in the County of Saint LouisCounty of Saint Louis
on the 27th Aug 1842 by reading it to AlonzoAlonzo Green GreenAlonzo Green
and Mrs Sally BushSally Bush and leaving a copy at the
residence of ElijahElijah HaydenHayden with a white female over
15 years of age.

fees	$1.50 ct
non est	12 1/2
	$1.62 1/2

You are hereby commanded, that setting aside all manner of excuse and delay, you appear
before the Judge of our Circuit CourtCircuit Court , on the thirtieth day of August
next at the City of St. LouisCity of St Louis, then and there to
testify, and the truth to say, in a certain matter of controversy now pending in our said Court,
wherein Mary RobertsonMary Robertson (a woman of colour) is plaintiff andRingrose D. WatsonRingrose D Watson is
defendant on the part of the defendant
and herein you are in no wise to fail.

Executed this writ in the County of Saint LouisCounty of Saint Louis
on the 26th August 1842 by reading it to Raplee-
JohnJohn Reesby ReesbyJohn Reesby not found in my county.

fees Serv.	50ct
non est	12 1/2
	1.62 1/2 ct

Witness

We command you to attach ElijahElijah HaydenHayden
by his body and safely keep, so that you have his body
before the Judge of our Circuit CourtCircuit Court , now in session at the City of St. LouisCity of St Louis, within and for
the County of St. LouisCounty of St Louis, on the 31 day of August 1842 then
and there to testify and the truth to say in a certain matter of controversy, now pending in
our said Circuit CourtCircuit Court , between Mary RobertsonMary Robertson
plaintiff, and RingroseRingrose D Watson DRingrose D Watson WatsonRingrose D Watson defendant wherein
the said ElijahElijah HaydenHayden has heretofore been summoned
on the part of the said Mary RobertsonMary Robertson

The within witness not found
in my County Aug. 30th 1842

ElijahElijah HaydenHayden

We command you to attach AlonzoAlonzo Green GreenAlonzo Green
by his body and safely keep, so that you have his body
before the Judge of our Circuit CourtCircuit Court , now in session at the City of St. LouisCity of St Louis, within and for
the County of St. LouisCounty of St Louis, on the 1 of September1842 then
and there to testify and the truth to say in a certain matter of controversy, now pending in
our said Circuit CourtCircuit Court , betweenMary RobertsonMary Robertson
plaintiff, and RingroseRingrose D Watson DRingrose D Watson WatsonRingrose D Watson defendant wherein
the said AlonzoAlonzo Green GreenAlonzo Green has heretofore been summoned
on the part of the saidMary RobertsonMary Robertson

Executed this attachment in the
County of Saint LouisCounty of Saint Louis on the 1st day of September 1842 by delivering the
Body of AlonzoAlonzo Green GreenAlonzo Green in Court

AlonzoAlonzo Green GreenAlonzo Green

Now the plaintiff by her Counsel
comes and moves the Court the reinstate her
case for the following reasons

1st
Because she has a good cause of action.

2nd
Because her former Counsel withdrew
the suit without her knowledge or instructions

3rd
Because if the case is reinstated
she believes she will be able to show
a good cause of action

Motion to reinstate

Mary RobertsonMary Robertson (negro), and
said plaintiff, being duly sworn upon
her oath says, that she employed HenryHenry
L CobbL Cobb . Attorney, sometime in the year
eighteen hundred & forty one to bring suit for
her freedom, before this Honorable Court, wherein
R D WatsonR D Watson is defendant, that for his
services in said such she paid him money
and did work for him as his
washerwoman, that she was ready for trial
of the time the case was to be called on
the fifteenth of this January Eighteen hundred &forty four, but that to her [ supprise ] her
suit had been dismissed. The affiant
further says that she has a good cause of
action as she is advised by her counsel
and that if her suit is reinstated and
she is permitted to go to trial she will
as she verily believes be able to make
out her case.
the affiant further say that she was
not aware that her said attorney
was to be absent or was absent on
or before the day of fixed for trial of said suit and
that she did not learn the fact of his
absence until several days afterwards
and further the affiant saith not

Sworn to and subscribed before me
this seventh day of February, A.D. Eighteen hundred and forty four.

Afdt. by plff in support of
motion to set aside nonsuit.

You are hereby commanded, that setting aside all manner of excuse and delay, you appear
before the Judge of our Circuit CourtCircuit Court , on thetwenty seventh
Mayat the City of St. LouisCity of St Louis, then and there to
testify, and the truth to say, in a certain matter of controversy now pending in our said Court,
wherein Mary RobertsonMary Robertson is
plaintiff andR D WatsonR D Watson
defendant on the part of the plaintiff
and herein you are in no wise to fail.

Exd the 25th May 1844
Wm MilburnWilliam Milburn Shff

A. Green Witness
for Plff at VirginiaVirginia Hotel. 27th May

You are hereby commanded, that setting aside all manner of excuse and delay, you appear
before the Judge of our Circuit CourtCircuit Court , on the 20th of June
at the City of St. LouisCity of St Louis, then and there to
testify, and the truth to say, in a certain matter of controversy now pending in our said Court,
wherein Mary RobertsonMary Robertson
plaintiff and R D WatsonR D Watson
defendant on the part of the plaintiff
and herein you are in no wise to fail.

Sub for

Executed
William MilburnWilliam Milburn Shff

Fee $ 1.00

You are hereby commanded, that setting aside all manner of excuse and delay, you appear
before the Judge of our Circuit CourtCircuit Court , forthwith
at the City of St. LouisCity of St Louis, then and there to
testify, and the truth to say in a certain matter of controversy now pending in our said Court,
wherein Mary RobertsonMary Robertson is
plaintiff and R D WatsonR D Watson is
defendant on the part of the plaintiff
and herein you are in no wise to fail.

Sub for

Executed Nov 26th 1844
Wm MilburnWilliam Milburn Shrff
fee $ .62 1/2 ct

You are hereby commanded, that setting aside all manner of excuse and delay, you appear
before the Judge of our Circuit CourtCircuit Court , on this day the 26th ofNovember 1844 at the City of St. LouisCity of St Louis, then and there to
testify, and the truth to say, in a certain matter of controversy now pending in our said Court,
wherein Mary RobertsonMary Robertson is
plaintiff and Ringrose D. WatsonRingrose D Watson
defendant on the part of Deft
and herein you are in no wise to fail.

Subpa

Executed Nov 26 1844.
Wm MilburnWilliam Milburn Shrff
fee 50cts

Executed this writ in the County ofCounty of St Louis
St. LouisCounty of St LouisNovember the 26th 1844 by leaving a true
copy thereof at the residence of Jn Risby with
a white member of the family over the age of
fifteen years

You are hereby commanded, that setting aside all manner of excuse and delay, you appear
before the Judge of our Circuit CourtCircuit Court , on theforthwith
at the City of St. LouisCity of St Louis, then and there to
testify, and the truth to say, in a certain matter of controversy now pending in our said Court,
wherein Mary RobertsonMary Robertson is
plaintiff and R. D. Watson is
defendant on the part of the Plaintiff
and herein you are in no wise to fail.

Sub for

We command you to attach Sally BushSally Bush by her body and safely keep, so that you have her body
before the Judge of our Circuit CourtCircuit Court , now in session at the City of St. LouisCity of St Louis, within and for
the County of St. LouisCounty of St Louis, on the 31 day of August 1842 then
and there to testify and the truth to say in a certain matter of controversy, now pending in
our said Circuit CourtCircuit Court , between Mary RobertsonMary Robertson
plaintiff, and RingroseRingrose D Watson DRingrose D Watson WatsonRingrose D Watson defendant wherein
the said Sally BushSally Bush has heretofore been summoned
on the part of the said Mary RobertsonMary Robertson

Executed
fee $1.00

Sally BushSally Bush
witness discharged