Jesse, a man of color v. George W. Coons
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To the Honorable John M. KrumJohn M Krum , Judge of the
Circuit Court of the Eighth Judicial Circuit:

Your petitioner, JesseJesse , a man of color, would
humbly represent to your Honor that he was
purchased and held as a slave by one MiltonMilton
Duty, in his lifetime, sincedeceased, that
the said Duty, being there a resident of the
State of MississippiMississippi, by his last will and
testament, dated the twenty-sixth day of October A.D. 1836, directed that, at his decease
your petitioner among other slaves which
he then owned, should be manumitted
and set free. Your petitioner further
represents that the said Duty removed your
petitioner, amongst other his said slaves,
to the State of MissouriMissouri in the month of
March A.D. 1837, and in the month of
August A.D. 1838, departed this life in
the city and county of St. LouisSt Louis and StateMissouri
of MissouriMissouri, having made no other will
than the one above mentioned; that the
said will was, as your petitioner is informed
and believes, established and admitted
to Probate, in the Probate court of
WarrenWarren County CountyWarren County in the State of MississippiMississippi
on the twenty-sixth day of November A.D. 1838, and, on the twenty second of June A.D. 1839, was recorded, as the last will and testament
of the said Duty, in the CountyCounty St Louis Court
of , and letters of administration
thereof granted to one George WGeorge W .|Coon, of the said city and county of StSt Louis.
LouisSt Louis, who now, as your petitioner verily

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believes, wrongfully and unjustly holds your
petitioner in slavery. Your petitioner therefore
humbly prays your Honor that he
may be allowed to prosecute this his suit
for freedom, as a poor person, that counsel
be assigned him, and that the usual
orders in such cases be made on his behalf,
and as is duty bound he will
ever prays âC.

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State of MissouriMissouri
County of St LouisCounty of St Louis
ss

This day personally appeared
before the undersigned, JesseJesse , the above named
petitioner, who being duly sworn on his oath
says that the facts stated in the foregoing
petition are true to the best of his knowledge
and belief.

his Jess
Mark

Sworn to and subscribed
before me the 28th day of May 1844

PeterPeter Bruess
Justice of the Peace

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State of MissouriMissouri
St. Louis County
ss.

JesseJesse , a man of color, plaintiff
in this action, complains of George WGeorge W Coons .
CoonsGeorge W Coons , defendant in said action, of a plea
of trespass and false imprisonment; for that
the said defendant on the twenty fifth day of May in the year of Our Lord eighteen hundred and forty four, with force and
arms, at the County aforesaid assaulted the
said plaintiff and then and there beat, bruised
and ill-treated him, and then and there imprisoned
him and then and there kept and
detained him in prison, without any reasonable
or probable cause whatsoever for a long time
to writ: for the space of six hours then next
ensuing, against the will and consent of the
said plaintiff and contrary to the laws of
the State of MissouriMissouri, and the liberties of
the people thereof; and the said plaintiff
avers that before and at the time of the committing
of the grievances above set forth he the
said plaintiff was, and still is, a free person, and
that the said defendant wrongfully and
unjustly, held and still holds him, said
plaintiff, in slavery; and other wrongs
to the said plaintiff then and there did
against the peace of the State of MissouriMissouri
and to the damage of said plaintiff
five thousand dollars, and therefore he sues

Risque
â TownsendTownsend for plff.

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â to sue as a
poor - â R,

Counsel âc

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St. LouisSt Louis Circ. Ct. Nov. Term 1844.

JesseJesse (a man of Color
vs
George WGeorge W Coons . CoonsGeorge W Coons

This is a suit for freedom.
let summon
RisqueâTownsendTownsend
p. q.

Filed May 28th 1844.

John RulandJohn Ruland , Clk

Petn. filed
BK15p82.
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County Of St. LouisSt Louis, ss.
The State Of MissouriMissouri,

To the Sheriff of St. Louis CountyâGreeting:

We command you to Summon George W. CoonsGeorge W Coons , 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. LouisSt Louis, on the third Monday
of November next, then and there to answer unto JesseJesse a
man of color, of a plea of trespass â false imprisonment,
to the damage of said plaintiff five 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, in the
city of St. LouisSt Louis, this third day ofJune in the year of our Lord eighteen hundred and forty four.

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

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Default â Judgment for freedom â costs March 26th 184516 p 137. (136)

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No 32

In the St Louis Circuit CourtCircuit Court
>November Term 1844

JesseJesse a man of color
vs
Summons 10th June
George W. CoonsGeorge W Coons

Trespass â false imprisonment
Damages $ 5000.00

Risque â TownsendTownsend . p.q.

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"It is ordered that said petitioner have
leave to sue as a poor person â the Court doth assign
Messrs Risque â TownsendTownsend as Counsel for said petitioner: and it is further ordered that
said petitioner have reasonable liberty
to attend his
counsel â the Court, as occasion may require, that
he be not removed without the jurisdiction of the
Court, and that he be not subjected to any severity
on account of his application for
freedom".

Filed June 3rd 1844

John RulandJohn Ruland Clerk

In forma pauperis () (113)
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Executed this writ in the County ofCounty of St Louis
St LouisCounty of St Louis on the 10th day of June 1844 by offering
to read it and the declaration to George W CoonsGeorge W Coons
which he refused to hear- also by reading to the
said George W CoonsGeorge W Coons the orders of the Judge
endorsed upon this writ.

WilliamWilliam Milburn MilburnWilliam Milburn Shff
By N.C.OsburnOsburn Depy

Fees $ 1.50