Mary, a negro woman v. James Jr.
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To the To the Hon the Judge of the st Louis circuit
court. The petition of MaryMary a Negro woman
aged about 32 years Respectfully Requests to your
honor that she was born in the state MarylandMaryland-
that she was owned & held as a slave by one Mr Gardner
who about the year 1819 him the said MaryMary & defendant
by a will then made & recorded in the county of BaltimoreBaltimore
to Miss Sarah Lurk to have- to hold as a servant
until she arrived at the age of twenty one years
or thereabout at which time she was to be free by
virture of said will & according to the Laws of MarylandMaryland of the will
your petitioner further requests that after the making no
aforesaid & after she came into possession of the said
Sarah Lorsh according to its provisions she was by the
said Sarah Lorsh summoned out of the state of
MarylandMarylandto the state of KentuckyKentucky & from
KentuckyKentucky she was removed to the StateMissouri ofMissouri MissouriMissouri
When the said Sarah Lorsh was married to
one & by virture of said
your petitioner came into the possession of the
said who mortgaged your petitioner
to for & who got possession
of your petitioner about the year1834 or 1840
and has continued to hold your petitioner since that
as a slave & still holds & acquires ownership
her as such although your petitioner
by virture of the will above mentioned is a free
woman of color therefore your petitioner pleas
that your honor allow her sue as a poor person
to establish her right to freedom according to the
Law in such case made & provided MaryMary

J F Ris

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MaryMary a negro Woman of color being sworn petitioner
says that the matters & things set forth in the forgiving
and there

MaryMary

X

her mark
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Sworn to and Subscribed
Before Me this 29th day of OctoberA.D.1844,

Whetman
Justice of the peace

I allow the foregoing and order First
That the said MaryMary be allowed to sue as a poor
person to establish her rightto fredom
& assign J.F Risk eqr as her counsel
Second that said MaryMary have reasonable
Liberty to attend her counsel & the court
as a season may require that she be not
removed out of the jurisdiction of the court
& that she be not subjectto any severity on
account of her application for freedom.

John M KrumJohn M Krum

Judge

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State of MissouriMissouri
CountyCounty St Louis of St. LouisCounty St Louis
MaryMary a negro womanvJamesJames Jr JrJames Jr

St Louis Circuit CourtCircuit Court
NovTerm 1844
for

MaryMary a Negro Woman
complains of JamesJames Jr JrJames Jr in a plea
of Trespass for false imprisonment For that
theretofore towit on the tenth day of October Eighthundred
and forty five A.D. 1843 the said JamesJames Jr JrJames Jr with
force & arms then & there made an assault on
the said MaryMary to wit at the city of St Louis County
of St LouisSt Louis & State aforesaid & then & there beat
bruised & illtreated her the said MaryMary & then &
there imprisoned her the said MaryMary kept & delivered
her the said MaryMary in prison there without any reason
able or probable cause whatsoever for
a long time towit for the space of one year
past contrary to Law & against the will of the
said plaintiff and the said plaintiff further
owns that before the government above
mentioned the was
& still is a free person of color
and that the defendent did then & still holds
her in slavery & therefore she sues

By

of F
Atty

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And the said trespass the force & in-
jury when he is assigned of the
said supposed trespass own land to his days
in manner &form another law pltff law &arm
thereof complains against him
himself when the county


Plea Filed Nov

19th 1844

D. Allen

Jno RulandJohn Ruland Clerk Att for Deft

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StateMissouri ofMissouri MissouriMissouri

Couty of St. LouisCircuit Court
St LouisSt Louis Circuit CourtCircuit Court
MaryMary a Negro woman
v
James Clemens JrJames Clemens Jr Action of Trespass
for flase imprison
ment

The Clerk will issue
a summons in the a:
bove returnable
to the Nov Term 1844

T H Rich
Att for Dfns

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County of St. LouisCounty of St Louis,

ss.

The State Of MissouriMissouri,

To the Sheriff of St. Louis County--Greeting:

We command you to summonJamesJames Clemens Jr Clemens JrJames Clemens Jr
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 Mon-
day of November next then and there to answer untoMaryMary
a negro woman of a plea of trespass and false
imprisonmentto the damage of said plaintiff 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, thisSecondday ofNovember in the year of our Lord eighteen hundred and forty four.

John RulandJohn Ruland

Clerk.

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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plea filed 15 p 297 suit dismissed November 26th. 184415p 330 at nobodys Costs

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No.346

St. LouisCircuit Court Circuit CourtCircuit Court
November 1844

MaryMary a negrowomanvJames Clemens JrJames Clemens Jr
SummonsTrespass & False Imprisonment

False T. F. Risk p.q

Filed November 2 1844

John RulandJohn Ruland

Clerk
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I allow the foregoing and order
First that the said MaryMary be allowed
to sue as a free person to establish her
right to freedom to assign T. F. Risk Esq
as her Counsel second that said MaryMary
have reasonable liberty to attend her
Counsel & the Court as occasion may
require that she be not removed and of the
jurisdiction of the Court that she be not
subject to any severity on account of her application for
her freedom Jno McKrum Judge 8 Jud Cir (153)

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Executed this writ in the
County of St. LouisCounty of St Louis on the 2nd day of Novem-ber 1844 by offering to read it and the
decleration to JamesJames Clemens Jr Clemens JrJames Clemens Jr which
he refused to hear - Also by reading to the
said James Clemens JrJames Clemens Jr . the of the
Judge endorse upon this writ.

WilliamWilliam Milburn MilburnWilliam Milburn Shff

By

N. C OsburnOsburn Shff

Fee $ 1.50