Thomas Jefferson, a man of color v. George A. Calton and Jonathan B. Moulton
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State of MissouriMissouri
County of St LouisCounty of St Louis

ss

In the St Louis Circuit CourtCircuit Court Nov Term 1845

Thomas JeffersonThomas Jefferson a man of
Color complains of George A Calton & Jonathon B
Moulton of a plea of tresspass for that said
defendents on the first day of January Eighteen hundred and forty five with force and arms
made an assault upon plaintiff to wit
at the County aforesaid and then and there beat
bruised and ill treated him the said plaintiff and
then and there imprisoned him the said plaintiff
and kept and detained him in prison then and
there without any reasonable cause whatever for
a long time to wit, the one month then
next following contrary to the statute Law of the said, against the will of sd
plaintiff and the peace & diginity of the State
And said plaintiff avers that before the Committing
of said grievances, he the said plaintiff was
and still is a free person. and that defendants
then held and still do hold him in slavery
to said plaintiffs damage five hundred
dollars and therefore he sues

Field Murdock & Dawson
pq

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To the HonJohn MJohn M [ Krumm ] Judge of the StCircuit Court Louis CircuitCircuit Court CourtCircuit Court


Your petitionerThomasThomas Jefferson JeffersonThomas Jefferson a man of color aged about
Thirty two years, humbly complaining respectfully
represents to your honor that he was born a slavein
the State ofState of Virginia VirginiaState of Virginia, That in the Spring of Eighteen hundred and thirty five he was brought by his master
one Charles Drexter to St LouisSt Louis in the StateMissouri ofMissouri MissouriMissouri
where he (your petitioner) resided [ untill ] the Spring of
Eighteen hundred and thirty nine. That in the
month of March or April of the year last mentioned
said Drexter sold your petitioner to one SamuelSamuel
ProsserProsser . That said ProsserProsser then resided and now
resides at JacksonvilleJacksonville in the State ofIllinois IllinoisIllinois
That said ProsserProsser immediately after becoming the
owner of yourpetitioner removed your petitioner
to the County ofCounty of Morgan MorganCounty of Morgan in the state of
IllinoisIllinois, where said ProsserProsser your petitioners then
master, held your petitioner in slavery & compelled
him to labour as such on a farm in said County
of Morgan & State of IllinoisIllinois for a period of
about Eight months. Then next following the
month of April in the year Eighteen hundred and thirty nine. at the expiration of which period
your petitioner was again brought back to St LouisSt Louis
by sd ProsserProsser and that some Six months since
said ProsserProsser sold your petitioner to one George
A Calton, and Jonathan BJonathan B Moulton MoultonJonathan B Moulton , who have
ever since, and still do hold your petitioner in
bondage. Your petitioner believing he is entitled
to his freedom, prays your Honor to grant him
cause to sue as a poor person to establish said
freedom according to the provisions of the Statute
in in such cases. & he willever pray &c

ThomasThomas his

x

mark JeffersonJefferson
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George M Richards being sworn
States he knows the petitioner
and believes
the facts contained in
foregoing petition to be true

Geo. M. Richards


Sworn to & Subscribed before me
this29 day of April 1845

Jn RulandJohn Ruland Clerk

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Sworn & subscribed
before me this 26th day ofApril A.D.1845

John Winright

Justice of the Peace

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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 Summon George AGeorge A Colton ColtonGeorge A Colton &
Jonathan B MoultonJonathan B Moulton that they 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 unto ThomasThomas Jefferson
JeffersonThomas Jefferson of a plea of trespass to the damage of said plaintiff five hundred
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 fifth day ofMay in the year of our Lord eighteen hundred and forty five.

JohnJohn Ruland 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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Plea filed 16 p 403.nonsuitNov. 30. 18463 p 390.

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No.24

Saint Louis Circuit CourtCircuit Court November Term 1845

Thomas JeffersonThomas Jefferson
vsGeorgeGeorge A Colton A ColtonGeorge A Colton and
Jonathan B. Moulton

Summons 5th May
Trespass Das
500

Murdock & Dawson

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Filed April 29th 1845

JnJohn Ruland RulandJohn Ruland Clk

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It is ordered by the Court that ThomasThomas Jefferson
JeffersonThomas Jefferson be allowed to sue as a poor
person to establish his right to freedom
and that Messrs Murdock & Dawson
are assigned him as Counsel he shall have
reasonable liberty to attend his Counsel
and the Court as occasion may require,
that he be not removed out
of the jurisdiction of the Court, and
that he be not subject to any severity
on account of his application for
freedom.


(190)

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Executed this writ in the CountyCounty of St Louis
of St LouisCounty of St Louis on the 5th day of May 1845 by
offering to read it and the declaration to
GeorgeGeorge A Colton A ColtonGeorge A Colton and Jonathan B [ Molton ]
the defendants, which they each refused to
hear

William MilburnWilliam Milburn Shff

By

A C OsburnOsburn Dety

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Service $2.00
service warrant 3.00
$5.00

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In the St Louis Circuit CourtCircuit Court November Term 1845

Thomas JeffersonThomas Jefferson
vs
Coulton & [ Molton ]

AndrewAndrew H H Dawson being
duly sworn states that it is his belief & he
has good ground to suspect & belief that
if an order is not granted in the
above case directing the Sheriff to take
possession of the above plaintiff, that the
sd defendants willremovesend said
plaintiff in order to present his successful
prosectuion of his suit & hereby prevent
his recovery of his liberty

AndrewAndrew H H Dawson

John RulandJohn Ruland Clerk

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No.19

St Louis Circuit CourtCircuit Court November Term 1845

ThomasThomas Jefferson JeffersonThomas Jefferson
vs Suit for freedom
Declaration
Petition & affidavit
Coulton & Moulton

filed29 April 1845

Jno RulandJohn Ruland Clerk


Richmond J Carle

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petition filed & statutory order made & Warrant issued at 10 am Wednesday16p175

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County of St LouisCounty of St Louissct
the State ofMissouri MissouriMissouri

To the Sheriff of CountyCounty of St Louis ofCounty of St Louis
St LouisCounty of St Louis Greeting:

It appearing to the Honorable Circuit CourtCircuit Court John M KrumJohn M Krum , Judge of the St LouisCircuit Court CircuitCircuit Court
CourtCircuit Court from affidavit filed that there is reason to suspect and believe that Thomas JeffersonThomas Jefferson , a
man of color, who has been allowed by the order of the
said Court to sue as a poor person to establish his right
to freedom, will be sent away in order to prevent his successful
prosecution of said suit, and thereby prevent his recovery of
his liberty. You are hereby commanded to seize the
said Thomas JeffersonThomas Jefferson wherever he may be found, and
bring him before me Honorable Judge of said Court at the Courthouse in the
CityCity of St Louis of St LouisCity of St Louis at nine O'clock A.M. on tomorrow
morning the [ thirtyeth ]April 1845, and also to summon
any person or persons in whose possession he may be
found in and particularly GeorgeGeorge A Colton A ColtonGeorge A Colton and JonathanJonathan B Moulton
B MoultonJonathan B Moulton to appear before our said Judge at the same
time and place, and have you then there this writ

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Witness JohnJohn Ruland RulandJohn Ruland , Clerk of our
said Court with the seal thereof
hereto affixed at office in the CityCity of St Louis
of St LouisCity of St Louis this 29th day of April 1845

.

John RulandJohn Ruland Clk

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Executed this writ in the CountyCounty of St Louis
of St LouisCounty of St Louis on the 30th day of April 1845by
reading it to GeorgeGeorge A Colton A ColtonGeorge A Colton & Jonathan
B. Molton and by seizing the body of
Thomas JeffersonThomas Jefferson the [ with ]named and
having his body before the Hon JohnJohn M Krum
M KrumJohn M Krum this 30th day of April 1845
as I am herein commanded

William MilburnWilliam Milburn Shff

Fee $3.00

By A. C

OsburnOsburn Depy
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ThomasThomas Jefferson JeffersonThomas Jefferson (of color)
vs
George A ColtonGeorge A Colton &
Jonathan B MoultonJonathan B Moulton

Warrant to Sheriff

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Tom Jefferson
vs
Colton & Moulton

In the Saint Louis Circuit CourtCircuit Court
of November Term AD.1845

.

And the said defendants by LeslieLeslie & Lord
their
attorneys come and defend the force and
injury when &. And say that they, neither of them
are not guilty of the said suffered trespasses above
laid to their change, or any or either of them in
manner & form
as the said plaintiff hath above
complained against them.

LeslieLeslie & Lord attys


for Defendents
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In Circuit CourtCircuit Court

Tom Jefferson
vs
Colton & Moulton

Plea not Guilty

LeslieLeslie & Lord
for Defts

filed Nov22nd 1845

John RulandJohn Ruland Clerk

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County of St. LouisCounty of St Louis,

Ss.

The State of MissouriMissouri

,

To Miron Leslie, Milton W. HopkinsMilton W Hopkins & Wm CarrCarr
Lane
Greeting:

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 30th day of November A. D. 1846
at 10. O'ClockA.M 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 Tom. Jefferson is
plaintiff and Coulton & Moulton Ure
defendants, on the part of Defts
and herein you are in no wise to fail.

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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 StCity of St Louis.
LouisCity of St Louis, this 25th day of in the year of our Lord one thousand eight hundred and forty-six

Jn. RulandJohn Ruland

Clerk, C. C.
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In Circuit CourtCircuit Court

JeffersonJefferson
v
Colton & Moulton

Subpoena for 30.Nov

X M. Leslie

X M. W. Hopkins

WmCarrCarr Lane

for Defts.
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ExecutedNovember 30th 1846
Except. W not found
Samuel ConwaySamuel Conway Sheriff

Fee 1.50

GG Stevens StevensG Stevens Depy