To the Honourable the Judge of the St LouisCircuit Court CircuitCircuit Court
CourtCircuit Court the petition of ElsaElsa Hicks HicksElsa Hicks a Mulatto Girl
aged about twenty one years Respectfully Represents
to your honour that she was born in the State ofState of Virginia
VirginiaState of Virginia & was owned by one JamesJames Mitchell MitchellJames Mitchell
Who aquired her by to one Miss Burle-
& has continued to hold her as a Slave since
that time That said MitchellMitchell about the year 1834
removed from said State ofState of Virginia VirginiaState of Virginia to the
Territory of Wisconson carrying with him your
petitioner Where he held your petitioner as
a slave for the term of six years, contrary
to the Ordinance of 1787 passed by the
Congress of the United StatesUnited States. That about the
year 1791 your petitioner was brought to
the City of St LouisSt Louis State of MissouriMissouri &
hired out by said MitchellMitchell to Edward Gay
of said City That one S. Burrel Burrel Representing
himself as the Brother in law of said MitchellMitchell
held your petitioner in his possession as a slave
& is removing your petitioner out
of the State of MissouriMissouri& beyond the Jurisdiction of your honors Court against her will
& contrary to the law in such case
made & provided and your petitioner here have
by prays to be by your honor permitted to sue in your honorable
circut for the as a poor person in behalf of
her freedom that she will ever pray &ElsaElsa Hicks HicksElsa Hicks a (Mulatto Girl being duly
sworn upon her oath says that the matters
& things set forth in the foregoing petion
are just & true

On reading & considering the above & foregoing
petition & being satisfied that the said petition contains
sufficient matter to authorize the Commencement of
a suit by the said Elsa for her freedom.
This ordered, that the said Elsa HicksElsa Hicks , be allowed
to sue upon her said Petition as a poor person
& that she have reasonable liberty to attend
her Counsel & the St. Louis Circuit CourtCircuit Court &
that she be not subjected any severity on
account of her application to institute her
said suit for freedom & that she be not removed jurisdiction of the Court & that John BJohn B KingKing
Esq be assigned her Counsel.

ElsaElsa Hicks HicksElsa Hicks complains of S
Burrell Bass & James MitchellJames Mitchell in a plea of Tresspass for false
imprisonment For that heretofore to wit on the thirty first day of January. A. D.. Eighteen hundred & fourty five 1845 the said Defendants with force & arms
then & there made an assault upon the said
ElsaElsa Hicks HicksElsa Hicks to wit at the CityCity of St Louis of St LouisCity of St Louisin the CountyCounty of St Louis
of StCounty of St Louis LouisCounty of St Louis & StateMissouri ofMissouri MissouriMissouri and then & there
beat bruised & illtreated her the saidElsaElsa Hicks
HicksElsa Hicks & then & there imprisoned her the said
Plaintiff kept & detained her the said plaintiff
in prison then without any reasonable
or probable cause whatsoever for a long
time to wit for the space of two days
last past Contrary to Laws & against the
will of the said plaintiff. And the said plaintiff
further avers that before the Grievances
above mentioned were committed
was & still is a free person of Colour
and that the Defendants did then and still holds her in slavery & therefore
she sues.

petiton & declaration
in Trespass for false
imprisonment

We command you to summonS BurrellS Burrell , and JamesJames Mitchell MitchellJames Mitchell , if they be found in your County 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 Monday
of April next, then and there to answer unto Elsa HicksElsa Hicks
of a plea of trespass for false imprisonment
to the damage of said plaintiff
dollars, And have you then there this writ.

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

Dismissed Nov. 25.184617p 375

Trespass for false imprisonment

S BurrellS Burrell and James S
Mitchell the defendants not found in
my County

To the Honourable the Judge of the
St LouisCircuit Court Circuit CourtCircuit Court a supplemental
petition of ElsaElsa Hicks HicksElsa Hicks your petitioner
represents unto your honour that the Sheriff Who
has made diligent seach cannot find Burrell
one of defts in the above suit to execute process
upon that she believes he is secreting
himself for the purpose of avoiding service
by the sheriff Your petitioner states
that said Burrell attempted to take your
petitioner out of the the StateMissouri ofMissouri MissouriMissouri
on Thursday last but
that theCaptainCaptain of the
that your petitioner was entitled to his
freedom required to take her on board of
his boat That said Burrell has sinceem
ployed some persons to your petitioner
to take your petitioner or
bound of a time
to day for the purpose of taking your
petitioner out of the StateMissouri ofMissouri MissouriMissouri
& out of the jurisdiction of Your
honor & therefore your petitioner prays that your
may issue a warrant your own to the Sheriff of the St Louis County for
your petitioner & bring her
before your honor to be dealt with as the & petioner
as in duly with
&c Sworn to & subscribed this

Whereas by the Petition of ElsaElsa Hicks HicksElsa Hicks it
is made to appear that she has instituted a suit
for her freedom in the St. LouisCircuit Court Circuit CourtCircuit Court against
SS Burrell _ BurrellS Burrell & JamesJames Mitchell MitchellJames Mitchell , which suit is
now pending & undetermined.. Whereas also
it also is made to appear from saidPetition that
said Burrel is about to remove the said
Elsa, without the jurisdiction of said Court
against her consent & Contrary to the order
of said Court. there are to Commandyou
forthwith to seize the said Petitoner if found
in your & bring her before we
all my in the Court House in
the County of St. Louis_ And also that you
summon the said Burrell & Mitchell or
[ anyother ]person in whose possesion
said Petitoner may be found_ forthwith
to appear before me at the place
afore said, then & there to bear
shall be in the or
to allow Cause against the said Petiton-

Excuted this unit in the County of St LouisCounty of St Louis on the 4th day. of February 1845 by seizing the Petitioner. Elsa named in this writ
and have her body before the Hon Jno M Krum as above com-
manded on the5th day of February 1845.- Neither S BurrellS Burrell
norJames MitchellJames Mitchell found_ WilliamWilliam Milbrun Sheriff

It is ordered that the
Sheriff of St. Louis County take possession
of the said Elsa, & during the pendency of
her said suit for freedom to hire her
to the best advantage; And it is further
ordered that the said sheriff shall take
a good & sufficientbond from the person or
person to whom he shall hire said Elsa
in the penal sum of Five Hundred ($500.) dollars
with approved Security & Conditions as
the law .