Jane Cotton
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County Of St. LouisSt Louis,

Ss.

The State Of MissouriMissouri,


To the Sheriff of St. Louis County, Greeting:

We command you To Summon JamesJames A AJames A Little
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. LouisCounty of St Louis, on the third Mon-
day
of April next, then and there to answer untoJane CottonJane Cotton of her petition for freedom this day
filedto the damage of said plaintiff
dollars: And have you then there this writ.

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 fifteenth day ofFebruary in the year of our Lord eighteen hundred and forty-eight

jno RulandRuland

Clerk.

By Wm Nemmington

V. C.
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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 fifteenth day of February 1848.

EliasElias BB Smith . SmithB Smith

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Executed this writ in the County of St. LouisCounty of St Louis
February 17th 1848 by reading the writ The .
To JamesJames A AJames A Litte the defendant. The declaration
he refused to hear.

Jam. Conway Sheriff


Fee $1.00
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No 37

St. Louis Circuit CourtCircuit Court
April Term 1848

JaneJane Cotton CottonJane Cotton
vs
James AJames A Little

Summoned
Set for Freedom

A. Meturoneatto


Filed

February 15th 1848


JnoJohn Ruland RulandJohn Ruland . Clerk

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JaneJane Cotton CottonJane Cotton
vs
James AJames A Little

Petition to be allowed to sue for freedom
on motion of the plaintiff by her attorney
and is appearing to the satisfaction of the court that the pe
tition herein filed sufficient matters to authorize
the of a duit, it is ordered that said
petitioner be allowed to sue requires security satisfacto
rily to the clerks for all costs that may be adjudged against
her, and that she have redeemable liberty to attend her
counsel and the Court as may require
and that she be not removed ask of this Jurisdiction of this
court and that she be not subject to any severity on ac
count of her application for freedom.

A. True Copy

attest Jno RulandJohn Ruland , Clerk


fee $ 2
$3 p. by clerk to
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Mo. to restrain18 p 177 Mo. for attach 18 p 179Mo. overruled18 p 208. Defts
to declare & Mo. for security p 218 Rejoinder in demr, 18 p 255
Withdrawn & plea filed 18 p 260Plea withdrawn. & demr.. with heretofore
recalled &.18 p 262. Demr suit leave to amend & at Plff
costs, 18 p 266 Mo. sec. withdrawn. 18 p 279 clerk: Mo for security18 p 369, Amended declaration filed 18 p 384Motion
for security ordered within ten days or suit dismissed18
p 389.
Dismissedfor want of security at
plff & exn Dec 4/48 18 p 421

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To the Honorable
AlexanderAlexander Hamilton HamiltonAlexander Hamilton , Judge of the
Circuit CourtCircuit Court of St. Louis County.

The Petition of Jane CottonJane Cotton Respectfully
she with:- that she is now held in slavery by
one James AJames A .
Little in the city and CountyCounty of St Louis
of St. LouisCounty of St Louis when she and has a right to be free.
And in order to establish this right, she prays
to be allowed to [ suo ], for the recovery of her
freedom in your Honorable court, and
for the following grounds, on which her
claim of freedom is founded, to wit
she
she was born free as she believes, in the Ter-
ritory of IllinoisIllinois; and two years after this Territory
had been admitted into the union as a
free state, she was brought for into
Boonsville MissouriMissouri, where slavery was by law permitted,
which Territory of MissouriMissouri, was, when ad-
mitted
into the union, was thus admitted
as a slave state; and the bringing of your
petitioner from a free state to a Territory,
was when she was in infancy and without
knowledge of her rights, and when she
had no one to protect her; and since she was
thus brought into MissouriMissouri she has been
wrongfully held as a slave, and is still so
held by one James AJames A Little a resident
of Fourth Street, in the city of St. LouisSt Louis
your petitioner further states that she
was carried to AlabamaAlabama within or to ArkansasArkansas after she was brought to MissouriMissouri
and she is not able to set forth any more facts and
particulars to sustain this application, but
relives upon the testimony which will
be addressed in the cause, and the
necessity of her witnesses; and your

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Petitioner will on pray &c

JaneJane her

x

mark Cotton
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State of MissouriMissouri
County of St. LouisCounty of St Louis

ss

Personally came
before the undersigned, a Justice of the
Peace within and for the County afore-
said,
JaneJane Cotton CottonJane Cotton , without having been
duly sworn, after the petition had
read and by her fully understood
, and made oath that the facts and all
the particular are true, to the best of
her knowledge and belief.

JaneJane her

x

CottonCotton mark
Sworn to and Subscribed
Before me this

15th day of February

1848


Justice of the Peace

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Witnesses for Plaintiff, a complainant.
1.JacobJacob CarrCarr
2.Darcy Wileman,
3.BenjaminBenjamin Philips Esqr.
4.RebeccaRebecca Rittenhouse-
5 John Woods
6 Old Mrs. still
all in St. Louis County about six miles

South of Belleville, IllinoisIllinois.

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Jane CottonJane Cotton
vs
James AJames A . Little

Petition in C. Court

A. Witmore
atty for plaintiff.

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Jane CottonJane Cotton
vs
James AJames A . Little

Motion
In Circuit CourtCircuit Court
Feburary 18. 1848.

Now comes the complainant by her
attorny, and suggests to the court the follow-
ing facts; that at the time that the order
of this court was made, allowing the com-
plainant to sue as a poor person for her
freedom, she had been by the defendant
committed to the jail of St. Louis County,
on the official commuttioned of Justice
JohnsonJohnson ; and that when the said Little
had been apprized of the application of the
complainant for the order aforesaid, and
after it was made, she he took the said
Jane CottonJane Cotton out of Jail and conveyed
her away JeffersonJefferson Baracks with
a of shipping her off beyond the
jurisdiction this court. Therefore she by her attorny, moves that an order
be made, that the said Little have
the said plaintiff within the jurisdic-
tion of this court; that âshe be at liberty
to attend her counsel and the court as occasion may require and that she be
not removed out of the jurisdiction of
this court,â; and that such order be by
this court made that she shall not
be any longer subject to any or further
security on account of her application
for freedom.

Alphonso WitmoreAlphonso Witmore
attorny for
complaint.

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Jane CottonJane Cotton
vs
James AJames A . Little

Motion in Circuit CourtCircuit Court .

Filed

Feb 18th 1848


Jno RulandJohn Ruland clerk


filed 177
numbered 208
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Jane CottonJane Cotton
vs
James AJames A . Little

In the Circuit CourtCircuit Court of St. Louis
County, In Chounry.
St. LouisSt Louis Feburary 18th. 1848.

Motion for attachment for contempt.
Now comes the complainant in this case and
files her motion by attorny, and moves the
court to attach the defedant for contempt
of this court in in refusing the obediance to
the lawful order of the court, and in this that
when he was required by said order to allow the
petitioner to be within the jurisdiction of the
Court to prosecute her suit for freedom, and
to have reasonable liberty to attend her counsel
and the court, as occasion may require; and
that she be not removed from the jurisdiction
of the court, and that she be not subject to
any severity on account of her application
for freedom. He said Little did remove and covered her and it appearing that the said
James AJames A Little has violated and disobeyed this
order, she by her attorney now moves, the
court to attach the said Defendant. to show
cause why he has so disobeyed the said order
of court; and that such other proceedings,
may be had in the case as may be legal
suit and equitable in the premisis.

Alphonso WitmoreAlphonso Witmore

Atty for complainant,
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Jane CottonJane Cotton
vs
James AJames A . Little

Motion to punish for contempt

Filed

Feb 19th 1848


JnoJohn Ruland RulandJohn Ruland Clerk


filed 179
number 208
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Jane CottonJane Cotton
v.
James AJames A . Little

Circuit CourtCircuit Court
April Term 1848

And now comes James AJames A . Little
who had been served with process in the above
entitled case, and , that the declaration
in this case is not sufficient in cause,
wherefore he prays judge &c

TaylorTaylor
for Little

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And moves the cause for a rule on the
plaintiff to furnish additional security-
in, this Cause for the reason that she person
whose name seen submitted for
security is , and is wholly im-
possible.

TaylorTaylor

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Motion Withdrawn May 6 1848

Jn RulandJohn Ruland clk

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241761

188291

53470

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CirCircut Court :CourtCircut Court
Apr:Febru 1848

Jane CottonJane Cotton
v.
James AJames A . Little

Demurres to dec=
laration, and
Motion for security
for cont.

filed April 17th 1848

Jno RulandJohn Ruland Clerk

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TaylorTaylor pq.
Withdrawn May 1st 1848.

Jn RulandJohn Ruland
Refiled

May 2 1848x

Jno. RulandJohn Ruland

ck
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County of St. LouisCounty of St Louis,

ss.

The State of MissouriMissouri,


To RichardRichard
Samuel WilliSamuel Willi
Greeting:

You are hereby commanded, that setting aside all manner of excuse and delay, you appear be-
fore our Circuit CourtCircuit Court for the county aforesaid, onthe Saturday 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 Jane CottonJane Cotton plaintiff andJames AJames A . Little defendant on the part of Little and herein you are in no wise to fail.

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 20 day of April in the year of our Lord one thousand eight hundred and forty-eight

Jno RulandJohn Ruland

Clerk C. C.
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Executed this writ April 21th 1848

PaulPaul . Conwey Shff


Fee $1.00
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22 April

Cir: Co
of: 48

Jane CottonJane Cotton
vs.
James AJames A . Little

witnesses for def
for Saturday next

ricch., Douluig


.Saw: Nilli

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County of St. LouisCounty of St Louis,

ss.

The State of MissouriMissouri,


To Samuel WilliSamuel Willi , Richard Dowling
Greeting:

You are hereby commanded, that setting aside all manner of excuse and delay, you appear be-
fore our Circuit CourtCircuit Court for the County aforesaid, on the 29th: of April
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, whereinJane CottonJane Cotton plaintiff and [ Jam ] A. Little defendant on the part of defdt, and herein you are in no wise to fail.

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 28 day of April in the year of our Lord one thousand eight hundred and forty-8

Jn. RulandJohn Ruland

Clerk C. C.
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Executed April 29th 1848

Jam. Conway, Shff

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Cir: Co:
ap: Term1848

Jane CottonJane Cotton
vs
Jam: A. Little

Witnesses for Saturday
29. April

X Samuel WilliSamuel Willi


X Richard: Dowling

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County of St. LouisCounty of St Louis,

Ss.

The State of MissouriMissouri,


ToAlphonso WitmoreAlphonso Witmore , Louis MartinLouis Martin
WilliamWilliam Kirk, Charles CollinsCharles Collins &AndrewAndrew Hooper.
John Stephenson
Greeting:

You are hereby commanded, that setting aside all manner of excuse and delay, you appear be-
fore our Circuit CourtCircuit Court for the county aforesaid, on the3rd day of May 1848
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,
whereinJane CottonJane Cotton is
plaintiff and James AJames A . Little is defendant on the part of the plaintiff and herein you are in no wise to fail.

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 29th day of April in the year of our Lord one thousand eight hundred and forty-

Jno. RulandJohn Ruland

Clerk C. C.
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Executed except AndrewAndrew
Hooper.

Laurel owner Shff

By Job Brown Dpy.

Fee $2.20
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3 May
Jane CottonJane Cotton
vs
James AJames A . Little

Subpoenae

A. Witmore

(2c)

X Louis MartinLouis Martin


W. Kirk


Chr. CollinsCollins


And. Hooper

==

John Stephunson

=
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JaneJane Cotton CottonJane Cotton
vs
James AJames A . Little

in CircuitCircuit Court CourtCircuit Court

Now comes the plaintiffs by allowing
and in the .

Alphonso WitmoreAlphonso Witmore
atty for plaintiff.

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Jane CottonJane Cotton
vs
James AJames A . Little

Rejoinder

Filed

April 29 1848


Jno. RulandJohn Ruland clk

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Answered Declaration

Jane CottonJane Cotton (a free person of colour
complains of JamesJames A AJames A Little of a plea
of trepass and false imprison
-ment for that when as heretofore
to on the fourteenth day of
February in the year of our
Lord one thousand eight hundred
and forty-eight with the said
defendant with force and arms
took & dragged the plain
tiff, and then and there im-
=prisoned her, the said defend
ant and kept and delivered her
in prison a long space of
time to wit for the space, of
months against the will
of the said plaintiff the
plaintiff sworn that before and
at the time of the said trespass
and false imprisonment by the
said defendant as aforesaid
was and now is a free person
and that the defendant did
then and now holds her in
slavery to the
of the said plaintiff five hund
=dred dollars

for the
Alphonso WitmoreAlphonso Witmore
plff attorny

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Jane CottonJane Cotton ,

James AJames A . Little,

- -
Filed 1848

Nov 20. 1848


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Jane CottonJane Cotton ,
James AJames A .,
Little,

Cis. Court,
Nov Term, 1848

and now comes the defendant, and defends, the demand,
of the plaintiff,

L. R. Taylor,

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Cis. Court,
Nov Term, 1848

Jane CottonJane Cotton ,

James AJames A . Little,

Plea, for defendant,

J., R. Taylor,


Filed

Nov. 21. 1848


J RulandJ Ruland ck

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Jane CottonJane Cotton ,

James AJames A Little,

Cis. Court,
April 1848

And, now comes,
the defendant, and defends the demand of the plaintiff.,

TaylorTaylor ,

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Circuit CourtCircuit Court of,
apr 1848

Jane CottonJane Cotton ,

James AJames A . Little

Plea, for defendant,

TaylorTaylor ,


Plea, with drawm,

May 2 1848.


filed,

May 1. 1849

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move the court for additional security, for costs, in
the case of Jane CottonJane Cotton , by James AJames A Little, on
account, of the insolvancy, of B.smith the
present security. TaylorTaylor , is counsel, for dft.

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Jane CottonJane Cotton ,
vs.
James AJames A Little,

In The circuit Court, of
St. LouisSt Louis county;- action of trespass,
for False Imprisonment,.

now comes Jane CottonJane Cotton the complainant,
and the plaintiff in the case, and makes comm-,-
plaint, by attorney complaint,;

For that, whenas the said defendant,,
heretofore, to wit; on the fourteenth day of february, anno Domini, Eighteen hundred and forty eight, did at the county, of St.LouisSt Louis in,
the state of MissouriMissouri, violently, and with
force hold and keep the said plaintiff and
camplainant, Jane CottonJane Cotton , imprisoned, as a
slave; and that he now does hold and
keep her this plaintiff and complainant as
a slave where she, the said, plaintiff and
complainant is a free person of color; and
that the said defendant did before the
date hereof and does, now falsely, imprison complainant, as a slave, when she is a
free person,; and this the plaintiff is ready
to verify,; and therefore she brings this suit
for the recovery of her freedom, being now, as
heretofor, held as a slave

Alphonso WitmoreAlphonso Witmore attorny, for plaintiff