Petition, of Thomas ScottThomas Scott

, a man, of color named Thomas ScottThomas Scott ,, of St. Louis, County, state, of MissouriMissouri,
would respectfully represent, to your honor,
, that, he is not, held in bondage, as a slave,
by one James HarrisonJames Harrison , of the County and state
aforesaid,, but is advised and believes, that he
ouhgt not thus, to be held, as a slave,, and that
according to the law, of the land he is entitled, to his freedom.

In support, of his claim, for freedom, your
states the following facts,.
that said James HarrisonJames Harrison , the then owner, of , sometime in the month of augustAD 1847 hired, your petitioner, as a petitioner, to one
one St., Brain. , a trader, in new trader in New MexicoMexico., who
carried your petitioner, to said County of new
MexicoMexico, and held him,him, there in bondage, for
a period, of at least, five months. and your
petitioner,, that slavery was, not allowable
by the laws, of new MexicoMexico, at the time, he was
so carried to that County and held there in slavery,
as aforesaid,.

your petitioner, therefore submits, if these facts
be true,, whether he is not entitled, to freedom

and your honor, for leave to sue as,
a poor person,, in order to establish his
right, to his freedom according to the
.

On the hearing of the above petition I.
Lorder, - that the petitioner,
for his freedom
Thomas ScottThomas Scott . a man of colour,, belowed to sue
on giving security satisfactory to the Clerk of the
Circuit, Court. of the County aforesaid,- for all costs,
that may be adjudged. against him. in said suit-
and I further, order that said Thomas ScottThomas Scott
have reasonable, liberty to attend his counsel,
and the Court. as may require,; that
he be not removed out of this jurisdiction, of this
Court. and that he be not subject, to any severity, on
account, of his application, for freedom-
Oct. 4, 1848.

ThomasThomas scott, a man of color, plaintiff in this suit complains
of James HarrisonJames Harrison the defendant in this suit of a plea
of trespass,

For that the said defendant on the first day day of October AD eighteen hundred and forty seven
with force and arms assaulted, the plaintiff at
the county aforesaid, and then and there ill treated
him, and thene and there imprisoned, him and
kept and detained him in slavery without any
reasonable or probable cause whatsoever for a
long time - to wit- for the space of five months
then next following, contrary to the land of this state and against the will of said plaintiff

And said plaintiff that at the time of the commit-
ting of the grievances, aforesaid by said defendant he, the said plaintiff was, and still is a free person, and that said defendant held and
still holds, him in slavery

And other wrongs to the said plaintiff then and
there did against the peace and to the damage
of said plaintiff of $300 and therefore he brings his suit.

We command you
to, Summon JamesJames Harrison HarrisonJames Harrison , 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 November next, then and there to answer unto ThomasThomas
scott,, a man of Color, of a /plea of trespass
to the damage of said plaintiff Three Hundred
dollars: And have you then there this writ.

I acknowledge myself bound for all costs that may accrue in the above cause.

Plea 18 385 at refer Dec 21. 1848
18 p 459.

300
WrightWright & Bowman atto

A HamiltonAlexander Hamilton Judge 8 Judicial district cir. court Mo

Executed this writ in the County ofCounty of St Louis St. LouisCounty of St Louis, on
the 6th day of October 1848 by reading the summons,
to James HarrisonJames Harrison the within named,
defendant & also, by reading the order to him

The defendant in the above
entitled, cause will, take notice, that the depositions
of witnesses, to be used in the trial of said cause, will
be taken on Monday, the 10th day of October 1848
at the Law office of WrightWright and Bowman, South East corner,
of Pine and third streets,, in the city of St. LouisSt Louis, between
the house of Eight O Clock,A.M. and Six O
P.m. of said day said depositions to on used on part
of said plf,

Served, this notice in the County ofCounty of St Louis St LouisCounty of St Louis, on the 6th day of October 1848 delivering, a true Copy thereof to
James HarrisonJames Harrison 50 cts

to take Subpoena,
47 south fourth

You are hereby commanded, that, all excuses and delays being set aside, you personally be and appear before
the undersigned, "The Law Commissioner of Saint LouisSt Louis County," on the 7th day of October 1848 at my office in the City of Saint LouisSt Louis, to testify on the trial of
a cause now pending in the circuit court wherein,Thomas ScottThomas Scott plaintiff and
James HarrisonJames Harrison ,
defendant on the part of the defendant; and of this you are not to fail, at your peril.

75

8

600

30

15

105

1

1,15

Depositions of witnesses produced, sworn, and examined, at
the office of the law Commissioner of St Louis,, County in the City and County ofCounty of St Louis
St. LouisCounty of St Louis, State ofMissouri MissouriMissouri, before me, the, Law Commissioner for
the said Country, in a certain cause now pending in the St. LouisCircuit Court
Circuit CourtCircuit Court,
State of MissouriMissouri between Thomas ScottThomas Scott , a man of color, and
JamesJames Harrison ,
HarrisonJames Harrison , on the part of the defendant,of lawful age, being duly sworn, and
examined, on the part of the defendant, deposith, and saith,
I am acquainted, with the plaintiff,
in this case: he went, with me and from there to Sante, Fe,
He went, as my servant, he was, hired
to me, by Mr HarrisonHarrison , the defendant,
He was hired, for the trip, and
return, - I understand, him to, be the slave,
of Mr HarrisonHarrison , and as such re-
turned, him I hired, at StSt Louis LouisSt Louis Mr HarrisonHarrison , said he wished, him
to on account of, his health, and if
he would be of, any service to, me he wished, him to be making, his wages,

Cross Examined,

I hired Thomas ScottThomas Scott in August 1827 of defendant. I think I paid, for him one Hundred & thirty dollars for the trip,- I spent, a part of, the time in New MexicoMexico, - The only under-,-
standing was, that him

out, for his health, and if, he was, any
service, to me I was, to allow him wages,

I had the entire control of him,
I had TomTom , with me, in New MexicoMexico,
from five months - I did not
hire him to any one in New MexicoMexico,

I gave him permission to hire, himself
and allowed him to, have, for, his own use,
all the over and, above what - I
to Mr, - HarrisonHarrison , - He hired, him
self to, a man by the name Holt,
I think, he lived, with him for about
three, months. - In one of, these
trips, we allways spent, from five
to six, months in New MexicoMexico,

I presume Mr HarrisonHarrison knew the,
length of time I would spend,
there, as he is an old trader, The was, that if TomTom
was able to per form, service, that
I was to pay Mr Harriosn, a spece,-
fied sum. If, he was not able
to perform service, I was, to pay
nothing. - If he died on the road it was, not to be my loss. Beuts, Fort is, on the ArkansasArkansas river.

I have resided most, of the time
at Beuts Fort, - I have always,

considered St. LouisSt Louis my place of residence,
I own property, here and have always,
voted here. TomTom was with me in New
MexicoMexico, during the months a
a half, of November 1847December 1847
January, February & March 1848

Re examination

I did not have any authority from Mr.
HarrisonHarrison to permit TomTom , to hire
himself out, I did it without Mr
Harrisons knowledge or consent.

This deposition is taken by consent of
parties it notice

I. âThe Law commissioner,
of St. Louis County, do hereby certify that
St the deponent, was
by me sworn to testify the whole truth
of his knowledge in the matter in
controversy in the cause aforesaid, that
deponent was examined and his ex-
amination reduce to writing by me and
subscribed, to by said deponent in my
presence on the seventh day of Octo-ber AD 1848 at the office of The
Law Commissioner of St. Louis County.

and that this deposition was taken by
consent.

filed Dec 15. 1848

$1.15/
by defendant

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

Plea.,

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, forthwith on the 19th of December, 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 Thomas ScottThomas Scott is,
plaintiff and James HarrisonJames Harrison ,
defendant on the part of defendant,
and herein you are in no wise to fail.

Witness for the deft,

Forthwith
Executed,