Peggy Perryman, a woman of color v. Joseph Phillippi (Philibert)
View original image: Page  001
[missing figure]

To, the Hon Alexander HamiltonAlexander Hamilton Judge, of the St Louis, County Circuit CourtCircuit Court ,

the petition of Peggy PerrymanPeggy Perryman respectfully represents that on or about the first of december past, - - she was residing, with her friends, in ArkansasArkansas,
in the peaceable enjoyment, of her freedom and
civil rights, to which she was enitled by her parents,by being free persons, her father, a free
person of color, in said state, and her mother was lawfully married, to her her father, an Indian of, the Black foot tribe Your Petitioner represents,
that about that time she was suddenly seized,
by persons, to her before unknown gaged, and transported, and finally sold into servitude that, her her relatives, by the mother side and, all not,
only free since, the memory of man but are distinguished, among their tribe, your
petitioner represents as such free born person she, is entitled, to her freedom from the engagement of which she is, wherefore she prays, in considerationof the promises she, may have leave, to sue,
as a poor person, in order to establish,
her right, to freedom and that counsel, to her for that purpose, order be made, as to secure
of prosecuting, her said, as in duty bound she,

PeggyPeggy , her

X

pPrryman,1848

HowardHoward

View original image: Page  002
[missing figure]

by the court, in the,

petition, shall during
suit have reasonable liberty of all and the court that she and,, of the state or jurisdiction that she shalln not be subject to any severity on account of her application,
for her freedom,
and that she be permitted to sue, as a poor person,

A Hamilton,


.

View original image: Page  003
[missing figure]
Peggy (of color)

JosephJoseph

In the circuit court,
of saint louis county,
April term, 1848

And this day comes the defendant and his, attorneys and moves the court, to dismiss the above potential suit, for the
following reasons

1st given
the commandment of , for casts might be
against for the as
is required the

2d Because no attorny, is given
the of statute to permit such a,
suit of one held as, a as a poor
person

3rd because, no suficient, reason
is for to make it,

4th because there, is in fact no suit pending for want of sufficientprocess

5th because there, is no unit,.

6th because there, is no service,.

Field + Hall

Attys for Deft.
View original image: Page  004
[missing figure]
PeggyPeggy (of color)

JosephJoseph Phillippi

Motion to Dismiss
& reasons,

Field, Hall


attys for deft, filed,june 15. 1848

JN RulandRuland clk,

View original image: Page  005
[missing figure]

In Circuit, court of
Saint LouisSt Louis County,November Term 1848

StateMissouri, ofMissouri MissouriMissouri,
County of saint Louis,

Peggy PerrymanPeggy Perryman ,
a free woman, of color, complained of
JosephJoseph Philibert, of a plea, of trespass,
for false imprisonment, for that whereas heretofore to wit, at the city and county of saint louis, and state of missouri, as about,
the spring of the year one thousand eight hundred and forty seven as your petitioner recollects, the said JosephJoseph Philibert drendant aforesaid then, and there with, force and arm assaulted, the said PeggyPeggy and her the,
said PeggyPeggy then, and there took, and
imprisoned and restrained, her of her liberty,
and her the said PeggyPeggy held in servitude from,
the spring of the year 1847 at which time, as your
petitioner, is informed the said defendant,
purchased her from one Bartley untill, the present time,
and still holds her in servitude, without any
reasonable or probably cause, against the
law, of the land and against the will of her, the said PeggyPeggy , and that she PeggyPeggy , before and at the time of the, said greivances was, and still, and that the said defendant holds her in servitude,, and servitude,
and to the great damage, of
and therefore, she sues,


View original image: Page  006
[missing figure]

to dismap suit 18p 347.

View original image: Page  006
[missing figure]
No

St LouisSt Louis Circuit,
April Term, 1848

PeggyPeggy , (of color)
vs.
JosephJoseph Philibert,

Trespass for false imprisonment,

Filed June,1848

Jno RulandJohn Ruland
clk


View original image: Page  006
[missing figure]

Executed this order of Court by reading, it and the
Petition and declaration to JosephJoseph Philibert in the
County of St LouisCounty of St LouisApril 28th 1848

SamuelSamuel Sheriff


By

Deputy

View original image: Page  006
[missing figure]

Service 50
Copy
1,10

View original image: Page  007
[missing figure]

To the Hon Alexander HamiltonAlexander Hamilton , Judge of the St Louis County Circuit, court

The Petition, of Peggy PerrymanPeggy Perryman respectfully represents, that on or about the
first day of december 1845 She residing with, her friends, in ArkansasArkansas, in the
enjoyment, of her freedom, and and civil rights,
to which she was entitled, her parents being,
free persons, her father, a free person of color, of
color in said state, and her mother who
was lawfully married, to her father an
Indian, of the Black Foot tribe. your
petitioner represents, that about that time
She was suddenly seized, by persons to
her before unkown, gaged and transported,
and finally sold, into servitude, that
her relatives, by the mother side and all not only
free since, the memory, of man, but and distinguished, among their tribe, - your
Petitioner represents, as such free person, she
is to her freedom from at
which she is now restrained, by JosephJoseph Philibert Wherefore, she
prays, in consideration, of the promises, she
may have had to sue as a poor person, in order to establish, her right to freedom
and that counsel, may be to her for
that, purpose and that such order be made
as to secure, her in the privelege, of presenting,
her said claims and, as in duty bound, she
will pray

PeggyPeggy ,

X

Perryman,

Sworn, to Subsribed, before me to this 5th of july 1848.

P.J. HowardHoward clk Criminal Court

View original image: Page  008
[missing figure]
View original image: Page  009
[missing figure]
Peggy of color vs Philibert,

Cicuit CourtCircut Court of St. Louis County,
November Term, 1848


Defendant comes and defends the,
of the said plaintiff,


Dory Field + Hall Attys for Deft
View original image: Page  010
[missing figure]
PeggyPeggy , ( of, color)
Philibert,



Atty for Dept

Filed,nov. 20. 1848

clk


18p 386
View original image: Page  011
[missing figure]
No 255

Saint Louis Circuit CourtCircuit Court November Term 1848

PeggyPeggy perryman(of color)vsjoseph phi libert,

suit for freedom

filed December,5, 1848

summons to april 1849

View original image: Page  011
[missing figure]

plaintiff attend counsel, to 19 p 26
motion to dismap,.

View original image: Page  012
[missing figure]
View original image: Page  013
[missing figure]

In Circuit CourtCircuit Court of St., Louis County nov T, 1848

State of MissouriMissouri, County of St LouisCounty of St Louis

Peggy Perry,man a
free woman of color complains, of JosephJoseph Philibert, of a plea of trespass, for false imprisonment, for that whereas the city and county of St LouisSt Louis and
State of MO during,, the spring of 1848,
as as your petitioner presents,
the said JosephJoseph Philibert, Defendant
then and there, with force and, arms
assaulted, the said PeggyPeggy , and then and there took, and imprisoned, and
restrained, her of her libery, and her the
said PeggyPeggy , held in servitude, from
the from the spring of, the year 1847 at which time as your said petitioner
the said deft, her from one BartlettBartlett ,
untill the present time, and still holds
her in such servitude without, any
reasonable, or probable cause, aganist
the law, of the land and against the will of her, the said PeggyPeggy , and the said
further and that before
and at the of the committing of the
said greivances, was and still is a free person, that the said Deft, held and still
holds her in servitude and, slavery against
the and to the great, damage of,
the said PeggyPeggy , therefore she sues,

Peggy PerrymanPeggy Perryman ,

View original image: Page  014
[missing figure]

It is ordered by the court in the
within, cause that the petitioner,
shall be allowed to sue as a poor person, and shall during, the of will have reasonable, liberty of attending
her counsel, and the court, and that
she, shall not, be removed, out of
the state, or jurisdiction, of this court,
and shall not be subject, to any
severity, on of of her application,
for freedom and that she is permitted, to sue, as a poor person

Personally, and
says that Peggy PerrymanPeggy Perryman is,
a poor person and unable to
prosecute her suit but as a poor, person

to this 4th day ofDec 1848

View original image: Page  015
[missing figure]

In Circuit CourtCircuit Court of St Louis County,nov 1848


State of MissouriMissouri,
County of St LouisCounty of St Louis,


Peggy PerrymanPeggy Perryman a free woman of color complains of JosephJoseph Philibert of a plea of Trespass, for false imprisonment for that, at the city and County of St LouisCounty of St Louis and State of MO during the spring of 1847, your petitioner recollects the said JosephJoseph Philibert defendant then, and there, with force, and arms assaulted, the said PeggyPeggy , and then, and
there took, and
imprisoned, and her of her liberty and her, the
said PeggyPeggy held in serviude, from
the spring of the year,1847 at, which
time the present, time and still holds her, in such servitude without any reasonable or probably casue against,
the law of, the land and against, the will of her, the PeggyPeggy , and she, the said further, and declares that she before,
and at the time, of the committing of, the
said greivances, was and still, is a free person and, that the said Deft, held and still,
holds her, in servitude and slavery against,
the will of, and and to the great damage of the said PeggyPeggy , and therefore she sues,

Peggy PerrymanPeggy Perryman ,


View original image: Page  016
[missing figure]

It is ordered, by the court, in the
within case that the petitioner shall be allowed,, to sue as a poor person and shall, the of this suit have reasonable liberty of attending her counsel and, the court and that she shall not be removed out of the state of or jurisdiction of this court,
and shall not be subject to any severity on account of her application,
for freedom and that she be permitted to sue, as a poor person,

Personally


to 4th day ofDec 1848

clk

View original image: Page  017
[missing figure]

County of St. LouisCounty of St Louis, Ss.

The State of MissouriMissouri,

To the Sheriff of St. Louis County, Greeting:

We command you To Summan JosephJoseph
Philibert 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 next, then and there to answer unto PeggyPeggy Perryman
PerrymanPeggy Perryman (ofcolor) of her petition for
freedom. filed V dr3th 1848.
And have you then there this writ.

[missing figure]
Wintness, John RulandJohn Ruland , Clerk of our said Court, with the seal thereof hereto affixed, at office, in the
city of St. LouisSt Louis, this 18th day ofDecember in the year of our Lord eighteen hundred and forty Eight

John RulandJohn Ruland Clerk.

View original image: Page  017
[missing figure]

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

[missing figure]
View original image: Page  018
[missing figure]

Excuted this unit in the county of St. LouisSt Louis on the 19th day of December 1848 by reading it to JosephJoseph Phili, bert said County
and further executed the same on the same day by
offering to read the declaration to the said JosephJoseph Philibert,
which he refused to hear

Louis T LabeaumeLouis T Labeaume Sherrif


By

Sein Fremon dept

Service $ 1 00
View original image: Page  019
[missing figure]

County of St. LouisCounty of St Louis, ss.

The State of MissouriMissouri,


To John /CalverbGreeting:

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 25th January
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 PeggyPeggy Parryman is
plaintiff and Jos. Philibert
defendant on the part of plaintiff
and herein you are in no wise to fail.

[missing figure]
Witness, WilsonWilson Primm, Clerk of our said Court,
with the seal thereof hereto affixed, at office, in the
City of St. LouisCity of St Louis, this 20th day ofJanuary in the year of our Lord one thousand eight hundred and forty-7

Milen ePrimm

Clerk C.C.
View original image: Page  020
[missing figure]
Nov. D. 1848
Peggy PerrymanPeggy Perryman vs.Jos. Philibert

John Calnent


( for 39)
View original image: Page  020
[missing figure]

Executed this 24th day of January 1849

L. J. Labeume shiff


By

fee 50 Coues Town this uag rz
View original image: Page  021
[missing figure]
Peggy PerrymanPeggy Perryman ,
vs
Philibert,

In the St Louis Circuit CourtCircuit Court ,
November 1848




,


View original image: Page  022
[missing figure]
Peggy PerrymanPeggy Perryman ,vs Philibert,

Motion to dismiss,

Filed February 9th 1849February 9th 1849

WilsonWilson Primm ck

View original image: Page  023
[missing figure]
Peggy PerrymanPeggy Perryman
vs
JosephJoseph ,
Philibert,

In the Circuit CourtCircuit Court
of St. LouisSt Louis country
April Term 1849

me said defendent comes and defe
the demand, of plaintiff,

Hall

attys for Deft,
View original image: Page  024
[missing figure]
Peggy PerrymanPeggy Perryman
vs
JosephJoseph Philibert

plea

Field + Hall


Attys for deft Filed april 17 1849

WilsonWilson Primm, clerk


99
View original image: Page  025
[missing figure]
Peggy PerrymanPeggy Perryman ,
vs JosephJoseph Philibert,

In the st louisSt Louis circuit court
April 1849

it this an
the 9th day of February 1849 the said defendant, is the his and

to an
the 6th day of is the is the 1849 the came an
whan the upon which of the
is the
and
at the
and this of he
and a
of is the
a 20th day of nov. 1848
and on the 17th day of april 1849
his of upon
is

View original image: Page  026
[missing figure]
Peggy PerrymanPeggy Perryman ,
vsJosephJoseph Philibert,

Bill, of Exceptions,

filed oct 6 1849

M. S. CerreM S Cerre clk

View original image: Page  027
[missing figure]

County of St. LouisCounty of St Louis, Ss.

The State Of MissouriMissouri,

To john Calverb-Batiste sr.
Greeting:

You Are Hereby Commanded, that setting aside manner of excuse and delay,
you appear before our Ciruit Court for the County aforesaid, on the 18th february 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 Peggy PerrymanPeggy Perryman , is
plaintiff and JosephJoseph Philibert, is
defendant on the part of plt,
and herein you are in no wise to fail.

[missing figure]
Witness, Michael S. CerreMichael S Cerre , Clerk of our said Court,
with the seal thereof hereto affixed, at office, in the City of St. LouisCity of St Louis, this 9th day of Fenruary in the year of our Lorde one thousand eight hundred and fifty

M SM S Cerre CerreM S Cerre

Clerk, C.C.
View original image: Page  028
[missing figure]

Circuit courtNov 1849

Peggy PerrymanPeggy Perryman ,vs Jos Philibert,

+ Mo Calvers

Mon. Batislean

( 12 no 488)
View original image: Page  028
[missing figure]

Excuted on Calvers,

L Labeaume,


fee 60
View original image: Page  029
[missing figure]

County of St. LouisCounty of St Louis, ss.

The State of MissouriMissouri,


To Curtis Kennedy
ReubenReuben BartlettBartlett
Broadway 292
neune placeGreeting:

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 18th day of February 1850 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 Peggy PerrymanPeggy Perryman is
plaintiff and Philibert is
defendant on the part of Deft,
and herein you are in no wise to fail.

Witness, M. S. CerreM S Cerre 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 11th day of February in the year of our Lord one thousand eight hundred andfifty

M. S. CerreM S Cerre

Clerk C.C.
View original image: Page  030
[missing figure]
PeggyPeggy vsPhilibert

for Deft,

View original image: Page  030
[missing figure]

Executed on
BartlettBartlett the other
not found

L T Labeaume shff


fee 60
View original image: Page  031
[missing figure]

County of St. LouisCounty of St Louis, Ss.

The State Of MissouriMissouri,


To John CalvertJohn Calvert Mon Batiste
Greeting:

You Are Hereby Commanded, that setting aside all manner of excuse and delay,
you appear before our Circuit CourtCircuit Court for the County aforesaid, on the 25//-
Feb1850 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 PeggyPeggy ,
is plaintiff and Jos,
Phillibert is
defendant on the part of
and herein you are in no wise to fail.

[missing figure]
Witness, Michael S. CerreMichael S Cerre , Clerk of our court,
with the seal thereof hereto affixed, at office,
in the City of St. LouisCity of St Louis, this 13//- day of Feby in the year of our Lord one thousand eight hundred and fifty

M. S. CerreM S Cerre

Clerk, C.C.
View original image: Page  032
[missing figure]
PeggyPeggy (of color
vs
Jos. Phillibert-

for peff

Mo CalvertCalvert


Mon Batiste.

View original image: Page  032
[missing figure]

Executed on
Calvert Batiste
not found

Louis T LabeaumeLouis T Labeaume shff


Fee 60
Ent 72.
View original image: Page  032
[missing figure]

60

10

100

60

60

50

3.40

1.20

4 60

View original image: Page  033
[missing figure]

County of St. LouisCounty of St Louis, Ss.

The State Of MissouriMissouri,

To Curtis Kennedy, Reuban Bartlett,Greeting:

You Are Hereby Commanded, that setting aside all manner of excuse and delay,
you appear before our Circuit CourtCircuit Court for the County aforesaid, on the 25Feby 1850 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 PeggyPeggy of color,
plaintiff and Jos. Philibert,
defendant on the part of deft,
and herein you are in no wise to fail.

[missing figure]
Witness, Michael S. CerreMichael S Cerre , Clerk of our said Court,
with the seal thereof hereto affixed, at office, in the City of St. LouisCity of St Louis, this 13 day ofJuly in the year of our Lord one thousand eight hundred and fifty

M. S. CerreM S Cerre

Clerk, C.C.
View original image: Page  034
[missing figure]
PeggyPeggy vs Phillibert,

for for deft,

R. Bartlett,

Curtis, Kennedy

View original image: Page  034
[missing figure]

Served, this subpoena, in the county
of St. LouisSt Louis on the 18th day of feby 1850

LouisLouis T Labeaume T LabeaumeLouis T Labeaume shff,

By

Fees 1.00,
View original image: Page  035
[missing figure]

County of St. LouisCounty of St Louis, Ss.

The State Of MissouriMissouri,


To Batiste Chouteau
Greeting:

You Are Hereby Commanded, that setting aside all manner of excuse and delay,
you appear before our Circuit CourtCircuit Court for the county aforesaid, on the 18th March 1850at the city of St. LouisSt Louis, then and there to
testify, and the truth to say in a certain matter of controversy now pending in our said Court,
wherein Peggy PerrymanPeggy Perryman is
plaintiff and Philibert is
defendant on the part of plaintiff
and herein you are in no wise to fail.

[missing figure]
Witness, Michael S. CerreMichael S Cerre , Clerk of our court,
with the seal thereof hereto affixed, at office,
in the City of St. LouisCity of St Louis, this 13th day of march in the year of our Lord one thousand eight hundred and fifty

M. S. CerreM S Cerre

Clerk, C.C.
View original image: Page  036
[missing figure]
Perryman
vs
Philibert

spa
Batiste Charleau

not found

Louis T LabeaumeLouis T Labeaume , shff


tea 10cts