Julia Ann Shaw v. Augustus H. Evans
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457

In the St LouisCircuit Court
Circuit CourtCircuit Court
February Term A.D. 1860

JuliaJulia Shaw ShawJulia Shaw
vs
AugustusAugustus HH Evans .EvansH Evans

Petition for Freedom

Filed Jany 16th 1860

S Rice Clk

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leave to sue as poor person

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Julia ShawJulia Shaw
plaintiff
v
AlexanderAlexander Augustus AugustusAlexander Augustus H. EvansH Evans
Defendant

In the St LouisCircuit Court
Circuit CourtCircuit Court
February Term A.D. 1860

Plaintiff states that she is
entitled to her Freedom: that she was born
in the city of St LouisSt Louis & State of MissouriMissouri
and was born free; that the Defendant
AlexanderAlexander Augustus AugustusAlexander Augustus H. EvansH Evans holds her unlawfully
in slavery

She prays therefore that this
Honorable Court by a suitabledecree will release her him from
the servitude aforesaid and set him her free; and she
prays that she be allowed to sue as a poor
person, and that this Court will make
an order on the said AlexanderAlexander Augustus AugustusAlexander Augustus H. EvansH Evans
that the Plaintiff have reasonable liberty
to attend her counsel and this Court as
occasion May require, that she the Plaintiff
be not removed out of the jurisdiction of
this Court, and that she the Plaintiff be
not subject to any severity on account,
of this her application for Freedom:
and that this Honorable Court will grant
unto him her such other and further relief
as unto the Court may seem right and proper

John JacksonJackson C.C.CarrollCarroll p.q.

John JacksonJackson agent of the Plaintiff
makes Oath and says that the matters
and things contained in the above petition
as therein stated he believes to be true

Subscribed and Sworn to
before me this 21st Jany 1860

S. Rice Clk
John JacksonJackson

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In the St. Louis Circuit CourtCircuit Court
September Term 1859.
Saturday January 21st 1860.

Julia ShawJulia Shaw
vs
AugustusAugustus H. EvansH Evans

Petition for Freedom,
Now comes the plaintiff by
her attorneys and files a petition
for freedom, and the Court be
ing of opinion that the said petition contains sufficient
matter to authorize the commencement of a suit doth
order that the said petitioner be allowed to sue as a poor
persons and that she have reasonable 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,
and be not subjected to any severity on account of her
application for freedom.

State of MissouriMissouri
County
S.S.

I, StephenStephen Rice, Clerk of the
St. Louis Circuit CourtCircuit Court,
within and
for the County aforesaid certify the foregoing to be a true
and correct copy of the order in the above entitled cause
as fully as the same remains of accord in my office.

In testimony whereof, I hereto set my
hand and affix the seal of said Court,
at office in the City of St. LouisCity of St Louis this 21st day of January A D 1860

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Feby T. 60 agreement filed next friend & guard ad litemapptd acceptance filed29 p 316.
Cont.on afft pltffs Costs 30p 57. Contd on afft 30p 323. Contd by consent 30p 598.
leave to file and pet 31 p 59. Mo to strike out amendedansoverd and
cause contd 31p 386. Sept T 1862 Continued for want of evidance of O
Bennett31p 509. Feby 13 1863 Compulasory nonsuit

A Comp nonsuit

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No 457

St. Louis Circuit CourtCircuit Court.
February Term 1860

JuliaJulia Shaw ShawJulia Shaw by Jno
JacksonJackson nextfriend& guardian ad
litem.Pet Sums
v 21 of January 1860

AugustusAugustus HH Evans EvansH Evans
Pet for freedom

Issued 20 of Jany 1860
S Rice Clerk
JJacksonJackson Security for Costs.
Copies due Clerk. 50

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Excuted this writ in the County of StCounty of St Louis
LouisCounty of St Louis on the 21 day of January 1860 by
delivering a copy thereof and of the Petition
as furnished by the Clerk to
the within named defendant

Fee 100

Thomis Sheriff
B

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The State of MissouriMissouri,
County Of St. LouisSt Louis,
SS.

To The Sheriff Of St. Louis CountyâGreeting:

We command you to summon
AugustusAugustus HH Evans EvansH Evans
to appear
before the Judge of our Circuit CourtCircuit Court , on the first day of the next Term thereof, to be
held in the City of St. LouisCity of St Louis, within and for the County of St. LouisCounty of St Louis, on the
First Monday of February next, then and there to answer the
complaint of
JuliaJulia Shaw ShawJulia Shaw
as set forth in the annexed petition: and have you then there and this writ.

Witness, StephenStephen Rice, Clerk of our said Court,
with the Seal thereof, hereto affixed, at office in the City ofCity of St Louis
St. LouisCity of St Louis, this >20 day of Jany in the year of our Lord, eighteen hundred and - Sixty

StephenStephen Rice

Clerk,
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I acknowledge myself bound for all costs that may accrue in the case of JuliaJulia Shaw
ShawJulia Shaw against AHH Evans EvansH Evans
Witness my hand and seal, at St. LouisSt Louis, this 21 day of Jany 1860

John JacksonJackson

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Circuit CourtCircuit Court

Julia Shaw
vs
AugustusAugustus HH Evans EvansH Evans

Answer of
defendant.

Filed Feby 11 1860

S Rice Clk

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Julia ShawJulia Shaw
v
AugustusAugustus H. EvansH Evans

In the St LouisCircuit Court
Circuit CourtCircuit Court .

Defendant for answer to the
petition of plaintiff states and says as
follows. He denies that plaintiff is entitled
to her freedom. He denies that plaintiff
was born free. He admits that plaintiff
was born in the City of St LouisCity of St Louis but
states and avers that defendant at the
time of her birth owned the mother
of plaintiff as his slave, and that
said plaintiff was born while his
mother was the slave of defendant
that he never set the defendant
free and that the said plaintiff now
is and has always been a slave.
He states that the mother of plaintiff
ran her off out of this state several
years ago and pretended that she
said plaintiff was dead, and so
soon as he knew of plaintiffs return to this
state he caused her to be apprehended
as his slave and lodged in jail for
safe keeping and which in jail tha plain
tiff obtained leave to bring this suit- Defendant
asks to be hence discharged & C.

Johnson & Tucker

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State of MissouriMissouri
County

AugustusH. EvansH Evans
being sworn states that the foregoing
answer and the matter therein as
stated he believes to be true.

Sworn to & subscribed before
me this 11 day of Feby 1860.

S. Rice Clk

A.H EvansH Evans

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In the St. LouisCircuit Court
Circuit CourtCircuit Court:
Feb Term A.D. 1860

IshamShawShaw
v
AlexH. EvansH Evans
&
Julia Ann Shaw
vs
Same

Affidavit for a
continuance to apply
to each of the above
cases.

Filed May 15 1860

S. Rice Clk

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IshamShaw &
JuliaAnn Plaintiff
v
AugustusAugustus H. EvansH Evans
defendant

In the St. LouisCircuit Court
Circuit CourtCircuit Court
February Term, A.D. 1860.

John JacksonJackson agent of each
of the plaintiff, being duly sworn, on his
oath says, that Oliver Bennett, who is a
merchant, and a resident, as this affiant is
informed & believes, of the City of Boston in the
State of Massachusetts, and has been a resident
of that place for the last year & more
is a material witness for the plaintiff in the
trial of each of the above entitled cases:-
that he has not been in this state since
the institution of said suits that cases; that
within the last week, it has been described
that said Bennett is a material witness
in said cases for the Plaintiff: that no other
witness is in attendance, or within the reach
of the process of this Court to the Knowledge of affiant or plaintiff upon which testimony
the plaintiff can safely rely to prove
the particular facts that the absent witness
is expected to prove; that the said JacksonJackson
agent of each of the plaintiffs believes that
plaintiff cannot safely go to trial without
the testimony of such absent witness; that
he is not absent by the consent
of the plaintiff: that there has not been
time to procure the deposition of said witness
since his materiality was known; that this ap
plication is not made for vexation or delay
but in sincerity & truth, for the purposes of
justice: that if these causes are continueduntil

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the next Term of this Court, the plaintiff will he able
to procure the testimony of the said Oliver Bennett by
deposition. He therefore prays, that the Court will continue
said causes until the next Term of this Court.

Sworn to subscribed before
me May 11 1860

John JacksonJackson

S Rice Clk

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No. 457

Julia ShawJulia Shaw
vs
A.HH Evans .EvansH Evans

Amended Answer
RecordedAnswer
-
Service of copy
admitted.

C.C.CarrollCarroll
Atty for Pltff
May 13th 1861

Filed May 16 1861

S Rice Clk
N. Cox
Defts Atty.

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JuliaJulia Shaw ShawJulia Shaw
Plaintiff,
against
AugusH. EvansH Evans
Defendant.

In the Saint LouisCircuit Court
Circuit CourtCircuit Court .
February Term 1861.

And now comesAugustusAugustus H. EvansH Evans ,
the above named defendant, and,
by leave of the Court here first had,
files this his Answer
to the petition of the plaintiff and
states that he denies that JuliaJulia Shaw
ShawJulia Shaw , the above named plaintiff,
is entitled to her freedom. Defen

dant admits that said plaintiff
was born in the City of Saint LouisSt Louis,
but denies that said plaintiff
was hour for and that the
defendant unlawfully holds her
in slavery.

Defendant for further
answer avers and states that
defendant at the time of the
birth of the plaintiff held and
owned the mother of the plaintiff
as his slave; that some years
ago the said mother of the
plaintiff removed said plaintiff,
or caused said plaintiff to be re

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moved out of this state and repre
sented to defendant that plaintiff
was dead; that so soon as the
return of plaintiff to this state came
to the Knowledge of defendant,
defendant caused her to be apprehended
and lodged in jail
as his slave and soon thereafter,
that is to say on or about the Ninth
day of June in the year 1859 without notice that said plaintiff claimed to be entitled to freedom sold
and delivered said plaintiff as a
slave to me Alexander Williams
and that plaintiff is now the
property of said Williams.

NathanielCox
Defts Atty.

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AugustusAugustus H. EvansH Evans , the above
named as defendant makes
oath and says that the afore
going Answer and the matters
therein, as stated, he believes to
be true..

Sworn to & Subscribed
before me May 16th 1861

S Rice Clk
A.H. EvansH Evans