Your orators Jonathan & Gilbert men of color represent unto your honor that heretofore to wit on the 20th day of May in the year of our Lord eighteen hundred & thirty at said county Coleman DuncanColeman Duncan whom your complainants pray may be made defendant to this bill had seized & taken into his possession & there held in his custody the said GilbertGilbert who is the brother of said JonathanJonathan & the said ColemanColeman then & there claimed siad GilbertGilbert as his slave for life offered to sell him as such to said complainant JonathanJonathan who is a free man of color & threatened that if said JonathanJonathan would not purchase said GilbertGilbert to take said GilbertGilbert to some other place & sell him as a slave The said ColemanColeman proposed that said JonathanJonathan should give him in advance one hundred Dollars & said JonathanJonathan & said GilbertGilbert should give him there obligation for three hundred Dollars more payable by Installments $100 payable Ten months from the date last aforesaid and & $100 payable Twenty months from the date last aforesaid & $100 payable Thirty months from the said 25th day May AD 1830 and it was further suggested that by the time these installments became due said GilbertGilbert could earn the money aforesaid $400 by his laboring & it was preposed that if said GilbertGilbert should die at any time before the end of the Thirty months aforesaid that the said Jonathan & Gilbert should only pay said a porportionable part of said sum of Three hundred Dollas, and it was suggested that as GilbertGilbert desired to be a free man said ColemanColeman should convey said GilbertGilbert to said JonathanJonathan as a slave by bill of Sale That said JonathanJonathan should give said GilbertGilbert a bond of Emancipation and that said complaints should give them same obligation to said ColemanColeman for the Three hundred Dollars payable by Installments as aforesaid your complainants say that said JonathanJonathan acting under the belief that the representation made by said ColemanColeman that said GilbertGilbert was his slave was true & said GilbertGilbert acting under of false imprisonment they to the preparation & acted upon the suggestions of said ColemanColeman and said JonathanJonathan accordingly advanced $100 to him said ColemanColeman then gave said JonathanJonathan a bill of sale for said GilbertGilbert, said JonathanJonathan there signed & sealed in presence of witnesses a bond of Emancipation for said GilbertGilbert which bond of Emancipation it was suggested said JonathanJonathan should keep the said sum of $400 should be paid by said GilbertGilbert so that said JonathanJonathan should be secured for the many & which he should security for an amount of said GilbertGilbert which Bill of Sale and bond of Emancipation are the first marked A No 1 & the Second B No 2. and the complainants make them a part of this bill. said complainants say they their expected & believed to said ColemanColeman there same obligation of for three hundred Dollars payable by Instalments according to the proposition of said ColemanColeman as before stated and said complainants say that said sum of $100 was advanced & said bond for $300 was given for the purpose of affecting the the Emancipation of said GilbertGilbert from Slavery & no other consideration and said complainants alledge that when said Bond was expected & long before that said GilbertGilbert had became entitled to his freedom & said ColemanColeman well knew it but then & for a Long time

held said GilbertGilbert in slavery & false imprisonment said complainants further say that said Bond for $300 as they are informed & believe is now held by Edward TracyEdward Edward TracyTracy & Charles WahrendorffCharles Charles WahrendorffWahrendorff of St LouisSt Louis & that they are interested in it.

Said complainants further alledge that said Coleman DuncanColeman Duncan is not a resident of the state of MissouriMissouri & that he is insolent & that if said bond should be paid your complainants could have no adequate remedy against him, your complainants pray that said & may also be made defendants your complainants for the reasons aforesaid pray that a subpoena may issued requiring the Defendants to appear and answer this bill that they may be compelled to answer an all the allegations of this bill so far as such answers will not them, that they may be compelled to produce in court the said bond for $300 - that they may be at Law on said bond untill they shall have answered this bill to and finally that by the of this Court said bond may be delivered & cancelled and finally the complainants pray for such further & other relief as shall to this Honorable court & they will pray

vs Coleman DuncanColeman Duncan Edward TracyEdward Tracy & Charles WahrendorffCharles Wahrendorff

Know all men by these presents that I JonathanJonathan a free black man of St LouisSt Louis MissouriMissouri for & in consideration of good causes me hereunto moving do hereby emancipate discharge & free from slavery a certain Negro Man aged about Twenty five years named GilbertGilbert being the same person this day conveyed to mt by Coleman DuncanColemanColeman DuncanDuncan by bill of Sale_ hereby relinquishing all my to him & discharging him from all claim or

of I have hereto set my hand & seal this Twenty fifth day of May in the year of our Lord one thousand eight hundred & thirty

Your orators Jonathan & Gilbert men of color represent unto your honor that heretofore to wit on the 25th day of may in the year of our Lord eightheen hundred & thirty at said county Coleman DuncanColeman Duncan whom your complainants pray may be made Defendant to this bill had seized & taken into his possession & then held in his custody the said GilbertGilbert who is the brother of said JonathanJonathan and the said then there said Coelman then & there claimed said GilbertGilbert as his slave for life offered to sell him as such to said JonathanJonathan who is a free man of color and threatened that if said JonathanJonathan not purchase said GilbertGilbert to take said GilbertGilbert to some other place & sell him as a slave That said ColemanColeman preposed that said JonathanJonathan should give him one hundred Dollars and said JonathanJonathan & said GilbertGilbert should give him this same obligation for three hundred Dollars made payable payable by $100 payable ten months from the date last aforesaid $100 payable twenty months from the date last aforesaid & $100 payable in thirty months from the date last aforesaid said 25th day of of may AD 1830 - and it was further suggested that by the time these installments became due said GilbertGilbert could earn the money aforesaid $400 by his labor and it was proposed that if said GilbertGilbert should die at any time before the end of the Thrity months aforesaid that the said Jonathan & Gilbert should only pay said Cole man a proportionable part of said sum of Three hundred Dollars - and it was Suggested that as Said GilbertGilbert desired to become a free man Said ColemanColeman should convey said GilbertGilbert to said JonathanJonathan as a slave by bill of sale that said JonathanJonathan should give said GilbertGilbert a Deed of Emancipation and that said complainants should give these same obligations to said ColemanColeman for the Three hundred Dollars payble by intallments as aforesaid Your complainants say that the said JonathanJonathan actingunder the belief that the representation made by said ColemanColeman that said GilbertGilbert was his slave was true and the said GilbertGilbert acting under duress of false imprisonment they agreed to the propositions & acted upon the suggestions of said ColemanColeman and said JonathanJonathan accordingly- advanced one hundred Dollars to him said ColemanColeman said JonathanJonathan then gave saidJonathanJonathan a bill of sale for said GilbertGilbert Said JonathanJonathan then Signed & Sealed in presence of witnesses a Deed of emancipation for said GilbertGilbert which of emancipation it wassuggested said JonathanJonathan should untill the said sum of $400 should be paid by said GilbertGilbert so that said JonathanJonathan should be secured for the money advanced & which he should security for on account of saidgilbert which Bill of Sale & Deed of emancipation the first marked A No 1 and the second B No 2 and the complainants make them a part of this Bill. Said Complainants say they there executed & delivered to said ColemanColeman obligation for three hundred Dollars payable by instalments according to the proposition of said ColemanColeman as before stated and said Complainants say that sum of $100 was advanced and said bond for $300

was given for the purpose of effecting the emancipation of said GilbertGilbert from slavery & no other consideration and said complain -ants alledge that when said bond was executedand long before that said GilbertGilbert had become entitled to his freedom but there & for a longtime previous held said GilbertGilbert in Slavery & falseimprisonment. Siad complainants furthersay that said Bond for $300 is now held byEdward Lay & Charles WahrendorffCharles Wahrendorff of St LouisSt St LouisLouis & that they are interested in it. Said Complainants further alledge that saidColeman DuncanColeman Duncan is not a resident of the MissouriState of MissouriMissouri & that he is & that if said Bond should be paid your complain - ants would have no adequate remedy against him. Your complainants pray that said Lay & may also be made Defendants Your complainants for the reasons aforesaidpray- that a subpoena may issue requiring the Defendants to appear & answer this bill that they may be compelled to answer onoath all the allegations of this bill so far assuch answer will not criminate them that they may be compelled to produce in court said bond for $300 that they maybe from proceeding at Law on said Bond untill they shall have answered this bill to_ and finally that by the the Decree of this Court said Bond may be deliveredup & cancelled and finally the complaints pray for such futher & other relief as shall seem meet to this honorable court and they will pray &c

Know all by those presents that I Coleman DuncanColeman Coleman DuncanDuncan of Hopkins CountyHopkins County in KentuckyKentucky for and in consideration of four hundred Dollars to me in hand paid by Jonathan DuncanJonathan Duncan afree black man of St LouisSt Louis in MissouriMissouri have granted bargained sold and conveyed and by these presents do grant bargain sell and convey unto said Jonathan DuncanJonathan Duncan a certain Negro manslave aged about Twenty five years namedGilbertGilbert being the same slave conveyed to meJamesJames by Bill of Sale dated second day of April in the year of our our Lord one thousand eight hundred & Twenty six -to have & to hold said Negro man slave named GilbertGilbert unto him said JonathanJonathan his administrators & assigns and I do hereby that I & my representations shall forever warrant & defend said slave & the title thereto unto the said JonathanJonathan his executors administrators and assigns against all presons claiming him as a slave

Sitting as Court of Chancery) at the next term thereof to be held at the City of St LouisCity City of St Louisof City of St LouisSt Louis within and for the County of Saint LouisCounty of Saint Louis on the Fourth Monday of March instant then and there to answer to a bill of complaint exhibited against them by JonathanJonathan and GilbertGilbert free men of Color and have you then there this writ.

I acknowledge service for

Executed this writ on Edward TracyEdward Tracy by off -ering to him the copy of bill furnished by the Clerk , and reading this writ to him, & on Chas. Wahrindorff by his (said Tracy's) acknowledging service , for him, Coleman DuncanColeman Duncan not found in my county

2 Service $22 .50$ 2.50

of to the of

The said defendants Charles WahrendorffCharles Wahrendorff & Edward TracyEdward Tracy , & reserving to themselves all and all manner of benefit of exception to said Bill of Complaint for the manifold errors , & insufficiences thereincontained for answer thereunto or to so much thereof or they are advised , is material, answer and they say that in the spring of the year 1830 JonathanJonathan one of the complainants, came to the defendant WahrendorffWahrendorff & stated that his (Jonathan's brother GilbertGilbert, the slave of Coleman DuncanColeman Duncan was then is your & could get free by paying & saving the sum of four hun-dred dollars, and asked said Wahrendorff's advicerespecting the manner in which it should be done: he then stated further that said coleman wishedhim (JonathanJonathan) to become bound for the money in which case he would give sufficient length of credit to enable GilbertGilbert to earn the money & that the sum of four houndred dollars was re - quired to be paid down. The defendant Wahren-dorff advised JonathanJonathan not to become bound unless Coleman DuncanColeman Duncan would agree to make a notable deduction from the amount of the purchase money, in case GilbertGilbert should die or become permanently unable to work within the period allowed by the contract. JonathanJonathan to the suggestion of said WahrendorffWahrendorff && asked him to accompany him - said JonathanJonathan to the office of J SpaldingJ. Spalding in order to conclude the arrangement with Coleman DuncanColeman Duncan. The defendants further say that immediately thereafter said WahrendorffWahrendorff did accompany JonathanJonathan to the office of said SpaldingSpalding where the arrange-ment was was concluded: and an instrument made seal of Jonathan & Gilbert to Coleman DuncanColeman Duncan for three hundred dollars was executed (a copy of which marked A. No. 1. is hereto annexed as part of this and immediately thereafter said Cole-man & JonathanJonathan accompanied the defendant Wah-rendorff to his stone, where he said defendant advanced at Jonathan's request, one hundred dollor to said ColemanColeman, it being the sum that was by the agreement to be paid down in cash and that in all this transaction the defendant WahrendorffWahrendorff was in no no win interest-ed, but acted merely as the friend of JonathanJonathan & at his request, & from the same motives & no other, then lent him said hundred dollars. The defendants further say that the said JonathanJonathan informed said WahrendorffWahrendorff during the aforesaid trans - actions that said Gilbert & Coleman had got into a dispute that ColemanColeman wished to take him out of the country & that GilbertGilbert intended to sue for free-dom, but that as he JonathanJonathan knew that Gil-bert belonged to ColemanColeman , it would be best to settle the matter amicably , & that it would be best to make the said arrangement; and that it was right that GilbertGilbert should pay for himself said defendents further say that afterwards wait

on the twenty eighth of June in the same year James DuncanJames Duncan the brother of ColemanColeman , called on said WahrendorffWahrendorff & borrowed on the the faith of said instrument a sum of money & pledged the said instrument or bond of Jonathan & Gilbert for the repayment of the same & that there is now due from said DuncanDuncan to these defendants for which said bond is pledged , the sum of one hundred dollars: and that said defendants have been notified that the balance due on said Bond, has been transferred to James S. Thomas and these defendants charge that there was no nor fraud in said transactions, alledging that they were not of any that the purchase of Gilbert's freedom was in their belief the result of a a dispute between the master and his have, which was compromised fairly at what they understand to be an underprice for the slave the said Gilbert & Jonathan his brother choosing rath-er to pay the sum of four hundred dollars, than to abide the result, & pay the expenses, of a tedious suit: and to that purport , the said JonathanJonathanexpressed himself to the defendant WahrendorffWahrendorff. The defendants further say that within a week after said bond was put into the defendant's hands to secure said hundred dollars, said Jona- than was notified of such fact & transfer at which time be made no objection to paying the same. The defendants further say that said Tracy during all said transactions was absent from St LouisSt. Louis & knows nothing except from hearsay & so makes the above statements. And they suppose that the instruments copies of which are made exhibits in the Bill of complaint were executed & that said copies are correct but do not know & therefore do not admit it They believe said ColemanColeman is not a resident of MissouriMissouri, but do not know whether he is insolvent or not but be-lieve & charge the the fact so to be that he is not in- solvent. Nor do these defendants know whether said GilbertGilbert could have obtained his freedom from said Cole - man by suit, but believe & charge that both Jona -than & GilbertGilbert were doubtful of the event, & chose rather than try the experiment of a suit & pay the expense & submit to the delay , to compromise the claim to freedom in the manner aforesaid: and then de- - fendants deny any participation in the transactionsdetailed in said Bill of Complaint other than as above stated: without that that there is any other matter or thing material or necessary for this defendant to make answer unto and not herein and hereby will and sufficiently answered unto, confessed or avoided traversed or denied, is true, , all which matters and things these defendants Tracy & Wahrendorff are ready to aver and prove as this honorable Court shall direct and award & humbly prays to be hence with their reasonable costs & changes in their behalf most wrongfully sustained

Edward TracyEdward Tracy & CharlesCharles Wah - rendorff being severally duly sworn on their oaths respectively say that the matters & things in above answer stated as of their own knowledge are true & those stated as matters of or belief they be-live to be true

Ten months after date we promise to pay to Coleman DuncanColeman Duncan or order the sum of one hundred dollars : & twenty months after date we promise to pay said ColemanColeman the fur- ther sum of one hundred dollars & thirty months after date we promise to pay said ColemanColeman the further sum of one hundred dollars. The two last mentioned serves to bear interest from the date hereof at the rate of six per cent per an - num for value received. This obligation however subject to the following condition. That whereas this instrument is for the benefit of the under - signed GilbertGilbert whose labor it is hoped will meet there payments now if said GilbertGilbert shall die or become from sickness or accident permanentlyunable to work, at any time within thirty months from this date then only the notable proportion of the above sum shall be paid, Witness our hands and seals this 25th. May 1830

Answer of Tracy & Wahrendorff

We command you as we heretofore commanded you to summon Coleman DuncanColeman Duncan that he be and appear before the Judge of our Circuit CourtCircuit Circuit CourtCourt sitting as a Court of Chancery at the next term thereof to be held at the City of S LouisS Louis within and for the County of S LouisCounty of S Louis on the fourth monday of July next then and there to answer the bill of Complaint of JonathanJonathan and GilbertGilbert, free men of color And have you then there this writ

Coleman DuncanColeman Coleman DuncanDuncan not found in my County

Alias-