MariguetteMariguette vs Sam T M KinneyT T M KinneyM T M KinneyKinney

petition to sue as person to establish to free dom

Your petitioner MaryMary to honorable court, that she was born in the town of Nashashia in what is now the state of IllinoisIllinois about thirty years since that she was purchased an infant by our MarshallMarshall and taken to St in what is now the state of MissouriMissouri And she has continued to reside in this state for that time until now held as a slave, that about six or seven months since she was purchased by one SamuelSamuel KinneyKinney as your petitioner who now holds her as a slave your petitioner is advised that in the north she has a claim to and is entitled to the freedom your petitioner therfore prays that she may be permitted to institute suit to establish her right to freedom and the such orders may be had in the as the law and

George T Strother presents the petition of MariguetteMariguette a woman of color praying that she may be permitted to institute suit against SamuelSamuel W KinneyW Kinney for Establishing her right to freedom and that she may be permitted to institute suit against SamuelSamuel W KinneyW Kinney for Establishing her right to freedom and that she may be permitted to sue as a poor person thereupon the court permit the said MariguetteMariguette to sue as aforesaid and direct that an action of assault and Battery and false imprisonment be brought in the name of the said Marguette and assign George F StrotherGeorge F George F StrotherStrother as her counsel and it is ordered by the court that the said SamuelSamuel W KinneyW Kinney permit the said MariguetteMariguette to have a reasonable liberty of attending her counsel and the court when occasion may require it and that the said petitioner shall not be taken or removed out of the Jurisdiction of this Court or be subject to any severity of treatment on account of her said application for freedom

This is an action of assault   battery and false imprisonment for freedom The Clerk will please issue a Summons

Served this writ by reading the declaration   writ to SamuelSamuel F M KinneyM M KinneyKinney on the 14th day of April 1831. served the the order at of the Circuit CourtCircuit Court a copy of which is endorsed on the declaration, my reading it to the said M KinneyM. M KinneyKinney

MariguetteMariguette who sues by permission of the Court Complains of SamuelSamuel W KinneyW Kinney of a plea of trespass. For and that the said SamuelSamuel W KinneyW Kinney on the first day of February in the year 1831 with force and arms made an assault upon the said MariguetteMariguette to wit at the County of St LouisCounty of St Louis and then and there struck and gave the said MariguetteMariguette a great many violent blows and strokes and then and there imprisoned the said MariguetteMariguette and kept and detained her in prison there without any reasonable or probable cause whatsoever for a long space of time to wit for the space of ten weeks then next following contrary to law and against the will of the said MariguetteMariguette whereby she the said MariguetteMariguette was then and there not only greatly hurt and wounded but was also thereby then and there greatly injured in her circumstances to wit at St LouisSt Louis aforesaid and the said MariguetteMariguette avers that before and at the time of committing the grievences aforesaid to wit at the county of St LouisSt Louis aforesaid then was and still is a free person and the defendants SamuelSamuel W KinneyW Kinney   CharlesCharles Wahrensdorff then held and detained her and still hold (and detain) her in slavery and other wrongs to the said MariguetteMariguette then and there did against the peace of the State and to the damage of the plaintiff Five Hundred dollars and therefore the brings her suit

I have copied the original declaration as well as I could make it out the same not being made out as required by Rule of court and being also very badly written

We command you to Summon SamuelSamuel W KinneyW Kinney that he be and appear before the Judge of our Circuit CourtCircuit Court at the next July Term thereof to be held at the City of St LouisCity of St Louis within and for the county of St LouisSaint Louis on the Fourth Monday of July next then and there to answer unto MariguetteMariguette of a plea of trespass to the damage of the plaintiff Five Hundred dollars and have you then there this writ

This is an action of assault and battery and false imprisonment for freedom on the clerk will issue a summons

St LouisSt Louis county to wit MaryMary guette who sues by of the court complains of SamuelSamuel L McKinney of a plea of trespass for that the said SamuelSamuel M KinneyM M KinneyKinney on the first day of February in the year 1831 with force and orders made an assault upon the said MaryMary guette to wit at the county of St LouisSt Louis and then and there and gave the said MaryMary guette a great many violent blows and strokes and then and there imprisoned the said MaryMary guette and left and detained her in prison there without any reasonable or probable cause whatsover for a long space of time to wit for the space of ten weeks then next following contrary to law and against the will of the said MaryMary guette whereby she the said MaryMary guette was then and there not only greatly beat and wounded but was also then and there greatly injured in her circumstances to wit at St LouisSt Louis aforesaid and the said MaryMary guette avers that before and at the time of concluding the grievances aforesaid to wit at the county of St LouisSt Louis aforesaid she was and still is a free person and the defendant SamuelSamuel L W KinneyW W KinneyKinney then held and detained her and still holds and detains her in slavery and after ways to the said MaryMary guette then and there did against of and to the damage of the plaintiff $ 500 and therefore she brings her suit

And the said M KinneyM M KinneyKinney comes and defends the force and injury when   c. and says that said plaintiff ought not to have or maintain her aforesaid action thereof against him because he says that at the time when this suit was commenced he had not nor claimed to have nor hath he nor doth he now claim to have but disavoweth   disclaimeth to have any title or interset in said MariguetteMariguette as a slave nor did he then hold nor hath he since had nor doth he now, hold her as a slave: and this he is ready to verify, where fore he prays proficient   c.

and the said Charles WahrendorffCharles Charles WahrendorffWahrendorff by his attorney comes and defends the force   injury when   c.   says that he is not guilty of the said supposed trespasses   wrongs in manner and form as in said declaration alleged : and of this he puts himself upon the country   c.

and for further plea in this behalf he says that said plaintiff ought not to have or maintain her aforesaid action thereof against him because he says, that said plaintiff at   before the time mentioned in said declaration for the committing said supposed trespasses   grievances , said plaintiff was   now is his slave, without there that she was or is a free person:   this he is ready to verify. Wherefore he prays   c.

Book 6 Page 92 Non suit Book 7 page 157

MariguetteMariguette vs SamuelSamuel T. McKinney

Disclaimer

by WahrendorffWahrendorff

You are hereby commanded to summon Clayton TiffinClayton Tiffin that setting aside all manner of excuse and delay, he be and appear in proper person before the Judge of our Circuit CourtCircuit Court, 3rd day of April 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 MariguetteMariguette is plaintiff, and SamuelSamuel T McKinney   Charles WahrendorffCharles Wahrendorff are defendants, on the part of the plaintiff; and have you then there this writ.

MariguetteMariguette vs F.T. McKinney   W WahrendorffW Wahrendorff

Executed on this writ on Clayton TiffinClayton Tiffin in the city of St LouisSt Louis on the 6th day of March 1832

We command you to attach Clayton TiffinClayton Tiffin by his body, and him safely keep, so that you have his body before the Judge of our Circuit CourtCircuit Court, now in session at the City of St LouisCity of St. Louis, within and for the county of St LouisSt. Louis, forthwith 18, then and there to testify and the truth to say in a certain matter of controversy, now pending in our said Circuit CourtCircuit Court, between MariguetteMariguette plaintiff and MariguetteMariguette S T M. Kinney is defendant, wherein the said TiffinTiffin has heretofore been summoned on the part of the said plaintiff

Executed & have the body of Clayton TiffinClayton Clayton TiffinTiffin in Court 24th April 1832

MariguetteMariguette vs S T McKinney

You Are Hereby Commanded To Summon Alexis AmelinAlexis Amelin that setting aside all manner of excuse and delay, he be and appear in proper person before the Judge of our Circuit CourtCircuit Court, forthwith 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 MariguetteMariguette is plaintiff, and S. T. McKinney is defendant, on the part of the plaintiff and have you then there this writ.

Served this writ on Alexis AmelinAlexis Alexis AmelinAmelin on the 25h April 1832

Marguritte vs S.T. McKinney

You Are Hereby Commanded To Summon Clayton TiffinClayton Tiffin and Alexis AmelinAlexis Alexis AmelinAmelin that setting aside all manner of excuse and delay, he be and appear in proper person before the Judge of our Circuit CourtCircuit Court, on the 30h day of July 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 MariguetteMariguette is plaintiff, and SamuelSamuel T M. Kinney   W WahrendorffW W WahrendorffWahrendorff are defendants, on the part of the plaintiff and have you then there this writ.

MariguetteMariguette vs S.T. W Kinney   W WahrendorffW W WahrendorffWahrendorff

Executed this writ on Clayton TiffinClayton Tiffin   Alexis AmelinAlexis Amelin in the city of St LouisSt Louis on the 3rd day of July 1832

We command you to attach Clayton TiffinClayton Tiffin   and Alexis AmelinAlexis Amelin by by their bodies, and them safely keep, so that you have their bod ies before the Judge of our Circuit CourtCircuit Court, now in session at the City of St LouisCity of St. Louis, within and for the County of St LouisCounty of St. Louis, on the 8th day of August 1832, then and there to testify and the truth to say in a certain matter of controversy, now pending in our said Circuit CourtCircuit Court, between MariguetteMariguette plaintiff and Sam T M KinneyT T M KinneyM T M KinneyKinney defendant, wherein the said TiffinTiffin and   AmelinAmelin have heretofore been summoned on the part of the said plaintiff

MariguetteMariguette vs M KinneyM M KinneyKinney

Executed   have the body of TiffinTiffin ߖ AmelinAmelin in of 7 Augst 1832

You Are Hereby Commanded To Summon Clayton TiffinClayton Tiffin and Alexis AmelinAlexis Amelin that setting aside all manner of excuse and delay, they be and appear in proper person before the Judge of our Circuit CourtCircuit Court, Fifth day of December 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 MariguetteMariguette is plaintiff, and SamuelSamuel T. M Kinney and defendant, on the part of the plaintiff- and have you then there this writ.

MariguetteMariguette vs S.T. McKinney   CW WahrendorffWahrendorff

Executed this writ on Clayton TiffinClayton Tiffin on the 12th Nov 1832 and A. Amelin on the 14tNov 1832 by reading the same to them in the County of St LouisCounty of St Louis

You are hereby commanded to summon Clayton TiffinClayton Tiffin   Alexis AmelinAlexis Amelin that setting aside all manner of excuse and delay, they be and appear in proper person before the Judge of our Circuit CourtCircuit Court, on the Twenty ninth day of March 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 MariguetteMariguette is plaintiff, and SamuelSamuel T M KinneyT M Kinney and Charles WahrendorffCharles Charles WahrendorffWahrendorff are defendants, on the part of the plaintiff and have you then there this writ.

Executed this writ by reading it to Clayton TiffinClayton Clayton TiffinTiffin and Alexis AmelinAlexis Amelin in the County of St LouisCounty of St County of St LouisLouis March 1st 1833

MariguetteMariguette vs S.T.McKinney   W WahrendorffW W WahrendorffWahrendorff

You are hereby commanded to summon Clayton TiffinClayton Tiffin   Alexis AmelinAlexis Amelin, that setting aside all manner of excuse and delay, they be and appear in proper person before the Judge of our Circuit CourtCircuit Court, on the 25th day of July 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 MariguetteMariguette is plaintiff, and SamuelSamuel T M KinneyT M Kinney and Cha. WahrendorffWahrendorff are defendants, on the part of the plaintiff and have you then there this writ.

MariguetteMariguette vs S.T. M Kinney   Chas Wahrendorff

Executed this writ on Clayton TiffinClayton Tiffin 18th on Alexis AmelinAlexis Amelin the 19th July 1833 in the County of St LouisCounty of St Louis

You are hereby commanded to summon Clayton TiffinClayton Tiffin   Alexis AmelinAlexis Amelin, that setting aside all manner of excuse and delay, they be and appear in proper person before the Judge of our Circuit CourtCircuit Court, on the 2nd day of December 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 MariguetteMariguette is plaintiff, and SamuelSamuel T M KinneyT M Kinney and Charles WahrendorffCharles Charles WahrendorffWahrendorff are defendants, on the part of the plaintiff and have you then there this writ.

MariguetteMariguette vs M Kimmey   WahrendorffWahrendorff

Executed this writ on Alexis AmelinAlexis Amelin 11th Clayton TiffinClayton Tiffin 18th days of November 1833

We command you to attach Clayton TiffinClayton Tiffin   Alexis AmelinAlexis Alexis AmelinAmelin by their bod ies, and them safely keep, so that you have their bod ies before the Judge of our Circuit CourtCircuit Court, now in session at the City of St LouisCity of St. Louis, within and for the County of St LouisCounty of St. Louis, forthwith 183, then and there to testify and the truth to say in a certain matter of controversy, now pending in our said Circuit CourtCircuit Court, between Marguette is plaintiff and S. T. M Kinney   C WahrendorffWahrendorff defendant, wherein the said TiffinTiffin   AmelinAmelin have heretofore been summoned on the part of the said plaintiff

Marguette vs Wm Kenney   Wahrendorff A

Executed this writ   the body of C TiffinTiffin   A in Court 14th December 1833