GabrielGabriel (man of color) by his attorneys complains of AndrewAndrew ChristyChristy Executor and Mary CoonsMary Coons Executrix of the Estate of David CoonsDavid Coons deceased of a plea of trespass . For that the said defendants on the third day of August in the year Eighteen hundred & forty six at St LouisSt. Louis, to wit; at said County, with force & arms &c, made an assault upon the said plaintiff, and then & there beat bruised and illtreated him the said plaintiff, and then & there imprisoned him the said plaintiff, and kept and detainted him in prison there without any reasonable or probable cause whatsoever for a long time to wit, for the space of seventy two hours, then next following contrary to the laws and customs of this country and against the will of the said plaintiff, and the said plaintiff avers that before and at the time of the grievances aforesaid he was and still is a free person, and that the defendants held and still hold him in slavery, and the said defendants then & there did other wrongs to the said plaintiff, to the great damage of the said plaintiff and against the peace of the country, wherefore the said plaintiff saith that he is injured , and hath sustained damage to the amount of three five hundred dollars and therefore he brings his suit &c

Papers filed 17p. 447- Submitted to Court & Judgement 17 p 448- Jan. 4, 1847

Narr.

And the said defeendants in their proper persons come & defend the force and injury when &c, and say that the said GabrielGabriel was at the times when &c, & is now the slave of the said defendants without that that he was or is a free person in manner and form as in said declaration is alleged, & of this they put them selves upon the County &c.

plea

We the undersigned were present and witnesses to the agreement and promises made by the late DavidDavid Coon to Gabriel McClelland which promise was that he the said GabrielGabriel should have his free papers when he should repay the money advanced by David Cerrs to said McClellan to buy GabrielGabriel from his former Walter McClelland. Gabriel himself had part of the purchase money and Mr David CoonsDavid David CoonsCoons lent him the balance taking as security a bill of sale for said GabrielGabriel from his former master Mc Clelland and we know that he GabrielGabriel is entitled to his free papers

signed by Geo W. Cerrs & HughHugh Gallaghin Original in It is further admitted by the attorney for the plaintiff & defendants and thereby the foregoing statement of which the above is a copy is the testimony evidence in this cause and it is further permitted by the defendants that the plaintiff GabrielGabriel has paid to the defendants as excutors the sum of seventy six dollars which was the balance due to the estate of DavidDavid Cerris for the money ad vanecd by said DavidDavid and they never said GabrielGabriel as belonging to said Estate