The petition of Alfred TaylorAlfred Alfred TaylorTaylor, a free man, of color respectuflly represents,, to your honor, that he is now confined, in the common jail, of said County by the jailor of the County aforesaid., your pet itioner states, that he was by the sherrif, of said County as the property, of at the of commenced in the Court, of Common pleas of said county by attachment your petitioner states, that at the present term, of the said Court of common pleas, the said letter moved the, said last mentioned court, for an order of sale in said Cause and the Said Court of Common Please where the said motion, did make, an order that your petitioner, should be sold as the property of said as aforesaid, your petitioner states, that the said sherrif, has your petitioner, for sale and will on this seventh day of October 1848, Unless, your honor, should and allow your petitioner, to sue, for his freedom your petitioner states, that at the time, he was on the attachment aforesaid as the property, of said he was entitled to his freedom and of to have, been free, and absolved from mandatory servitude, , your petitioner states, that he was formerly, the slave of Isaac VanHouton, a resident, of St LouisSt. Louis aforesaid now deceased, , that said IsaacIsaac departed, this life, in the in the early part, of 1847. after the death, of said IsaacIsaac the said CorneliusCornelius claimed, to be the owner of your petitioner, and held, him in slavery up, to the time he was attached as aforesaid, . your petitioner states, that he does not know, by what right

or authority, the said CorneliusCornelius, holds or to claim, your petitioner, as his slave. Your petitioner states, that in the lifetime, of the said petitioner, your petitioner, was often by the said IsaacIsaac, that your petitioner, should be liberated, and set free, upon the payment by your petitioner, of the sum, of eight, hundred dollars your petitioner states, that he paid, to the said IsaacIsaac, in his lifetime, two hundred and forty six dollors and to the widow, of the said IsaacIsaac, at the of the said CorneliusCornelius the sum of ninety nine dollars and to the said CorneliusCornelius, the sum of four hundred and fifty five, dollars making in all, the sum of Eight hundred dollars, your petitioner states, that the said CorneliusCornelius since, the death, of the said IsaacIsaac, and before the issuance, of the attachment in said cause promised, your petitioner that he the said CorneliusCornelius would in due time by proper and sufficient, liberate and emancipate your petitioner, which promises and the said CorneliusCornelius have, broken and wholly failed, to fulfil, and perform. Your petitioner states that he is in equity amd good, to his freedom upon the ground that, he has paid to those owning, him as a slave the amount agreed, that he should pay, and his value, even if he were a slave your petitioner, further states, that in the year, of our Lord one thousand eight hundred and forty one or two the the said Isaac VanHouton, took your petitioner, to the state, of IllinoisIllinois, and at and town in said state, the names, which are not known, to your petitioner nor does, he know, the names of the counties, in which said, towns are situated, but he knows, they are in the state, of IllinoisIllinois, that said Isaac VanHouton, in the said town of and other towns in said of , held your petitioner, in slavery and invluntary servitude.,

and compelled, your petitioner to labor for him the said Isaac, Van Houton, as a Slave for a long space of, of time to wit for the space, of ten days your petitioner therefore prays that he may be permitted to sue as a poor person to establish his right to his freedom that your honor, may make an order allowing your petitioner to sue an satisfactory to the Clerk of the Circuit CourtSt Louis Circuit Court And also that your petitioner have reasonable liberty to attend his Counsel and the Hon the Circuit CourtCircuit Court as ocasion, may require, and that he be not removed out of the jurisdiction of the Court and that he be not subject to any severity, on account of his application for freedom pursuant to the form of the statute, in such case made and and that your Hon, may unto your petitioner such, other and further in the presence as the law may out and to your honor, the nature, of his case and in he will ever

Alfred TaylorAlfred TaylorThe above named petitioner being, duly sworn on his oath, states there the - tion has been to him that he understands the Thereof and he further states, that the matter and are true, to the best of his Knowledge thereof

Filed Oct 7th 1848

Petition to sue for freedom

It is hereby ordered that the named petitioner be allowed to sue on giving security satisfactory to the Clerk of the Circuit CourtSt Louis Circuit Court for all costs, that may be adjudged against him

Second, , It is further ordered that the said petitioner have reasonable liberty to attend his Counsel and the Court as occasion may require and that he be not removed out of the State of Jurisdiction of the Circuit CourtSt. Circuit CourtLouis Circuit Court and that he be not subject to any severity on account of his application for freedomGiven under my hand October 1848

Alfred TaylorAlfred Taylor, a free man, of color, the plaintiff, in this case, by his attorny complains, of CorneliusCornelius Vanhouton LewisLewis Moutin, and Samuel ConwaySamuel Conway defendants, of a pleas, of trespass for, that the said defendants on, the first day, of August in, the year of our lord one thousand eight hundred and forty eight at St LouisSt Louis, in the County of St LouisCounty of St Louis aforesaid with, and the said plaintiff, to at the county aforesaid, and then and, there seized, and laid hold, of the said plaintiff, and with great force, and violence, - the said plaintiff, and the said plaintiff a great many violent blows, and strikes, and also, then and forced, and compelled, the said plaintiff, to and off of a then and at the county aforesaid, to go in and to the Common Jail, of said County situated, in the county aforesaid, and there then imprisoned, the said plaintiff, and kept and detained him, in person, there without any reasonable, or probably cause, for a long space of time, to wit from, that day witherto, and still holds detains and imprisons, the said plaintiff in the jail aforesaid, to wit, at the at the county aforesaid against the law of, our said state and against the will of the said plaintiff, the said plaintiff, was greatly hurt and injured, to wit, at the at the county aforesaid, the said plaintiff, at of the above stated he, was and still is, a free person,

and that the said defendants held, and still holds, said plaintiff, in slavery, to wit, at the County aforesaid, to the to the damage, of the said plaintiff, therefore he brings his suit,

for freedom,

We command you To Summon Cornelius Van, Houton Louis MartinLouis, Louis MartinMartin, and Samuel ConwaySamuel Conway, 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 third Mon-day of November next, then and there to answer unto Alfred TaylorAlfred Taylor, of color of, a plea of trespass, to the damage of said palintiff one hundred dollars: And have you then there this writ.

I acknowledge myself bound for all costs that may accrue in the above cause.

Plea, by Martin Conway, 18p391 for van 18 p 445 ( copy order ) at Sep-11-1849- 19p 175

Sacdd. dam :or

It is here by ordered that there within named petition to be allowed to sue ongoing so-clearly satisfactory to the clerk of the St. louis circuit Court for all costs that may be adjudged against him. Second It is further ordered that the said petitioner, have Rea sonable liberty to attend his counsel and the court as occasion may require and that he be not removed out of the state or jurisdiction of the st. Louis circuit court and that he be not suffer to any severity on ac, - count, of his application for freedom. Given under, my hand and, seal October 7th 1848

Served, this writ in the county of St LouisSt.Louis on this 7th day of October 1848 by offering to read it and this declaration to Samuel ConwaySamuel Conway which he refused to hear

Executed this writ in the county of St LouisSt. Louis this 7th day of October 1848 by offering to read it and the declaration to Lewis H. Martin one of, the within named defendants which he refused to hear Cornelius VanHouton not found in my county

$100 total $ $50$150 total $ 2,50

the defendands with > , the plaintiff

Plea,

Suit for freedom this case