the petition of Peggy PerrymanPeggy Perryman respectfully represents that on or about the first of december past, - - she was residing, with her friends, in ArkansasArkansas, in the peaceable enjoyment, of her freedom and civil rights, to which she was enitled by her parents, by being free persons, her father, a free person of color, in said state, and her mother was lawfully married, to her her father, an Indian of, the Black foot tribe Your Petitioner represents, that about that time she was suddenly seized, by persons, to her before unknown gaged, and transported, and finally sold into servitude that, her her relatives, by the mother side and, all not, only free since, the memory of man but are distinguished, among their tribe, your petitioner represents as such free born person she, is entitled, to her freedom from the engagement of which she is, wherefore she prays, in considerationof the promises she, may have leave, to sue, as a poor person, in order to establish, her right, to freedom and that counsel, to her for that purpose, order be made, as to secure of prosecuting, her said, as in duty bound she,

by the court, in the, petition, shall during suit have reasonable liberty of all and the court that she and,, of the state or jurisdiction that she shalln not be subject to any severity on account of her application, for her freedom, and that she be permitted to sue, as a poor person,

And this day comes the defendant and his, attorneys and moves the court, to dismiss the above potential suit, for the following reasons

1st given the commandment of , for casts might be against for the as is required the

2d Because no attorny, is given the of statute to permit such a, suit of one held as, a as a poor person

3rd because, no suficient, reason is for to make it,

4th because there, is in fact no suit pending for want of sufficient process

5th because there, is no unit, .

6th because there, is no service, .

Motion to Dismiss & reasons,

Peggy PerrymanPeggy Perryman, a free woman, of color, complained of JosephJoseph Philibert, of a plea, of trespass, for false imprisonment, for that whereas heretofore to wit, at the city and county of saint louis, and state of missouri, as about, the spring of the year one thousand eight hundred and forty seven as your petitioner recollects, the said JosephJoseph Philibert drendant aforesaid then, and there with, force and arm assaulted, the said PeggyPeggy and her the, said PeggyPeggy then, and there took, and imprisoned and restrained, her of her liberty, and her the said PeggyPeggy held in servitude from, the spring of the year 1847 at which time, as your petitioner, is informed the said defendant, purchased her from one Bartley untill, the present time, and still holds her in servitude, without any reasonable or probably cause, against the law, of the land and against the will of her, the said PeggyPeggy, and that she PeggyPeggy, before and at the time of the, said greivances was, and still, and that the said defendant holds her in servitude,, and servitude, and to the great damage, of and therefore, she sues,

to dismap suit 18p 347.

Trespass for false imprisonment,

Executed this order of Court by reading, it and the Petition and declaration to JosephJoseph Philibert in the County of St LouisCounty of St Louis April 28th 1848

Service 50Copy 1,10

The Petition, of Peggy PerrymanPeggy Perryman respectfully represents, that on or about the first day of december 1845 She residing with, her friends, in ArkansasArkansas, in the enjoyment, of her freedom, and and civil rights, to which she was entitled, her parents being, free persons, her father, a free person of color, of color in said state, and her mother who was lawfully married, to her father an Indian, of the Black Foot tribe. your petitioner represents, that about that time She was suddenly seized, by persons to her before unkown, gaged and transported, and finally sold, into servitude, that her relatives, by the mother side and all not only free since, the memory, of man, but and distinguished, among their tribe, - your Petitioner represents, as such free person, she is to her freedom from at which she is now restrained, by JosephJoseph Philibert Wherefore, she prays, in consideration, of the promises, she may have had to sue as a poor person, in order to establish, her right to freedom and that counsel, may be to her for that, purpose and that such order be made as to secure, her in the privelege, of presenting, her said claims and, as in duty bound, she will pray

Defendant comes and defends the, of the said plaintiff,

suit for freedom

plaintiff attend counsel, to 19 p 26 motion to dismap, .

Peggy Perry, man a free woman of color complains, of JosephJoseph Philibert, of a plea of trespass, for false imprisonment, for that whereas the city and county of St LouisSt Louis and State of MO during,, the spring of 1848, as as your petitioner presents, the said JosephJoseph Philibert, Defendant then and there, with force and, arms assaulted, the said PeggyPeggy, and then and there took, and imprisoned, and restrained, her of her libery, and her the said PeggyPeggy, held in servitude, from the from the spring of, the year 1847 at which time as your said petitioner the said deft, her from one BartlettBartlett, untill the present time, and still holds her in such servitude without, any reasonable, or probable cause, aganist the law, of the land and against the will of her, the said PeggyPeggy, and the said further and that before and at the of the committing of the said greivances, was and still is a free person, that the said Deft, held and still holds her in servitude and, slavery against the and to the great, damage of, the said PeggyPeggy, therefore she sues,

It is ordered by the court in the within, cause that the petitioner, shall be allowed to sue as a poor person, and shall during, the of will have reasonable, liberty of attending her counsel, and the court, and that she, shall not, be removed, out of the state, or jurisdiction, of this court, and shall not be subject, to any severity, on of of her application, for freedom and that she is permitted, to sue, as a poor person

Personally, and says that Peggy PerrymanPeggy Perryman is, a poor person and unable to prosecute her suit but as a poor, person

Peggy PerrymanPeggy Perryman a free woman of color complains of JosephJoseph Philibert of a plea of Trespass, for false imprisonment for that, at the city and County of St LouisCounty of St Louis and State of MO during the spring of 1847, your petitioner recollects the said JosephJoseph Philibert defendant then, and there, with force, and arms assaulted, the said PeggyPeggy, and then, and there took, and imprisoned, and her of her liberty and her, the said PeggyPeggy held in serviude, from the spring of the year, 1847 at, which time the present, time and still holds her, in such servitude without any reasonable or probably casue against, the law of, the land and against, the will of her, the PeggyPeggy, and she, the said further, and declares that she before, and at the time, of the committing of, the said greivances, was and still, is a free person and, that the said Deft, held and still, holds her, in servitude and slavery against, the will of, and and to the great damage of the said PeggyPeggy, and therefore she sues,

It is ordered, by the court, in the within case that the petitioner shall be allowed, , to sue as a poor person and shall, the of this suit have reasonable liberty of attending her counsel and, the court and that she shall not be removed out of the state of or jurisdiction of this court, and shall not be subject to any severity on account of her application, for freedom and that she be permitted to sue, as a poor person,

Personally

We command you To Summan JosephJoseph Philibert 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 the third Mon-day of next, then and there to answer unto Peggy PerrymanPeggy Peggy PerrymanPerryman (ofcolor) of her petition for freedom. filed V dr3th 1848. And have you then there this writ.

I acknowledge myself bound for all costs that may accrue in the above cause. Witness my hand and seal, at St LouisSt. Louis, this day of

Excuted this unit in the county of St LouisSt. Louis on the 19th day of December 1848 by reading it to JosephJoseph Phili, bert said County and further executed the same on the same day by offering to read the declaration to the said JosephJoseph Philibert, which he refused to hear

You are hereby commanded, that setting aside all manner of excuse and delay, you appear be-fore our Circuit CourtCircuit Court for the county aforesaid, on the 25th January 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 PeggyPeggy Parryman is plaintiff and Jos. Philibert defendant on the part of plaintiff and herein you are in no wise to fail.

Executed this 24th day of January 1849

,

Motion to dismiss,

me said defendent comes and defe the demand, of plaintiff,

plea

it this an the 9th day of February 1849 the said defendant, is the his and to an the 6th day of is the is the 1849 the came an whan the upon which of the is the and at the and this of he and a of is the a 20th day of nov. 1848 and on the 17th day of april 1849 his of upon is

Bill, of Exceptions,

You Are Hereby Commanded, that setting aside manner of excuse and delay, you appear before our Ciruit Court for the County aforesaid, on the 18th february 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 Peggy PerrymanPeggy Perryman, is plaintiff and JosephJoseph Philibert, is defendant on the part of plt, and herein you are in no wise to fail.

Excuted on Calvers,

You are hereby commanded, that setting aside all manner of excuse and delay, you appear be-fore our Circuit CourtCircuit Court for the County aforesaid, on the 18th day of February 1850 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 Peggy PerrymanPeggy Perryman is plaintiff and Philibert is defendant on the part of Deft, and herein you are in no wise to fail.

for Deft,

Executed on BartlettBartlett the other not found

You Are Hereby Commanded, that setting aside all manner of excuse and delay, you appear before our Circuit CourtCircuit Court for the County aforesaid, on the 25//- Feb 1850 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 PeggyPeggy, is plaintiff and Jos, Phillibert is defendant on the part of and herein you are in no wise to fail.

for peff

Executed on Calvert Batiste not found

60

10

100

60

60

50

3.40

1.20

4 60

You Are Hereby Commanded, that setting aside all manner of excuse and delay, you appear before our Circuit CourtCircuit Court for the County aforesaid, on the 25 Feby 1850 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 PeggyPeggy of color, plaintiff and Jos. Philibert, defendant on the part of deft, and herein you are in no wise to fail.

for for deft,

Served, this subpoena, in the county of St LouisSt. Louis on the 18th day of feby 1850

You Are Hereby Commanded, that setting aside all manner of excuse and delay, you appear before our Circuit CourtCircuit Court for the county aforesaid, on the 18th March 1850at the city of St LouisSt. Louis, then and there to testify, and the truth to say in a certain matter of controversy now pending in our said Court, wherein Peggy PerrymanPeggy Perryman is plaintiff and Philibert is defendant on the part of plaintiff and herein you are in no wise to fail.

spa Batiste Charleau