State of Missouri
County of St. Louis
SsIn the Circuit Court
November term 1827.
Elizabeth a free girl of color held in slavery who i
permitted by the court to sue by Alexis Amelin
the next
friend as a poor person, by her attorneys John
M Bass & Isaac
C
McGirk assignedby said court as
counsel,
complains of Francois Menard & Andre
Landreville
of a plea of trespass with force &
arms for
that the said defendants
heretofore to wit on the first day of January, one thousand
eight hundred
and twenty seven with force and arms
at the county of St.
Louis aforesaw unlawfully an assault did
make in and upon the said Elizabeth and then & there
beat
bruised and ill- treated the said
Elizabeth and
then
& there imprisoned her and kept and
detained her
in prison without any
probable or reasonable cause what
so ever and have eversincekept&detained
her in
prison and do still keep & detain her the said
Elizabeth
and the said plaintiffs that before & at the time
of committing this grievance
in prisonagainst
her will, contrary to the laws
aforesaid she was &
still is a free person and that the defendants held
detained & still hold & detain
her
the said Elizabeth in slavery of the state and other
wrongs then & there did to
the said Elizabeth against the peace
of this state;
wherefore the said Elizabeth says she is injured
and has sustained damage to the amount of
five hundred dollars and
therefore she sues c
Bass & McGirk
Atty P
Q.
The State of Missouri
County of St. Louis To the Sheriff of St. Louis County Greeting
We command you to summon Francois Menard and Andre Landreville that
they
be and appear before the Juddge of an circuit Court at the next term
thereof to be
held at the city of
St. Louis within and for the county of St. Louis on the Fourth monday
of November next then and there to answer into Elizabeth who sues by
Alexis Amelin
her next friend of a
plea of Trespass to the
damage of said plaintiff of Five Hundred
Dollars and have you then therethis
writ
Witness Archibald Gamble Clerk of our said Court of office
this
fourth day of August 1827 Archibald Gamble Clerk
Executed this writ on Andre Landreville August 8th
1827 in the City
of St Louis by informing him of the
contents thereof and his acknowledging
the service of the same Francis
Menard not found in my
County Nov 10th
1827
R. Simpson Sheriff Service $ 1.00
non Est
50
1.50 July 12 1828. Francois Menard not
found
& R Simpson Shff
No 13 In the St. Louis Circuit Court
November term 1827.
Elisabth a free girl of Color
vs
Francois Menard & Andre Landreville
Declaration
This is an action of assault
& Battery and false
impris
onment
Let a summon issue
Bass & McGirk
P L . Filed 4th August 1827, Archibald Gamble Clerk Amended declaration filed 18th
December 1827 Arch Gamble Clerk
St. Louis Cicuit Court July Term 1827
John M Bass presents to the Court the petition of Elizabeth , Virginia and
Victoire children
of Mary a colored woman praying that they may be
permitted to institutea suit
against Francois Menard and Andre Landreville for
Establishing their right to
freedom and that they
may be permitted to sue as poor persons - thereupon
the Court
permit the said Elizabeth Victoire , and Virginia to
sue as aforesaid and direct that
an action of assault and battery and
false imprisonment be commenced against
the said defendants by their
next friend in the names of the said Elizabeth Victoire
and Virginia
and assign John M Bass and Isaac C
McGirk as their counsel and it
is
ordered by the Court that the said defendants permit the said plaintiffs to
have a
reasonable liberty of attending their counsel and the Court when
occasion may
require it and that the said plaintiff shall not be taken
or removed out of the Jurisdiction
of this Court and that the said
plaintiff shall not be subject to any seventy
of treatment on account
of then said application for freedom
Archibald Gamble Clerk
County of St. Louis The State of Misouri To the Sheriff of St. Louis County Greeting
We command you to summon Francois Menard that he be and appear before
the Judge
of our Circuit Court at the
next term thereof to he held at the City of St. Louis within and for
the County of St. Louis on the fourth monday of July next then and their to
answer unto
Elizabeth who sues by Alexis Amelin her next
friend of a plea of trespass to the damage of
said plaintiff of
Five
Hundred dollars and have you then there this writ
Witness archibald Gamble Clerk of our aid Court at office this
Ninth day of may One thousand Eight hundred and
twenty Eight Archibald Gamble Clerk
vs
Francois Menard
&
Andre Laundreville
St. Louis Circuit Court Mr Andre Laundreville
Will take notice that
on the 13th day of the
present month between the
hours of 9 O clock in the forenoon and
5 O clock in the
afternoon of that day at the office of V
in thi city we shall proceed to take the depositions
of
witneses to be read in the above
suit
in behalf
of the plaintiff.
St. Louis Nov 6th 1827. Bass & McGirk Attys for Pltff
Elizabeth
vs
Menard & Landreville
notice
Served a Copy of the within notice
on Andre
Landreville Nov. 8th 1827
in St. Louis D P
Sheriff Service $ 0.50
November term 1827 Andre Landreville
Elizabeth
And thesaid Andre
Landreville by his attorney
and defendsthe
force
and injury wherefore and says
he
is not guilty
of the said supposedtrespassassaults and
battery;
imprisonment and detentions
above said to his charge or
anypart thereof
in manner & form as the
said Elizabeth by
her next friend Alexis Amelin
hath above
thereof against him and of this
hethe said
Andre Landreville puts
himself upon the
county
and the said plaintiff
doth
the like Bass & McGirk for pltff
And for furtherpleain this
behalf
the said Andre Landreville says the said
Elizabeth ought
not to haveor
maintain her
aforesaid action thereof against him because
he says that
the said Andre Landreville
at the times mentioned in the said
declaration had not norclaimed
to have nor
hath he nor dothhe now
claim to have but
disavoweth and disclaimethtohaveanytitle
claim or
interest in and to then said
Elizabeth and thusthen
said Andre Landreville
is ready
to testifywherefore
he prays
judgement if the said plaintiff ought to
have or
maintain aforesaid actionagainsthim
attorney for dnt
No 13 November Term 1827
Elizabeth
vs
Landreville
filed for Nov 29th 1827 A. Gamble Clk
Elizabeth vs A Landreville
and the said, Elizabeth for replication to the
plea of the
said Landreville secondly above plea did says that
She ought not to be
barred &
precluded from having & maintaining
her action aforesaid against the said Landreville because she
says that
the said Landreville at the said times in her said declaration
mentioned & before the said several times did
claim to have
& hold the said Elizabeth as a slave & doth still
claim the
said Elizabeth as a slave and of this she the said
Elizabeth puts
hereof upon the county & C.
Bass & McGirk
Attys for Pltff.
Elizabeth
vs
Landreville
Rep filed Decr 2nd
1828 A Gamble Clk