To the Honorable Circuit Court of the County St. Louis county July term 1827

The petition of Mary , a woman color,
represents, that she was born in Kaskaskia
in the now state of Illinois in the family and
possession of one Michel Bienvenu there are
that your petitioner is now
about twenty six or seven years old
is informed and believes; that she was reared and
brought up in a state of slavery in Kaskaskia
in the possession of said Bienvenu and remained
in his family till his death, after which, your
petitioner was sold as a slave to Francois
Menard an inhabitant of Illinois at that time that said Menard held your petitioner in slavery
in Illinois until about three years ago, where
he brought your petitioner to St. Louis , and put
her in the possession custody and care of Andre
Landreville of the city and county of St. Louis ; that
your petitioner was hired out by said Landreville in St. Louis and her wages
still continues to claim the direction and control
of your petitioner as a slave, either for his
own use or profit or as the agent of said
Menard and that she is still held in state of
slavery, by said Landreville and Menard . And your
petitioner represents, that she now has three in
fant childrens to wit one girl, named Virginia
who is now upwards of seven years of age, one girl
named Victoire , who is upwards of six years
old and one little girl named
Elizabeth who is about three years of age, who are
all held and claimed as slaves by said Menard
and Landreville And your petitioner represents
that she is advised--that being born in
the now state of Illinois and having been brought
up there, that she and all her infant children
are according to the Laws of the land en
tittled to their freedom from slavery, to exercise
and enjoy their natural liberty, of which they have
been unjustly deprived. And your petetioner represents,
that she can prove and establish the
fact of her birth and residence in Illinois by
persons who reside there. Your petitioner therefore
prays that their honorable Court will permit and order
that your petitioner be allowed and permitted to in-
stitute suits for the freedom of her self and her
said children against the said Menard and Landreville in and that
permitted to sue as poor persons, according to
the form of the statute in that case made
and provided, and your petitioner will ever pray

Mary her X mark
Peter Ferguson

State of Missouri
County of St Louis

Personally approved her
for the undersigned
a justice of the peace within and for the
county and state aforsaid, Mary , a woman
of colour, the same person who subscribed the
petition who being sworn by
upon his approval saith
facts set forth upon in the foregoing petition
by her subscribedas stated upon her own
knowledge are true, and that stated upon
the information and heresay of others, she
verily believes are true and can be proved, and
further, that she know of no person to whom
can prove the facts stated in her petition
to whom she thinks she could safely confide
her intention of instituting a suit for her freedom
without in- curring the hazard of living deprived
of the opportunity of making this application
by being sent out of the jurisdiction of this court
sworn to and subscribed

Mary X mark
Peter Ferguson Justice of the peace
County St. Louis Witness Madam La Chappel -- St. Louis at Rocheblave Madam Rocheblave - St. Louis John Edgar - Kaskaskia
Henry Bienvenu , Mr Pagie
Louis Biatt Kaskaskia

no 7 November Term 1827

Petition to be permitted
to sue for their
freedom

FiledJuly 21st 1827A G Clerk

State of Missouri
County of St. Louis .ss.In the Council court November term 1827.

Mary a free girl of color held in slavery who is permitted
by the court to sue as a poor person by the attorneys
John M. Bass & Issac McGirk assigned as counsel by said
court complains of one Francois Menard & Andre Landreville
of plea of Trespass with force & arms, for that they the said defen
dants herefore to wit on the first day of January was in the
year of one lord eighteen hundred & twenty seven much force
& arms at the county of St. Louis aforesaid unlawfully an assault did
make in & upon the said Mary , and then & there beat
bruised & ill - treated her the said Mary and then
& there imprisoned her and kept & detained her in prison
without any reasonable or probable cause whatsoever and
have ever since kept & detained her the said Mary in
prison & do still keep & detain her in prison against
her will contrary to the laws of this state and the said plaintiff avers that before and of the time of the committing the grievances
aforesaid she was & still is a free person and that the defendants held & detained her and still hold & detain her in slavery her the said Mary .
and other wrongs then & there did to the said Mary against the
peace of this state therefore the said Mary says she
is injured and has sustained damage to the amount
of five hundred dollars & therefore she sues

Bass & McGirk , PQ

County St. Louis The State of To the Sheriff of St. Louis County Greetings

We command you to summon Francis Menard and Andre Landreville that
they be and appear before the judge of our circuit court at the next term therof
to us held as the city of St. Louis within and for the county of St. Louis on the
Fourth Monday of November next time and these to answer unto Mary
of a plea of Trespass to the damage of the said plaintiff of Five hundred
Dollars and have yoU
then there this writ

Witness Archibald Gamble Clerk of our said
Court at office this 31st July 1827 Archibald Gamble Clerk

Executed this writ on Andre Landreville august 1827
by reading to him the declaration, writ & order of court
Francois Menard not found in my county Nov 10th
1827

R. Simpson Sheriff Francois Menard not found


R. Simpson Sheriff

Service$1.00non Est501.50

No 7
St. Louis Circuit Court
November Term 1827

To the clerk
This is an action of Trespass, assault & Battery and false imprisonment.
Issue a summons for the
Defendants

Bass & McGirk Atty PQ Filed 31st July 1827 Arch Gamble Clerk Amended Declarations filed 18th December
1827 Arch Gamble Clerk

H. Louis Circuit Court
July Term 1827
Tuesday July 31st 1827

John M . Bass presents the petition of Mary praying that she may be permitted to
institute suit against Francois Menard and Andre Landreville to establish her
right to freedom and that she may be permitted to sue as a poor person, therefore
the Court permits the said Mary to sue as aforesaid and direct that an action of
assault and battery and false imprisonment be commenced against the said
Francis Menard and Andre Landreville in the name of the said Mary and
assign John M . Bass esquire as her counsel and it is ordered by the court that
the said defendands permit the said Mary to have a reasonable liberty
of attending her counsel and the court when occasion may require it and
that the said Mary the plaintiff shall not be taken or removed out of the
Jurisdiction of this Court and that she shall not be subject to any severity
of treatment on account of her said application for liberty
A true copy of the order

Arch Gamble Clerk

County of St. Louis The state of Missouri To the Sheriff of H. Louis County greetings

We command you to summon Francis Menard that he be and appear before the Judge of
our Circuit court at the next term thereof to be held at the city of the St. Louis within and for the
county of St. Louis on the fourth monday of July next then and there to answer unto Mary
of a plea of Trespass to the damage of the said Mary of five hundred dollars and have you
then show this writ

Witness Archibald Gamble Clerk of our said Court at office
this Ninth day of May Eighteen hundred and twenty Eight Archibald Gamble Clerk

St. Louis Circuit Court

M. Andre Landreville

Take notice that on the
18th 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, in the office of J V Garnier Esquire
in this city we shall proceed to take the depositions
of witness to be read in the trial of the above
suit in behalf of the plaintiff

St. Louis Novr 6th 1827 Bass & McGirk Attys for Plaintiff

notice

Served a copy of the within notice on Andre Landreville November 8th 1827 in St. Louis

In for Timonds Deputy Sheriff
Service.50

St Louis Circuit Court

Mr. Andre Landreville

Take notice that on the
13th day of the present month between the hour
of nine o clock in the afternoon and five o clock in the
afternoon of that day at the office of J V Garnier Esquire
in this city we shall proceed to take the depositions
of witnesses to be held in the trial of the above
suit- in behalf of the plaintiff

St Louis November 6th 1827 Bass and McGirk Attys for pltff

November term 1827

And the said Andre Landreville by his attorney
comes and defends the
force and injury whereto And says he is
not guilty of the said supposed Trespass
assaults and Battery and imprisonment and detention
above laid to his charge or any part thereof
in manner and form as the said Mary by
her next friend Alexis Amelin
thereof impleaded against him and of this
he the said Andre Landreville puts
himself the county

And the said plaintiff cloth the like
McGirk & Bass for plaintiff
And his further plea in this behalf
the said Andre Landreville the says the
said Mary ought not to have or maintain
her aforesaid action thereof against him
because he says that he the said Andre Landreville at the times mentioned in
the said declarations had not nor declared
to have nor hath been nor doth he now declare
to have but disavoweth and disclaimeth
to have any title claim or interest in and to
the said Mary and this the said
Andre Landreville is ready to verify wherefore
he prays judgement if the said plaintiff ought to have or maintain her aforesaid action
against him

Attorney for defendant

filed November 29th 1827

A gamble clerk

State of Missouri
County of St. Louis ss.In the Circuit court

Deposition taken by virture of a notice
on the thirteenth day of November in the year eighteen
hundred and twenty seven and by consent at the dwelling
house of Madame Rocheblave between the hours of nine
oclock in the forenoon and five o clock in the afternoon of the
same day and to be read in evidence on the case now pending in the Circuit Court of the county of St. Louis
in which Mary , a woman of color who has for her freedom
is plantiff and Andre Landreville who is impleaded with
Francis Menard is defendent on the part of the plaintiff

Marie Louise LaChapell being duly sworn on her oath Saith
that she is acquainted with Mary the above named plantiff and
she knew her as the slave of the late Michel Bienvenu that she knew
her from her birth that she was born at Kaskaskia in the
state of Illinois has known her ever since and still knows her
to be the same at whose birth the attended

Sworn to on the day and
year and at the place first above
mentioned the plantiff being present
and the defendent having appeared
and afterwards with Before

Marie Louis Rocheblave being also duly sworn on her oath
saith that she has known Mary the above named plaintiff
and has Known her from the day she was born, that she
was born at Kaskaskia in the State of Illinois but she can not tell the day
or year, knew her as the slave of the late Michel Bienvenu
has seen her in this place but can not tell how long
she has resided there

Marie Louise Rocheblave

Sworn to and subscribed on the day and year, at the
place and between the hours first above the
plaintiff being present and the defendent having appeared
but with drew before the taking of the depositions before

The Clerk of the Circuit Court
St. Louis County

filed 3rd December 1827

A gamble Clerk

County Of St. Louis , Sct.The State Of Missouri ,To The Sheriff Of Saint Louis County-Greeting.

You are herby commanded to summon David Massey
that setting aside all manner of excuse and delay, he be and appear in proper person before the Judge
of our Circuit Court , forthwith at the City 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 Mary is plaintiff,
and Landreville impleaded is defendant,
on the part of the plaintiff; and have you then there this writ.

Witness, Archibald Gamble , Clerk of our said Circuit
Court , at the City of St. Louis , this 2nd day of
December in the year of our Lord one thousand eight
hundred and twenty eight Archibald gamble Clerk C.C.

plaintiff
for David Massey

Executed this writ upon David Massey
by his acknowlegment of serviceDecr
2nd 1828

R Simpson SheriffDeputy

And the said Mary for replication to the plea
of the said Landreville secondly above pleaded say that she
ought not to be barred and precluded from having and maintaing
her action aforesaid against the said Landreville for she
says that the said at the said times in her
said declaration mentioned and before the said several times
did claim to have and hold the said Mary as a slave and doth
still claim the said Mary as a slave and of this she the said
Mary puts herself upon the county

McGirk & Bass Attorneys for plaintiff
And the defendantdoth the like

refiledDecember 2nd
1828

A G Clerk

County Of St.Louis , Sct.The State Of Missouri ,To The Sheriff Of Saint Louis County - Greeting.

You are hereby commanded to summon & Marie
Louis Rocheblave , Madame La Chappelle
that setting aside all manner of excuse and delay, they be and appear in proper person before the Judge
of our Circuit Court , Forthwith, at the City 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 Mary is plaintiff,
and A Landreville impleaded is defendant
on the part of the plaintiff; and have you then there this writ.

Witness, Archibald Gamble , Clerk of our said Circuit Court ,
at the City of St. Louis , this 3rd day of
December in the year of our Lord one thousand eight
hundred and twenty eight. A Gamble Clerk C.C.

november 1828

Madame Lachapelle
M.L Rocheblave
forthwith

Executed on M L. Rocheblave and
Madame La Chappelle Decr 3. 1828
by reading to them the same on
John B Perron Decr 3. 1828.
Service 1.50

R Simpson Sheriff
Deputy Sheriff

County Of St. Louis , Sct.The State Of Missouri ,To The Sheriff Of St. Louis County--Greeting:

You are hereby commanded to summon Charles Dumont
that, setting aside all manner of excuse and delay, he be and appear in proper person before the Judge
of our Circuit Court , forthwith, at the city 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 Mary , woman of color plaintiff,
and Andre Landreville is defendant,
on the part of the plaintiff and have you then there this writ.

Witness, Archibald Gamble , Clerk of our said Circuit
Court , at the city of St. Louis , this third day of
December in the year of our Lord, one thousand eight
hundred and twenty eight Agamble Clerk C.C.

for Charles Dumont forthwith
for pltff

Executed this writ upon Charles Dumont by reading the same to him Decr 3rd 1828
Service 0.50

R . Simpson SheriffD. Deputy