To the Honorable the Circuit Court of St. Louis County
at the present July Term of said Court, now in session,
The petition of Carey Euston , alias Ootow , a free man of
Colour held in slavery humbly & presents: That he was born
as a slave, in the family of one Robertson , in the Town of Petersberg
in the state of Virginea in or about the year 1790, when
and where your petitioner was held in bondage by said
Robertson , until about the year 1800 or 1801 when your
petitioner was end by virtue lan execution against said
Robertson , as the slave of said Robertson sula, when your petitioner
was purchased by one Richard Cox , and by him he
moved from the state of Virginia to Spring=field, Washing =
=ton
County in the state of Kentucky immediately. When the
said Richard Cox helld your petitioner in bondage and treated
him, as his slave, until about the year 1815 or 1816, when
the said Richard Cox sold your petitionor as a slave to
one John Hughes of Springfield , in Kentucky , which said
last purchaser, John Hughes , kept and detained your petitioner
in slavery in Springfield of onesaid until about the
year 1818 or 1819, when the said John Hughes
sent your petitioner to the state, of Misouri ; (then Territory,
by his brother Thomas Hughes , who took your petitioner
to the Tour of Palmyra , in this state, by whom and
when your petitioner was held in slavery four or five
months, when the said Thomas Hughes ,
removed to Galina , or the Fover River Leads mines in the
state of Illinois , and took your petitioner with him, where
the said Thomas Hughes held and treated your
petitioner as a slave, and set and kept your petitioner
digging lead ore for him the said Thomas Hughes , in
the state of the Illinois for until about the year 1824 or 1825,
Your petitioner further states, that he was then removed
by said Thomas Hughes , from the lead mines in the
state of Illinois aforesaid, to Palmyra , in this state, when
the said Thomas Hughes sold your petitioner as a slave
to one William Mulder , who immediately took your
petitioner to H. Charles in this State, and sold him as a slave
to one William Ewton , alias Ootow , who held your petitioner
in bondage and slavery in H. Charles , until his death, which
happened only two or three years ago, Your petitioner states
further, that since the death of the said William Ewton
alias Ootow , he was sold as the property of the Estate of
the said William Ewton , alias Ootow , and slave of said
Estate, and purchased by Benjamin Trilder , who brought
your petitioner to St. Louis , in the year 1827 When the said
Benjamin Trilder , now holds and treats your petitioner as
a slave, by exercising all control over him, and receiving
the benefit and labor of your petitioner at mile and pleasure,
and whom the said Benjamin Trilder has held your petitioner
in bondage and slavery for the last two years.

Your petitioner alledges, and so believes the fact to be that
that, having resided in the state of
Illinois , and been carried there by a person who located him
=self this and Carried on business there, for a considerable time
as above stated, and your petitioner having been forced away
out of the said state of Illinois , much against his mile, and
in the night reason - after having resided there for a long period
of time,- that he is by the laws of the lands entitled to his
freedom, - Your petitioner therefore prays this honorable Court,
that he may be permitted to institute a suit in this Circut , against
Benjamin Trilder , for the purpose of establising his right to
freedom, and that your petitioner may be permitted to sue
as a poor person; and that this honorable Court will appoint
or assign Counsel to your petition to prosecute his right or

or claim to freedom, , also, your petitioner prays this
honorable Court to make an order that your petitioner be
permitted to attend his Counsel or this Court, or reasonable
liberty to attend either when occasion may require it,
and that your petitioner shall not be taken or removed
out of this jurisdiction of this Court, nor be subject to any
severity of treatment because of his application for freedom,
which said several orders, if this honorable Court, will make
for your petitioner, he feels assured that he will be
able to fully establish his freedom by then established evidence,
and to the full satisfaction of this honorable Court, and
as in duty bound your petitioner will ever pray .

Witness-- Peter Ferguson
Carey his X mark Ewton alias Ootow

State of Misouri
County of St. Louis Sct.

Personally appeared beore me, the undersigned
one of the Justice of the peace within and for the Country
of St. Louis , the above named petitioner Carey Ewton alias
Ootow , who being duly sworn, depases says, that the facts
set forth in the above petitioner so far as stated on his own
knowledge are correct and true, and those stated on
the information of others he believes to be so = and further, that
he has cause to suspect and believe, and doth suspect and
believe that he is about to be removed without the jurisdic=
tion of this Court, to prevent this applicant from establishing
his right or claim to freedom -

Sworn to & subscribed before
me this 10th August 1829 Peter Ferguson Justice of
the peace
Carey his X mark Ewton alias Ootow

S. Louis Circuit Court
July Term 1829

August 11th Tuesday

John T. Darby presents the petition of
Carey , Ewton alias Ootow praying that he may be permitted
to institute suit against Benjamin Wilder to establish his
right to freedom and that he may be permitted to sue as a
poor person - thereupon the Court permits the said Carey
Ewton alias Ooton to sue as aforesaid and directs that
action of assault and battery and fase imprisonment to be
commenced against him the said Benjamin Wilder in the
name of the said Carey Ewton alias Ootow and assign
John T. Darby as his Counsel and it is ordered by the Court
that he said defendant permit the said Carey Ewton alias
Ooton to have a reasonable liberty of attending his counsel
and the Court when occasion may require it and that the said Carey
Ewton alias Ooton , the plantiff shall not be taken or removed out of the
Jurisdiction of this court and that he shall not be suffered to
any severity of treatment on account of his said application
for freedom

A. True Copy -
Testo. Archibald Gamble Clerk

Carey Ewton alias Ooton
to the St. Louis
Circuit Court

filed Augut 17th 1829

A . Gamble Clerk

St. Louis Circuit Court
November Term 1829County of St. Louis Sct.

Carey Ewton alias Ooton , a man
of color by Darly his attorney complains of Benjamin
Wilder , of a plea of trepass, assault and Battery and
false imprisonment, For that the said defendant on the
eight day of August in the year of our Lord eighteen
hundred and twenty nine, with force and arms
made an assault upon the said plaintiff, to wit, at
the County of St. Lous aforesaid, and then
and there beat bruised and ill treated him, the
said plaintiff, and then and there imprisoned
him the Said plaintiff, and kept and detained
him in prison then, without any resonable or probable
cause whatever, and against the will of the said
plaintiff and then and there held and detained
him the said plaintiff and there holds and detains
him in slavery, and the said plaintiff over, that
before and at the time of committing the said
several grievances, he was and still is a free person
wherefore the said plaintiff saith he is injured
and hath sustained damage to the value of
five hundred dollars and therefore he bring
suit

Darby for plff

Executes this writ on Benjamin Wilder in city of St. Louis
August 19. 1829 he refusing to hear the Declaration & summons
and order of court had and acknowledging serve

Service$ 1.00 R Simpson Shf
By Jn Brotholem Dshf

No 10
In the St. Louis Circuit
Court - Nov. Term 1829

alias
a man of color
vs

filed 11 August 1829

Arch Gamble Clk

This is an action of trepass,
assault & Battery & false
imprisonment - suit for freedom
one Count only -
Damage $500

Let a summons issued
the orders of Court, petition accompany
-

Darby for plff

County of St Louis Ss.The State of Missouri To the Sheriff of St Louis County
Greeting.

We command you to summon Benjamin Wilder
that he be and appear before the Judge of our Circuit
Court the next term thereof to be here at the City
of St. Louis within and for the County of St. Louis on the
fourth Monday of November next term and there to
answer unto Carey Ewton alias Ooton a man of color
of a plea of trespass assault and Battery to the damange
of said plaintiff of five hundred dollars and here
you then have this writ

Witness Archibals Gamble Clerks of our
Said Court at Office this Eleventh day of
August 1829
Archibald Gamble Clk

County of St. Louis ssThe State of Missouri To Benjamin Wilder - Greeting

You are hereby commanded to have the body
of Carey Ewton alias Ooton detained in your Custody
as it is said under a safe and secure conduct together
or with the day and cause of his being taken and
detained by whatsoever name he shall be called in
the same before our Circuit Court -within and for the County
of S. Louis immediately after the receipt of this writ
to do and receive all and those things
which our said Court shall then and their consider
concerning him in this behalf and have you then
there this writ -

Witness Archibald Gamble Clerk
of our said Court at office this
Eleventh day of August 1829 Archibald Gamble Clk

This writ was executed in S Louis August 13 1829 by
reading the same to Benjam Wilder

R Simpson Shf
By Jno Brothelin Dshf
Serve$1.00

vs

November Term 1829

ads
alias

And the said Benjamin
by his attorney comes and defends
the wrongs and injury when . and
says that he is not guilty in manner
and form as the said Carey hath
in his said declaration above thereof
complained against him and of
this he puts himself upon the County

atny for Dfn
filed 24 Nov 1829 Arch Gamble Clerk

No 10
St. Louis Circuit Court
November Term 1829

ads
alias

plea not Guilty

atny for Dfn
filed 24 November 1829
Archibald Gamble Clerk

non fiut Book 5 page 517

A Gamble Clerk

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

You are hereby commanded to summon Elijah Smith - Puirs Misseau
Fevo Vallé - Barney Handley and James Barry
that setting aside all manner of excuse and delay, they be and appear in proper person before
the Judge of our Circuit Court , on the fifth day of April 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 Cary Ewton alias Ooton is plaintiff,
and Benjamin Wilder is defendant, on the
part of the plaintiff; and have you then there is writ.

Witness, Archibald Gamble , Clerk of our said Circuit
Court , at the city of St. Louis , this Twentieth day
of March in the year of our Lord one thousand
eight hundred and Thirty Archibald Gamble Clerk C.C.

March Term 1830

Cary alias
vs

for plaintiff
Elijah Smith
Fevo Vallé
+ Barney Handly 27
+ James Barry 27
on 5th April

Executed this writ on Louis Barry & Barry Haudly ,
March 27th and E. Smith Fevo Valle & Puvre
Mupian not found

R Simpson Shf By J. DshfServe 1.00
3 n 5. 37E

County Of St. Louis , Sct.State of Missouri ,To the Sheriff of S Louis County---Greeting.

You are hereby commanded to summon Jno H Price & Samuel
Merry
that setting aside all manner of excuse and delay, they be and appear in proper person before the Judge
of our Circuit Court , on the 22nd day of August 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 Cary a man of color is plaintiff, and
Benj . Wilder is defendant, on the part of the
plff; and have you then there this writ.

Witness, Archibald Gamble , Clerk of our said Circuit Court ,
at the City of St. Louis , this 15th day of August in
the year of our Lord one thousand eight hundred and thirty-One A Gamble Clerk, C.C.

Caryvs

for
X Gnoch Price
Samuel Merry

22nd August for Plantiff

Served this writ on Enoch
on the 16th Augt 1831
G Merry not

Jno