To the Honorable the Circuit Court within and
for the county of St. Louis a the judge Thereof

The petition of George a man of colour
commonly called George Relfe humbly whereto
that your said petitioner was born a slave in
the state of Virginia the property of an James
Duff and intermarriage of one
James H. Relfe with the daughter of said
Duff your petitioner was by his said master
given and delivered to his said son in law
James H. Relfe that said James H. Relfe
after his marriage rended some time at
Wheely in Virginia and removed thence
in the year 1815 and after remaining
about one month at St. Genevieve in Missouri , settled in the then territory now state of Illinois and resided
there about two years. where he again
removed and settled in Missouri where
he has ever since resided your petitioner
further states that from the time of the marriage of said James H. Relfe your petitioner
continued in the possession of said James
H. Relfe and was held by him as a slave
and resided within in Virginia at
and in Illinois during the whole period aforesaid
your petitioner further represents that while
the said James H. Relfe held and kept your petitioner in Illinois (your petitioner being then about seventeen years
of age) he said James H recognized your
petitioner to be free and prevailed in him
your petitioner to bind himself by a contract in writing to serve him said James
H until he your petitioner should arrive
at the age of twenty eight years ; and the said James H . therefore prepared a writing
or caused it to be done which he represented
to be of the effect aforesaid and your petitioner
confiding in the truth of said representation and
being unable to read subscribed said paper
and your petitioner has since learned that
said writing if valid would bring him
to serve said Relfe ninety nine years
but your petitioner is advised that said
writing is utterly void in law and the said
James H. Relfe has frequently admitted that
he could not hold your petitioner is virtue
thereof and according by about a year or more
ago he said James H . informed your petitioner
on that he was free and suffered him to
go at large and act as a free man
which your petitioner did for several
months where the said James H ., contrivinghow to cheat your petitioner out
of the rights which he had acquired by occasion of the premises prevailed on the said James
Duff his father in law to reclaim your
petitioner and make sale of him and
the said James Duff after having given
and delivered your petitioner to his
and son in law and suffered him to
remain in his uninterrupted possession
for a period of thirty years. executed
as your petitioner is informed and believes a
power of attorneyto D. Linn of St. Genevieve authorizing him to sell your petitioner which
he accordingly did to one Augustus Jones
who sold him to one Thompson H. Ficklin

which sales your petitioner is informed and
believes was made for the benefit of said
James H. Relfe who received the proceeds
In virtue of which contrivances
the said Thompson H. Ficklin now claims your
petitioner as a slave and detains him
as such

Your petitioner upon the facts aforesaid
claims his freedom and prays that he may
be permitted to sue as a free person to establish his freedom and that he may
have the protection of your honorable court
until the cause shall be finally determined
according to the form of the statute in
such cases made And your
petitioner will ever pray

George Relfe

St. Louis Circuit Court
In vacation July 5th 1829.

It is ordered that the within petitioner be permitted
to sue as a poor person to establish his
right to freedom and Henry I Geyer is
hereby assigned to act as counsel for the petitioner

And it is further ordered that the petitioner
have reasonable liberty to attend his counsel
and the court where occasion may require ; and that the petitioner shall not be taken or removed
out of the jurisdiction of the court nor be subject
to any severity because of his application for
freedom.

Will C. Carr
Judge 3rd Circuit

St. Louis July 7th 1828. Served the above order on Thompson
H. Ficklin in the city of St. Louis by giving him a certified
Copy thereof

R Simpson Sheriff
By L. P. Timonds for Dept. Sheriff

In St. Louis Circuit Court .
July Term 1828

George a man of color other wise called George Relfe by Geyer his attorney complains of Thompson H. Ficklin
of a plea of Trespass, assault & battery
& false imprisonment For that the said
defendant on the fourth day of July in the
year of our Lord eighteen hundred and twenty
eight with force and arms, made an assault
upon the said plaintiff to wit at the county of
St Louis aforesaid and then and there beat, bruised and ill-treated him the said plaintiff
and then & there imprisoned the said
plaintiff, and kept and detained him in prison there without any reasonable or probable cause
whatsoever and against the will of the said
plaintiff and then there held and detained
him the said plaintiff and still holds &
detains him in slavery, and the said plaintif
avers that before & at the time of the committing the
said severy grievances he was and still
is a free person - Wherefore the said
plaintiff saith he is injured & hath sustained
damage to the value of five hundred dollars
& therefore he brings suit.

Geyer for plff

County of St. Louis State of Missouri
To the Sheriff of St. Louis county Greeting

We command you to Summon Thompson H . Ficklin that he be and appear
before the Judge of our 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 July Instant then and there to answer unto George Relfe of a plea of Trespass, assault and battery and false imprisonment wherefore the said plaintiff
saith he is injured and hath sustained damage to the value of four hundred
dollars and have you then there this writ

Witness Archibald Gamble Clerk of our said court
at Office this Fifth day of July 1828 Archibald Gamble Clerk

Judgement in favor of plff Book 5 page 264

Agamble Clerk

No 64
St. Louis Circuit Court
July Term 1828

vs.

Petition & order of Judge
Declaration one count assault
& false imprisonment
to recover freedom 500
Issue a summons with
a copy of the Judges
in - Geyer

Filed 5th July 1828 Archibald Gamble Clerk

the Copy of St. Louis , by writ Declaration & petition to him
to read and his acknowledging the service thereof

R. Simpson Sheriff Service $1.00
By L P Timonds Dp Sheriff

ads

And the said Defendant by his
attorney comes and defends and the force and injury
when he and says that he is not guilty of the
supposed trespass in the declaration mentioned
in manner and form as the said plantiff has
above thereof complained against him and of this
he puts himself upon the county

H R Geyer Setts
for Deft

ads

plea

filed December 1st 1828A gamble clerk

vs

In St. Louis Circuit Court

Thompson H Ficklin the above named
defendant will take notice that I shall attend
at the office of the Clerk of the Circuit Court
within & for the county of Randolph in the
state of Illinois on the second and third, ninth
and tenth days of March next and then
and there between the hours of eight of
the O'clock of the fore noon and six of the
clock of the afternoon on each of said days
taken the depositions of witnesses to be read
at the trial of the above cause on the part
of the plaintiff

St. Louis 12th Feburary 1829. George Relfe
by H Geyer his attorney

State of Missouri , Washington Countysct

Philip Boh being
duly sworn according to law deposith and saith
that on the eighteenth day of Febuaryinstant
he served Thompson H Ficklin the within renamed
defendant with the by serving him a copy thereof and with this
deponent with

P.Sworn to and subscribed before me A justice of the peace
within and for said county aforesaid this 26th day of
Febuary A.D. 1829Airs Hudspeth Justice of
the peace

Deposition of witnesses produced sworn and
examined on the twenty sixth day of February
in the year of our Lord one thousand eight
hundred and twenty nine, between the hours
of eight of the clock of the forenoon and
six of the clock of the afternoon of that
day at the dwelling house of William
Cole in the town of in the
county of Washington state of Missouri
before me a justice of the
peace within and for the county of
Washington aforesaid in a certain case
now pending in the Circuit Court of
the county of Saint Louis , in the state
of Missouri , between George Relfe
plaintiff, and Thompson H . Ficklin
defendant, on the part of the plaintiff.

James H Relfe of lawful age being produced
sworn and examined on the part of the
plaintiff, deposith and saith that he has
known since the month of september 1815 a certain
negro man named George , and believes him to
have been born a slave, the property of James
Duff of Rockingham county Virginia at which
time to wit in the month of september 1815 he came
into the possession of the said deponent. This deponent, has always considered and the said George .the property of Mr. Duff , but expected at his
andeath, the said George would be given to this
deponent or his family. This deponent brought
said George to the county of Randolph
State of Illinois in the month of January
in the year 1817 without the knowledge
of Mr. Duff (When this deponent left Virginia
he expected to reside somewhere in the state
of Missouri ) soon after this deponent took
up his residence in the State of Illinois Mr. Duff became acquainted with the fact
but this deponent has no recollection of
giving him information thereof or that
be had taken George there. This deponent
removed from the state of Illinois to the
state of Missouri in the month of November
1818 and at the particular request of
the said plaintiff George he brought him
with him. This deponent wished the said George to remain on this deponent's farm in Illinois . This said George continued to reside with this deponent in Missouri until the spring of the year 1827, when
after he had made a second attempt to commit
murder on the family of this deponent,
this deponent drove the said George from his
house, and informed Mr. Duff of the

Circumstance, telling said Duff who is the
father in law of this deponent, that said George
was then running at and declined
having anything further to do with him. Soon after the receipt of this Letter by Mr. Duff , Mr. Duff forwarded to Dr. Lewis F . Linn of
St . Genevieve a power of attorney to take up
George and sell him as his property, and
to pay the proceeds of such to this
deponent Dr. Lewis F Linn therefore sold
said George to Augustus Jones of Washington
County , and A. Jones this deponent
believes and has been informed sold the said
George to Thompson H Ficklin the deponent
in the above action. In1817 this deponent
took an indenture for fifty years on George
according to the Laws, of the state of Illinois
but this deponent never asked the permission his father in law Mr. Duff
nor does he
believe that Mr. Duff has any knowledge
of said indenture at this time

by plaintiff Witness you have stated that
George attempted to commit a murder in your
family, please state the circumstances of that affair?

Case. This deponent believes it was an the
Month of March in the year 1824he directed George the now plaintiff to go with the train to plow a garden for a neighbor; some time
in the course of the day George advanced into the
room where the deponent and some company
were sitting with an axe elevated in a striking
position swearing he would kill the rascal. This
deponent sprung towards him and with difficulty
avoided the blow. George then ran and was
followed by the deponent to the woods, where
he lost sight of him. George returned to the
house and endeavored to procure a furr, but
was prevented by a man of the neighbourhood
who happened to be in the house. The second attempt was made in the spring of
the year1827, when early one morning George came into the room took down
the furr. This deponent was shortly afterward
jarred by the cry of a negro woman
that George was going to kill Ned a negro man. This deponent followed George
who was in pursuit of Ned in the
bush threatening to shoot him and when this
deponent asked George to give up the furr
George pointed it at deponent and threatened
to shoot until this deponent stepped back

This deponent was under constant anxiety for
his family when absent from home on account
of George , and nothing insured him to keep
him as Comp in his family, but for the circumstance, that George was the son of an old
negro woman who had been the nanny
of Mr. Relfe ; and to whom this deponent
had given a promise to keep George in the
family.

by plff. How much money did
. A Jones give Dr. Lewis F. Linn for
George ?

two hundred and fifty dollars

by plff. Has Dr. Linn accounted with
you witness for the proceeds of George as sold to Jones ?

He has

by plff. at what time did it become known to your father in law Mr. Duff , that you
reside in Illinois ?

Soon after this deponent arrived there
by Defendant - Do you know the time the
defendant Thompson H Ficklin purchased said George
from Jones do you know of George informing said Ficklin
or telling him that he had no idea of of his being entitled to his freedom, & would serve Ficklin Defendant
as a slave if he the said deft would buy him George and
what you heard George say about that time as his promise to deft-before or afterwards purchase George ?

Deponent believes it was in the latter part of May
or first of June last he was informed by George that Thompson H. Ficklin had purchased him from Jones , and that he was
to to be sold to Scott and Rub of St. Louis , who was to put him aboard one of their steam boats, and if he conducted himself well for two years, he would then be emancipated,
previous to that time George informed the deponent that he
had abandoned the idea of getting his freedom.

James . H . Relfe .Sworn and subscribed to before me on the day at the
place and within the house first a aforesaid Aris Hudspeth Justics
of the Peace

Mildred Relfe of Lawful age being properly sworn and examined on the part of the plantiff
deposith and saith in answer to the following
interrogation that is to say

by plaintiff Witness do you know George the plantiff in the above action?

I do

by How long have you known
him ? Since his birth twenty
nine years

plantiff Was George born a slave if so
whose property was he ? He was born
a slave and was the property of Mr Duff
the father of this deponent

Have you ever owned or possessed
Him ? If so how did you obtain possession, from whom, for what purpose and on what
terms ?

my father Mr Duff observed to this deponant
that he would make her a present of George
if she would take him home this was in September
in the year 1815Therefore George came to the
possession of this deponent and her husband James H. Relfe and continued in possession from that
time until the year 1827

Did you reside in the state of Illinois ,if so in what county and how long ?
Given Yes lived in Randolph County Illinois
come there 3rd May 1817 and left there in the
month of November 1818

Did George the plantiff live
with you in Illinois and how long?

He did the whole of the time this
deponent resided there.

Was it knownto your father
Mr Duff that you resided in Illinois , at the time
George was with you there, if at what time
did it became known to Mr. Duff your father
that you resided in Illinois ?

Mr Duff knew of our residing in Illinois
shortly after this deponnent and family came there
but the precise time when Mr. Duff became thus
informed this deponent cannot state.

Where was George born ? In the state of Virginia county of

plaintiff, Where has George the above
Plaintiff resided in your possession? First in Virginia , secondly in Missouri , thirdly
in Illinois and fourthlyin Missouri

by plaintiff What knowledge has Mr. Duff
had of the place of residence of George
the plaintiff.

from the family corrospondence Mr. Duff must have known of the several removals
of this deponent, and also of Georges severals places of residence.

by plaintiff Have any arrangements been made
for the sale of George , if so to whom has he been sold, and how are the proceeds to be apportioned
and for whose use?

This deponent has understood that George was sold to A. Jones by Lewis F. Linn by power of attorney from Mr. Duff and that Jones sold George to Thompson H . Ficklin and that the proceeds of the sale of George as sold by Dr.
Linn , were for the use of James H.Relfe
the husband of this deponent.

Mildred - Relfe Sworn & subscribed to before me on the day
at the place and within the hours first afore said Aris Hudspeth Justice
of the Peace

I Aris A Justice of the Peace within and for the county
of Washington in the State of Missouri do here by certify that
James H. Relfe Mildred Relfe the Deponents were before me
Severally sworm to testify the whole truth of their knowledge
Touching the matter in controversy aforesaid that they were
Examined and their examination reduced to writing and by
hand Respectively, subscribed in my on the day
between the hours and at the place in that behalf first
aforesaid

Aris Hudspeth Justice
of the Peace24th July 1829

Justice feesissueing subpoena18 3/42 certificates on notices505 certificates on Depositing25 P T . McCabe 2.93 3/4summoning withness50$ 3.43 3/4

vs

In St. Louis Circuit Court

Thompson H Ficklin the above named defendant
will take notice that I shall attend at the
dwelling house of William Cole in the
Town of Caledonia in the county of
Washington , state of missouri on the twenty sixth
and twenty seventh days of febuary
instant and then and there between the
hours of eight of the clock of the fore noon
and six of the clock of the afternoon of
each of said days taken the deposition
of Witnesses to be read at the trial of the
above cause on the part of the plaintiff

Feburary 17 1829. George Relfe
by Geyer attorney

State of Missouri
Washington County

Philip Boh being sworn
according to him deposith and saith that
on the eighteenth day of February instant
be served the accused a writ on Thompson H. Ficklin the defendent by delivering him a copy thereof
and further the said P. Boh saith to wit

P. Boh

subscribed & Sworn to before me A Justice of the
peace within and for the county aforesaid this 24th day of
febuary A.D 1829

Aris Hudspeth Justice
of the peace

vs

notice

Issued & filed7 March 1827 A Gamble clerk Washington County

Extrait Louis Jesi Louis Louis
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and sent cerit
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certifie present extract are
Louis
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