In the Circuit Court
3d. Judicial Circuit March Term AD 1832.
St Louis to wit Charlotte a girl of colour & infact
under twenty one years of age by Edward Bates
her next friend complains of Green Crowder
of a fees of herpap. For that the said defendant
on the twenty third day of November in the year
1831 with force Law openated the said plaintiff
to wit at the county aforesaid them there beat
& ill-heated her the said plaintiff & detained her in prison there without any reasonable a pro-
bable cause whatsoever for a long time to writ for
the space of twenty four hours the next follow-
ing contains to the law of the land against the
will of the said plaintiff and often wrongs to
the said plaintiff then & there did against the peace
& dignity of the state of Missouri & to the damage of
the said plaintiff of one hundred dollors & therefore she
brings her sent &c.
And the said plaintiff avers that before & at
the time of the committing the prisoner afore-
said she was & still is a free person that the
defendant held & detained her & still holds & de-
tains her in slavery.
Bates
I acknowledge myself willing to procecute to next
friend of Charlotte the action commanced by her
against Green Crowder for her freedom, in
the circuit court of the county of St Louis -
25th Nov: 1831. Edw. Bates
County of Saint Louis Ss
The State of Missouri To the Shariff of the County of Saint Louis Greeting
We Command you to summon Green Crowder that he be and
appear before the judge of our Circuit Court at the next March terms thereof
to be held at the City of St Louis within and for the county of Saint
Louis on the fourth Monday of March next then and there to answer
unto Charlotte a girl of Color & infant under twenty one years of age
by Edward Bates her next friend of a plea of trespass to the damage
of the said plaintiff of one Hundred dollars and have you then
there this writ.
Witness Archibald Gamble Clerk of our said
Circuit Court at office this Twenty fifth day of
November Eighteen Hundred and thirty one Archibald Gamble Clerk
Copy of the order of the judge permitting plaintiff to sue
State of Missouri third Judicial Circuit to wit on the foregoing petition
theirin the called Sarah is hereby permitted to sue as a poor person
as well is her own behalf as also in that of her child Charlotte to establish their
right to freedom and Edward Bates Esq. is hereby assigned her as counsel this
moreover ordered that for the purposes aforesaid the said Thenia or Sarah have
reasonable liberty to attend the court & her counsel whenever occasion may
require that neither she nor said child be subjected to any severity on account
of her application for freedom & that they be not removed out of the jurisdiction of this
court - Given under my hand this 24th of Nov 1831
Will C. Carr a copy of the order of the judge A Gamble Clerk
served this writ on Gree Crowder by
reading it & the declaration to him on
the 26th day of November 1831, in the
city of St Louis . I also at the same time
read to him the copy by the order of the to will
C. Carr Judge of the 3rd. Circuit
sum $ 100
ads Charlotte
And the said Green browder by
his attorney comes and defends the force and injury when
and says he is not guilty in manner and form
as the said plaintiff hath in her said declaration
complained against him and of this he puts
himself open the county the
for depts
No. 10
Saint Louis Circuit Court
March Term 1832
Charlotte
a colored girl
action trespass for
freedom $100,
Issue a Summon
Barty
Filed 25th, November 1831 Archibald Gamble Clerk
Plea filed april
20th 1832
A Gamble Clk