Disclaimer of 13 p 228- order of liberation p 425 (423)
Judgt for plff13 p 418

Mary ( a colored woman)
vs
James alias E.C. Dougherty
J Richmond J Curle
Summons

Trespass $ 1000.
Suit for freedom-

Davis & Gale atty

County of St Louis
State of Missouri

It is hereby ordered that Mary
be allowed to sue as a poor person and Davis
& Gale are assigned as her counsel and it is further
ordered that she have reasonable liberty to attend
her counsel & the court as occasion may require
that she be not removed out of the jurisdiction
of the St Louis Circuit Court and that, she be
not subject to any severtiy on account of her
application for freedom as witness my hand this
fourteenth April A.D. 1842 Bryan Mullanphy
Judge of the 8th Jud. Cir of the State of Mis

-souri

Filed April 20th 1842
Jno Ruland Clerk
Free

Executed this wirt, on the 21st day of April, 1842, in the County of St. Louis , by reading it and the annexed declaration to Richmond J Curle - James alias & EC Dougherty not found in my County

Marshall Brotherton Sheriff
By Joseph W M Clung Dep'y

service$1.00.50$ 1.50

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

We command you to Summon James alias E C
Dougherty and Richmond J Curle if they
be found in your County. that they be and
appear
before the Judge of our Circuit Court , on the first day of next term thereof, to be
held at the City of St. Louis , within and for the County of St. Louis , on the third Mon
day of July next, then and there to answer unto Mary
(a colored woman) of a plea of Trespass
to the damage of said plaintiff of one thousand
dollars: And have you then there this writ.

Witness, John Ruland , Clerk of our said Court,
with the seal thereof hereto affixed, at office, in the
city of St. Louis , this Twentieth day of
April in the year of our Lord eighteen
hundred and forty two. Jno Ruland Clerk.

I acknowledge myself bound for all costs that may accrue in the above cause.

Witness my hand amd seal, at St. Louis , this day of 184

In St. Louis Circuit Court
July Term 1842

Mary (a colored woman)
vs
James Dougherty alias
E. C. Daugherty
and
Richmond J. Curle

for false
imprisonment


Mary a colored woman plaintiff in
this suit complains by her attorneys of James
Daugherty alias E. C. Daughterty and Richmond J Curle defendants
of a plea of trespaps


For that the defendants heretofore,
to wit, on the thirteenth day of April in the year
of our Lord eighteen hundred and forty two in
the county of St Louis and state of missouri with
force and made an assault on said plain
tiff and then and there beat, bruised and ill-treated
her, and then and there imprisoned her and
kept her imprison without any reasonable
or probable cause whatever for a long space
of time to wit for the space of two days
then next following contrary to then laws of
the state of Missouri and against the will
of the plaintiff and other wrongs to the
said plaintiff then and there did
against the peace of the state of
Missouri to the damage of the said
plaintiff in the sum of one thousand
dollars


and the said plaintiff avers that before and at the time of the
committing of the greivances aforesaid
by the said the said plaintiff
was and still is a free person and that
the said defendants held and still hold
her in slavery.


and the plaintiff avers that the true christain
name of the aforesaid Dougherty is unknown
to the said plaintiff and the he passes by
the name of E.C. Daugherty and James
Daugherty
Wherefore He brings suit by
her attorneys

Davis & Gale

To the Honorable Bryan Mullanphy Judge
of the Circuit Court within and for the County
of St Louis and State of Missouri

Respectfully and humbly represents
your petitioner, Mary a colored girl, that
about seven years ago the was taken from
the State of Kentucky , where she had been the
servant and slave of George Wilson , by him
the said Wilson and carried to Du

a place in the Territory of Wisconsin ;
That the said Mary was so taken to the Territory
of Wisconsin by him the said George Wilson
claiming to be her master and owner, for
the purpose of introducing her into the said
Territory as a slave, and was then and
there sued and held by him as a slave
and made to labor and serve as such for a
long space of time to wit for the space of
five years, he the said Wilson during that
time being a resident of the Territory of
Wisconsin ; That subsequently, be the said
Wilson took your petitioner to Dubuque a
place in the Territory of Iowa , where your
petitioner resided with said Wilson and labored
and served in his family as a slave, for the
space of one year; that subsequently she
left the said Wilson and resided with one
Davis in Dubuque aforesaid who paid her
wages for her labor; that subsequently she resided
with Judge Wilson of Dubuque who is repu

ted to be a brother of the said George Wilson
and that said Judge Wilson paid your petitioner wages for her labor while in his family;
that on the evening of the 8th day of April
1842. your petitioner was taken from the house of
the said Judge Wilson after right fall by force
and arms, by one James Dougherty , and being
placed on board the steam boat New Brazil , was
taken to the City and County of St. Louis
when she has since been under the control
and management,, and subjected to the
orders of the said Dougherty and one Richmond
J. Curle of the City and County of St. Louis .


Your petitioner further states that the
said Prairie Du and the said Dubuque
are in places in the United States where
slavery is not allowed by the laws of the
United States and therefore your petitioner is
free and not a slave, and not subject by the
laws of the State of Missouri or of the United
States to the Control of the said Dougherty or
the said Curle or subject to the owner

ship of said Dougherty or said Curle or any
other persons, in any manner or form.


And further your petitioner respect

fully prays that she may have leave by
an order of this Honorable court to sue
the said Dougherty and the said Curle , one or both
of them, or any other person or persons
claiming to exercise ownership over her, to
establish her right to freedom, as a poor
person, and that counsel may be assigned
her. And further that the aforesaid

petitioner may have reasonable liberty
to attend her Counsel and the Court as
occasion May require; that the be not
removed out of the jurisdiction of the court
and be not subject to any severity on
account of her application for freedom.

And as in duty bound will

State of Missouri
St Louis County
Ss

This day personally appeared
before me a Justice of the peace within and
for the County of St Louis , Mary , a colourd girl,
the foregoing petitioner, and being duly sworn
under oath that the facts put forth in the
foregoing petitioner are true in my petition

Mary x her
mark
Sworn to & subscribed before
me this 14th day of April 1842
DuBouffay Fremon
Justice of the Peace
for St Louis County

County of St Louis
State of Missouri

It is hereby ordered that Mary be allowed
to sue as a poor person and Davis
& Gale are assigned as her Counsel, and
it is further ordered that she jave reasonable
liberty to attend her counsel & the court
in may require ; That she be
not removed out of the jurisdiction of the
St Louis Circuit Court and that she be not
subject to any severity on account of her applicationfor freedom- as witness my
hand this fourteenth April A.D. 1842

Bryan Mullanphy
Judge
Cir of the State
of Missouri -

State of Missouri
County of St. Louis

This day personally appeared before
me a Justice of the Peace, Mary , the foregoing petitioner
and being duly sworn, on her oath says, that all
the facts and statements set forth in the foregoing
petition are true in every particular; and said affiant
in addition to the foregoing, further states on her oath
that she has reasonable cause to believe and does fully
believe that she the said petitioner is about to be restrained
by the said Dougherty and the said Curle of reasonable
liberty of attending her Counsel & the Court that she is
about to be removed beyond the jurisdiction of the
Circuit Court of St. Louis County , and subjected to
severity on account of her application for
freedom.

Mary herx
mark
Sworn to subscribed before me
this 14th April AD 1842
DuBouffay Fremon
Justice of the peace
for St Louis County

The State of Missouri To
Marshall Brotherton Sheriff
of the County of St Louis in

State of Missouri To the Sheriff of St Louis County Greeting

Whereas one Mary was on this Day brought
before Bryan Mullanphy the Judge of our
Eighth Judicial Circuit by writ issued
under fourth & fifth sections of an act
entitled “an act to enable persons held
in slavery to sue for their freedom”
and one Richmond J Curle appearing
before our said Judge & praying
that the hearing be adjourned until
tomorrow at nine oclockAM. in
order that James alias E.C. Dougherty who
claims to be the owner of said
Mary may being notified whatever
he will enter recognize as provided
by said act, you are hereby com

manded to keep the said Mary in
your custody untill tomorrow
morning at nine O'Clock and have
her before our said Judge at
that hour at the Jail in the City
and county of St Louis in the State
of Missouri -
for which this shall be your
authority. as Witness, the the hand of
out said Judge at Chambers in
the city & county of St Louis in the
State of Missouri Bryan Mullanphy

Judge of the 8th Judicial
Circuit of the State of Missouri

the State of Missouri -

The Judge of the Circuit
Court of our Eighth Judicial
Circuit being satisfied that
Mary who hath been permitted
by our said Judge to sue for
her freedom is about to be removed
out of the Juridiction of our said Judge's
courts, We do hereby command you
to seize the said Mary , wherever she
may be found and bring her before him
at the office of . Davis and Gale
in the city and county of St Louis at
three O clock of the afternoon of this
day and to summon the person in
whose possession she may be found
and any person who may claim her
and especially James Dougherty and
Richmond J. Curle , to appear before our
said Judge at the same time and place
& this writ-
As witness the hand of our said
Judge at Chambers in the city & County
of St Louis this fourteenth April
A.D. 1842-

Bryan Mullanphy
Judge
Cir of the State
of Missouri

In the matter
of the application
of Mary a
coloured woman
to sue for freedom
15 April
Sworn $1.87
month=

In obedience to this writ I have shown Mary within before the Hon Judge Mallan

phy at the time and place as by this
writ I am commanded and have
Summoned Richmond S.Curle
by reading to him this writ
James Doug herty not found
in my County

M Brotherton Sheriff
St Louis April 14th 1842

State of Missouri
County of St Louis
ss.

And was on this Fifteenth day of April
in the year of our Lord One thousand
eight hundred forty two. Before
Bryan Mullanphy Judge of the eighth
Judicial Circuit of the State of Missouri
appeared E.C. Dougherty by his counsel
Wm . M Esqe. and the said
Mary by W Gale Esqu and the said
Dougherty having declined entering into
the required by law, it is ordered
that Marshall Brotherton Esqe Sheriff take
possession of said Mary a colored wo

man the petitioner for freedom and hire
her out to the best advantage from
time to time during the of
the suit and take from the
hirer payable to the State of Missouri
in the sum of seven hundred Dollars
and with security as the said Sheriff
shall , conditioned, that said petitioner
shall during the of her suit
have reasonable liberty of attending
her counsel and the Court, that she
shall not be removed out of the
Jurisdiction of the St Louis County Circuit
Court where her suit is to be brought
and that she shall not be subjected
to any severity on account of her ap
plication for freedom and that the
hirer will pay the service to the sheriff
and return the petitioner at the of the term for which she is hired which
shall be six months, or as soon as the ac
tion is determined- witness was heard this
fifteenth April the year above written

Bryan Mullanphy
Judge of the 8th
Cir of the State of Missouri

No 23
In St. Louis Circuit
Court July Term 1842

Mary (a colored person)
vs
James Dougherty alias
E.C. Daugherty
and
Richmond J. Curle

Suit for freedom

Davis & Gale
attonys