No. 7
February 1814

Petition to sue,
for freedom as a pauper

Wit Peter Doolins St Louis , Benedict, S Louis
John Ken in S Louis ,

2 subp issued,

Trespass assault & Battery damage, 1000.

The aforesaid Jacob Horens,
by Carr his attorney, comes & defends, the charge,
of the wrong & injury, when and saith, that he
is not guilty, of this he puts himself upon, the
county, and for further plea in this behalf,
the said Jacob says, that the said plaintiff is & always, has been, a slave upon his birth, & the
propeprty, of him, the defendant, and that he
purchased him, of one condition Agasse Brooke,
in the state, of Kentucky , on the twenty fourth, day
of July eighteen hundred & ten, of the
said Bill the following Bill, of sale to wit, In consideration, of three hundred fifty,
dollars, to me this day granted, bargained, sold set over & delivered, a certain negro man, by the known by the name, of Bill aged twenty,
four or twenty five, years, or, there about, for which I warrant & defend, the bills, of s. negro,
all persons whatsoever, & also warrant him clear, of all impediments as witness my hand & seal, this 24th day of July 1810&”

&“
&“ Squire Brooke,

Wherefore, the said Jacob Honne prays judgment the whether the plaintiffs action might, not to be barred,

Carr atty p.d

The the plaintiff joins issue on, the first plea,, and
as to the second plea (protesting, that the defendant, did not obtain such bill of sale as therein alledged) for replication thereto, say

that he on the day of the assault, & false in
prisonment, said in his declaration way and
still is, free, and of this he puts himself,
upon the the county

Barton ,
for Deft,

Plea,

filed,22nd February 1814

Missouri Territory,
County of St Louis ,The United States of America , to the
Sheriff, of the county of st. Louis
Greeting

Whereas, a petition from Billy Tarlton, a man of
colour,, has been presented to the court of common pleas, of the
county of Saint Louis , praying the said court to admit the
said Billy Tarleton to sue, as a pauper, for his freedom he being
held (as he states) in unlawful servitude, by a certain Jacob Horine ,
affidavit of William Russell , of Joachim, on file that he has prob-
able reason to believe that the matters contained in the said petition,
are true whereupon the court assigned D Barton Esquire, as cousel
for said Billy Farleton,, to issue, against Jacob Horine , and take
the proper measures in this case, agreeably to the statute, in such
case made, and provided, And the court did order and dirict that
the said Jacob Horine , permit the said Billy Farleton, to have a reason-
able liberty, of attending his counsel and this court whenever occasion
may require it and that the said petitioner, shall not be taken
nor removed out of the jurisdiction, of this, court, nor be subjected to
any severity, because of his application for freedom
we command you that you summon Jacob Horine , if he may
be found within your bailiwick, that he be, and appear before,
the judges of our court of common pleas to he holden at the
town, of Saint , Louis within and for the said county of st Louis
on the third, monday of february next then &, there to answer unto
William Farleton,, otherwise called Billy Farleton,, otherwise called
Bill a black man, in a plea, of trespass assault, and, battery, and
false imprisonment, to the Damage of the said William Farlton,
otherwise called one, thousand Dollors as it is said,
have you then there this writ,

Witness, Mary P Leduc clerk, of our
said court, at the town, of St Louis ,

Territory of Missouri
County of Saint Louis In the Court of Common pleas,

William Farlton,, otherwise called Billy Farlton,
otherwise called Bill, a black man who is admitted
by the court here to sue in this behalf, as poor person, com-
plain of Jacob Horine , of a plea, of trespass, with force
and arms, for that heretofore, to wit on the first day of may
in the year of our Lord, one thousand eight hundred
and thirteen, the said , with force and
arms at the township of Joachin, in the county aforesaid,
and within the jurisdiction, of this court, did make
an assault, on him the said William Farlton,, and
him the said William ,, did then and there unlawfully beat wound, and abuse, take, enslave, and imprison,
and him the said William , in prison, and deprived
of his liberty there for a long time to wit from the
said first day of may in the year last aforesaid,,
untill the twenty fourth day of september then
next ensuing, without any reasonable and lawful
cause, and against the laws of this territory, did
detain and other outrages, on him the said
Williams , then and there committed. against the
peace of the united states of America , and of this
territory; and to the damage of the said William Farlton, otherwise called as aforesaid,, one thous-
and dollars therefore, he sues, by his counsel assigned, him by the court

D Barton,

No. 7

in assault
battery false imprisonment,

Let a writ of sum
mons its issue, in a plea
trespass, assault, battery and false imprisonment,
to the plaintiff's demage
one thousand, dollars
and attach to the writ
a full copy of the
order of the court in
this case.

Barton Executed
J.W.Thompson Shff

service,-.80 travel,3.60$4.30

This third day of October in the year of our Lord one
thousand & eight hundred and thirteen and of our inde-
pendence the thirty eighth

Mary P Leduc , clerk

Tr, ass, battery, false imprisonment,

Jacob , Horine the deft being, duly sworn,
says that he purchased, the plaintiff in Kentucky ,
as a slave, from one certain Squire Brooke living, in Jefferson county, that he send, by
his deponents brother, to said, Brooke to fur,
nish him, with the necessary proof, of
to said plaintiff time sufficient for him, to
return, to this term but, he has not, yet re, turned that he does not think he can safely,
go to trial, without the evidence, of said Brooke,
the Bill, of sale, which Deponent supposes,
is in his possession such other evidence, as he
can furnish, that deponent, does not think he ought, to permit, this case to go on, to trial without giving, him said Brooke on opportunity, of establishing, his right, to sale said plaintiff, as a slave, that he expects to recieve, an answer, from said Brooke, sufficient, to be ready, for trial, as the
next term,

Jacob Horine , Sworn, to in open court, this 27th June 1814M. P. Leduc

Territory of Missouri County of St , Louis The United States of America to the sheriff of the county of St , Louis Greeting

You are hereby commanded to summons Benedict & John
Keer that setting aside all manner of excuse, and delay they be and appear, in proper
Person before the judges of our court of Common, pleas on the twenty first day
of February next, at the town, of saint, Louis then & there to testify and the truth to,
say in a certain matter of controversy now pending in our said court wherein William
Farlton is, Plaintiff and Jacob Horine , defendant on the part, of the defendant, and
have you then there this writ.

Witness Mary , P . Leduc , of our said court of
Common, pleas at the town of St , Louis this third day of
December in the year of our Lord one thousand eight hundred
& thirteen and the thirty, eighth of the United States M. P. Leduc Clk

St Louis Common, pleas
February Term 1814

Subpa, for
Benedict

John Kerr of the couty
of St Louis

Executed

Service33

Jn. W. ThompsonShff D Barton atty for Plff,

Territory Of Missouri , County Of St. Louis sctThe United States of America to the Sheriff, of the county of St. Louis Greeting.

You are hereby commanded to summon Benedict Kerr & John Kerr,
that setting aside all manner of excuse and delay they be and appear in proper person
before the judges, of our court of common, pleas on the twenty eighth
day of junenext, at the town of St . Louis , then there to testify and
the truth to say in a certain matter of controversy now pending in our said court, wherein
Billy Farlton, is plaintiff and Jacob Horine ,
defendant on the part of the plaintiff, and have you then there this writ.

Witness Mary P Leduc ,
of our said court of common pleas, at the town of St . Louis this
twenty second day of May in the year of our
Lord, one thousand eight hundred and fourteen and of the
Independence of the United States , the thirty eighth Mary P Leduc , Clerk of St. L . C.C.P.

St louis Common, pleas
June Term 1814

subpa- for
Benedict & John Kerr
of S Loius county

Executed

service on Kerr.33Benedect.20non est.20milage -2.40$ 3.23

Barton 20

Territory Of Missouri , County Of St . Louis sct.The United States of America to the sheriff of the county of st Louis
Greeting

You are hereby commanded to summon Jno Benedict K & John Kerr,
that setting aside all manner of excuse and delay they be and appear in proper person
before the judges of our court of common pleas, on the fourth
monday of october next, at the town of St . Louis , then there to testify and
the truth to say in a certain matter of controversy now pending in our said court, wherein
William Farlton, is plaintiff and Jacob Horine ,
defendant, on the part of the plaintiff, and have you then there this writ.

Witness Mary P Leduc clerk,
of our said court of common pleas, at the town of St . Louis this
sixth day of august in the year of our
Lord, one thousand eight hundred and fourteen and of the
Independence of the United States , the thirty ninth,M. P . Leduc , Clerk of St. L . C.C.P.

St Louis coummon pleas
October Term 1814

subpa, for
mr. Benedict & copy
John Kerr
of St Louis county
1st leres

Executed

Two service,.66 traveling,2.10$2.76

D. Barton

Territory Of Missouri , County St . Louis sct.The United States of America to Joseph Kerr & John Bell,
Greeting

You are hereby commanded
that setting aside all manner of exuse and delay you be and appear in a proper person
before the judges of our court of common pleas, on the 25th
day of October, at the town of St . Louis , then there to testify and
the truth to say in a certain matter of contrversy now pending in our said court, wherein
William Farlton, a negro, is plaintiff and Jacob Horine ,
defendant, on the part of the plaintiff and have you then there this writ.

Witness Mary P Leduc , Clerk
of our said court of common pleas, at the town of St . Louis
25th day of October in the year of our
Lord, one thousand eight hundred and fourteen and of the
Independence of the United States , the 39thM. P. Leduc ck Clerk of St. L . C.C.P.

subp

John Bell &
Jos Kerr, forthwith,

Executed

Service- .66

Court of common, pleas
October Term 1814

To my attendance, this term,
as a witness four, Days $2.00
traveling to
60 miles

twenty miles 3.10

sworn, to before me
27th octr. 1814

a petition, in behalf, of a Billy Farlton