To William C. Carr Esquire Judge of the Circuit Court
for the County of St. Louis
The petition of Suzette alias Judith Bequette
alias Suzette Merry aged about twenty five years in behalf
of herself and her children. John aged about eight years
old, Angelique aged about two years, and Edmund
aged about two months, humbly represents to this honorable
Court, that she was born in the town of Ste. Genevieve
in the State of Missouri in the family of Nicholas
Beauvais, who held and claimed her as a slave from
the time of her birth until his death, which happened
sometime in the year eighteen hundred and fourteen or
fifteen, when upon the division of the property
of said Beauvais among the heirs of said deceased
she fell to the lot of Julie Jarrot , the daughter
of said Beauvais, who had intermarried with
Nicholas Jarrot of the town of Cahokia in the State of Illinois . That said Nicholas
as soon as he had attained possession of your
petitioner conveyed her to the town of Cahokia
in the State of Illinois , the residence of said
Jarrot , That your petitioner remained sometime
with said Jarrot , who transferred and sold your
petitioner to one McCracken the son -in-law
of said Jarrot by whom she was sold to one
Louis Pincinneau who sold her to John Reynolds ,
who now holds and detains or pretends to claim
and hold your petitioner as a slave, your
petitioner further represents that she has been
held and detained as a slave in Illinois ,
ever since she was first taken there by Jarrot
first by said Jarrot then by McCracken, afterwords
by Pincinneau & now by said John
Reynolds .
Your petitioner is advised and believes that
neither she nor her children, who were all, born
since your petitioner was taken to the state of Illinois ,
can legally be held in slavery, She therefore
humbly prays this honorable Court permit her to institute
suits for herself and children to recover
their freedom and that
she and her said children may sue as poor persons
to establish their freedom aforesaid and that
this honorable Court would assign them Counsel
and your petitioners will ever pray
State
Jos Charless Jr.
Judith Bequette
State of Missouri
County of St.Louis In the St.Louis Circuit Court march Term 26th march 1828
Joseph Charless Jr . presents the petition of Judith Bequette in behalf of herself and her children praying
that they may be permitted to institute suit against John Reynolds to establish their right to freedom
and that they may be permitted to sue as poor persons thereupon the court permits the said Judith
Bequette and her said children to wit John, Angelique, and Edmund to sue as aforesaid and direct
that an action of assault and Battery and false imprisonmentbe commenced against the said
John Reynolds in the name of the said Judith Bequette and in the name of the said John ,
Angelique and Edmund by their next friend and assign Joseph Charlesd Jr. Esquire as the counsel
and it is ordered by the Court that the said defendant permit the said Judith Bequette , John ,
Angelique and Edmund to have a reasonable liberty of attending her counsel and the court when
the occasion may require it and that the said Judith , John , Angelique and Edmund the Plaintiffs
shall not be taken or removed out of the Jurisdiction of this Court and that they shall not be
subject to any severity of treatment on account of her said application for freedom
A true copy of the order
Archibald Gamble Clerk
vs
John Reynolds
Petition filed
March 26th 1828
A.G.Clerk
In the St. Louis Circuit Court
July Term 1828 County of St. Louis Sct.
Suzette alias Judith a free woman of
colour who is permitted by the Court to sue by
her next friend, as a poor persons by Charless her attorney
assigned as counsel by the Court Complains of John Reynolds
of a plea of Trespass, for that the said defendant heretofore to wit on the first day of January eighteen hundred
and twenty eight, with force and arms at the city of
St. Louis , unlawfully an assault did make upon the
body of said Suzette alias Judith , and then and there
did beat bruise and ill treat her, said Suzette , and
then and there imprisoned her said Suzette , and kept and
detained her in prison, without any reasonable or probable
cause whatsoever against the will of said Suzette
and has ever since kept and detained her said Suzette
in prison, and still keeps and detains her in prison
without any reasonable or probable cause, whatsoever con-
trary to the laws of this state.
And the said defendant avers that before and at the time of
the committing of the said several grievances she was and
still is a free person and that the said defendant holds and
detains her in slavery
and the said defendant other wrongs
then and there did to her said to her said Suzette against
the, peace and dignity of the state. Wherefore the said
Suzette says she is injured, by the said defendant, and
has sustained damaged to the amount of six Hundred
dollars and therefore she sues. Charless Jr. atty for pltff
State of Missouri sct.The state of Missouri To the Sheriff of St. Louis County Greeting
We command you to summon John Reynolds that he be and appear before the
judge of our circuit count 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 next. Then and
there to answer unto Suzette alias Judith of a plea of Trespass wherefore the said plaintiff
says she is injured by the said defendant and has sustained damages to the amount
of six hundred dollars and have you then there this writ
Witness Archibald Gamble Clerk of our said Court at
office this 4th day of April Eihteen Hundred and
twenty Eight Archibald Gamble Clerk
State of Missouri
County of St. Louis
In the St. Louis Circuit Court March Term 26th March 1826
Joseph Charless Jr . presents the petition of Judith Bequette in behalf of herself and
her children praying that they may be permitted to institute suit against John Reynolds to establish
their right to freedom and that they may be permitted to sue as poor persons thereupon the court permits
the said Judith Bequette and her said children to wit John, Angelique and Edmund to sue
as aforesaid and direct that an action of assault Battery and false imprisonment then commenced
against the said John Reynolds in the name of the said Judith Bequette and in
the name of the said John Angelique and Edmund by their next friend and assigned
Joseph Charless Jr . Esquire as their counsel and it is ordered by the court that the said defendant permit
the said Judith Bequette , John, Angelique and Edmund to have a reasonable liberty of attending
the counsel and the court when the occasion may require it and that the said Judith , John ,
Angelique and Edmund the plaintiffs shall not be taken or removed out of the jurisdiction
of this court and that they shall not be subject to any severity of treatment on account
of their said application for freedom. A true copy of the order
A Gamble Clerk
No9
St. Louis Circuit Court
July Term 1828
Suzette alias Judith
vs
John Reynolds
Narr
This is an action
of Trespass false im
prisonment. Let a
summons issue damages $600
Charless Atty Filed 4th April 1828 Archibald Gamble Clerk
July 1828
John Reynolds not found
in my County.
R. Simpson Sheriff