State of Missouri Circuit Court Third Judicial Circuit St Louis
CountyMarch Term AD 1831To the Honorable William C Carr Judge of said
Court in Chancery Sitting

Your orators Jonathan & Gilbert
men of color represent unto your honor that heretofore
to wit on the 20th day of May in the year of our Lord
eighteen hundred & thirtyat said county Coleman Duncan
whom your complainants pray may be made defendant
to this bill had seized & taken into his possession & there
held in his custody the said Gilbert who is the brother of
said Jonathan & the said Coleman then & there claimed
siad Gilbert as his slave for life offered to sell him
as such to said complainant Jonathan who is a free man of color & threatened that if said
Jonathan would not purchase said Gilbert to take
said Gilbert to some other place & sell him as a slave
The said Coleman proposed that said Jonathan
should give him in advance one hundred Dollars
& said Jonathan & said Gilbert should give him
there obligation for three hundred Dollars more
payable by Installments $100 payable Ten months
from the date last aforesaid and & $100 payable Twenty
months from the date last aforesaid & $100
payable Thirty months from the said 25th day
May AD 1830 and it was further suggested
that by the time these installments became
due said Gilbert could earn the money aforesaid
$400 by his laboring & it was preposed that if said
Gilbert should die at any time before the end of
the Thirty months aforesaid that the said Jonathan
& Gilbert should only pay said a porportionable
part of said sum of Three hundred Dollas, and it
was suggested that as Gilbert desired to be a free man
said Coleman should convey said Gilbert to said Jonathan
as a slave by bill of Sale That said Jonathan
should give said Gilbert a bond of Emancipation
and that said complaints should give them same
obligation to said Coleman for the Three hundred Dollars
payable by Installments as aforesaid your complainants
say that said Jonathan acting under the belief that
the representation made by said Coleman that said
Gilbert was his slave was true & said Gilbert acting under
of false imprisonment they to the preparation
& acted upon the suggestions of said Coleman and said
Jonathan accordingly advanced $100 to him said Coleman
then gave said Jonathan a bill of sale for said
Gilbert , said Jonathan there signed & sealed in
presence of witnesses a bond of Emancipation for
said Gilbert which bond of Emancipation it was
suggested said Jonathan should keep the said
sum of $400 should be paid by said Gilbert so
that said Jonathan should be secured for the
many & which he should security for an
amount of said Gilbert which Bill of Sale and
bond of Emancipation are the first marked
A No 1 & the Second B No 2. and the
complainants make them a part of this bill.
said complainants say they their expected & believed
to said Coleman there same obligation of for three
hundred Dollars payable by Instalments according
to the proposition of said Coleman as before stated
and said complainants say that said sum of
$100 was advanced & said bond for $300 was
given for the purpose of affecting the the Emancipation
of said Gilbert from Slavery & no other consideration
and said complainants alledge that when said
Bond was expected & long before that said Gilbert
had became entitled to his freedom & said Coleman well knew it but then & for a Long time

held said Gilbert in slavery & false imprisonment
said complainants further say that said Bond
for $300 as they are informed & believe is now
held by Edward Tracy & Charles Wahrendorff
of St Louis & that they are interested in it.

Said complainants further alledge that said
Coleman Duncan is not a resident of the state of
Missouri & that he is insolent & that if said bond should be paid
your complainants could have no adequate remedy
against him, your complainants pray that said
& may alsobe made defendants
your complainants for the reasonsaforesaid pray
that a subpoena may issued requiring the Defendants
to appear and answer this bill that they
may be compelled to answer an all
the allegations of this bill so far as such answers
will not them, that they may be
compelled to produce in court the said bond for
$300 - that they may be
at Law on said bond untill they shall have answered this bill to and finally that by the
of this Court said bond may be delivered &
cancelled and finally the complainants pray for
such further & other relief as shall to
this Honorable court & they will pray

G A Bird Solicitor for
complainants

No304
St Louis Circuit Court
March Term 1831

vs
Coleman Duncan
Edward Tracy
& Charles Wahrendorff

Original bill in ChangeryThe clerk of St Louis
Circuit will please
Issue a subpoena
G A Bird Solicitor for
complts Filed12th March 1831
Archibald Gamble Clerk

Copy of B

Know all men by these presents that I Jonathan
a free black man of St Louis Missouri for &
in consideration of good causes me
hereunto moving do hereby emancipate
discharge & free from slavery
a certain Negro Man aged about Twenty five years named Gilbert being the same
person this day conveyed to mt by Coleman
Duncan by bill of Sale_ hereby relinquishing
all my to him & discharging him
from all claim or

of I have hereto set my hand & seal this Twenty fifth day ofMay
in the year of our Lord one thousand
eight hundred & thirty

Jonathan Duncan x his mark Signed Sealed & Delivered after having been read to Jonathan in our presence J Spalding James Keyte

State of Missouri . Judicial Circuit
St Louis CountyMarch Term AD 1831
To the Honorable William C. Carr Judge
of said Court in Cancery Sitting

Your orators Jonathan & Gilbert men of color
represent unto your honor that heretofore to wit
on the25th day of may in the year of
our Lord eightheen hundred & thirty at said county
Coleman Duncan whom your complainants pray
may be made Defendant to this bill had seized
& taken into his possession & then held in his custody
the said Gilbert who is the brother of said Jonathan
and the said then there said
Coelman then & there claimed said
Gilbert as his slave for life offered to sell him
as such to said Jonathan who is a free man of
color and threatened that if said Jonathan not purchase said Gilbert to take said Gilbert to some other place & sell him as a slave
That said Coleman preposed that said Jonathan
should give him one hundred Dollars
and said Jonathan & said Gilbert should give
him this same obligation for three hundred Dollars
made payable payable by $100 payable
ten months from the date last aforesaid $100
payable twenty months from the date last
aforesaid & $100 payable in thirty months
from thedate last aforesaid said 25th day of
of may AD 1830 - and it was further suggested
that by the time these installments became due
said Gilbert could earn the money aforesaid $400
by his labor and it was proposed that if said Gilbert should die at any time before the end
of the Thrity months aforesaid that the said Jonathan & Gilbert should only pay said Cole
man a proportionable part of said sum of
Three hundred Dollars - and it was Suggested that as Said Gilbert desired to
become a free man Said Coleman should
convey said Gilbert to said Jonathan as a slave
by bill of sale that said Jonathan should
give said Gilbert a Deed of Emancipation and
that said complainants should give these same
obligations to said Coleman for the Three hundred
Dollars payble by intallments as aforesaid
Your complainants say that the said Jonathan acting
under the belief that the representation made by
said Coleman that said Gilbert was his slave
was true and the said Gilbert acting under
duress of false imprisonment they agreed to the
propositions & acted upon the suggestions of said
Coleman and said Jonathan accordingly-
advanced one hundred Dollars to him said
Coleman said Jonathan then gave said
Jonathan a bill of sale for said Gilbert
Said Jonathan then Signed & Sealed in presence
of witnesses a Deed of emancipation for said Gilbert which of emancipation it was
suggested said Jonathan should untill the said sum of $400 should be paid by
said Gilbert so that said Jonathan should be
secured for the money advanced & which he
should security for on account of said
gilbert which Bill of Sale & Deed of emancipation the first marked A No 1 and the
second B No 2 and the complainants make them a part of this Bill. Said Complainants
say they there executed & delivered to said
Coleman obligation for three hundred Dollars payable by instalments according to the
proposition of said Coleman as before stated and said Complainants say that sum of $100 was advanced and said bond for $300

was given for the purpose of effecting the
emancipation of said Gilbert from slavery &
no other consideration and said complain

-ants alledge that when said bond was executed
and long before that said Gilbert had become entitled to his freedom but there & for a long
time previous held said Gilbert in Slavery & false
imprisonment. Siad complainants further
say that said Bond for $300 is now held by
Edward Lay & Charles Wahrendorff of St
Louis & that they are interested in it.
Said Complainants further alledge that said
Coleman Duncan is not a resident of the
State of Missouri & that he is & that
if said Bond should be paid your complain-
ants would have no adequate remedy against
him. Your complainants pray that said
Lay & may also be made Defendants
Your complainants for the reasons aforesaid
pray- that a subpoena may issue requiring
the Defendants to appear & answer this bill
that they may be compelled to answer on
oath all the allegations of this bill so far as
such answer will not criminate them that they may
be compelled to produce in
court said bond for $300 that they may
be from proceeding at Law on said Bond untill they shall have answered
this bill to_ and finally that by the the Decree
of this Court said Bond may be delivered
up & cancelled and finally the complaints pray for such futher & other relief as shall
seemmeet to this honorable court and they
will pray &c

G A Bird Solicitor

Copy of A No 1

Know all by those presents that I Coleman
Duncan of Hopkins County in Kentucky for and
in consideration of four hundred Dollars to
me in hand paid by Jonathan Duncan a
free black man of St Louis in Missouri have
granted bargained sold and conveyed and by
these presents do grant bargain sell and convey unto
said Jonathan Duncan a certain Negro man
slave aged about Twenty five years named
Gilbert being the same slave conveyed to me
James by Bill of Sale dated second day of
April in the year of our our Lord one thousand
eight hundred & Twenty six-to have & to hold
said Negro man slave named Gilbert unto him
said Jonathan his administrators & assigns
and I do hereby that I &
my representations shall forever warrant & defend
said slave & the title thereto unto the said
Jonathan his executors administrators and
assigns against all presons claiming him as a slave

In testimony whereof I have hereunto set
my hand & seal this Twently fifth day of
May in the year of our Lord one thousand
eight hundred & thirty Coleman Duncan Signed Sealed &Delivered in presence of J Spalding

Sitting as Court
of Chancery) at the next term thereof to be held at the City
of St Louis within and for the County of Saint Louis on
the Fourth Monday of March instant then and there to answer
to a bill of complaint exhibited against them by Jonathan
and Gilbert free men of Color and have you then there this writ.

Witness Archibald Gamble Clerk of our
said Circuit Court at office this twelfth
day of March Eighteen hundred and thirty
one Archibald Gamble Clerk

I acknowledge service for

E Tracy

No304
St Louis Circuit Court
March Term 1831

Executed this writ on Edward Tracy by off
-ering to him the copy of bill furnished
by the Clerk, and reading this writ to
him, & on Chas. Wahrindorff by his (said
Tracy's) acknowledging service, for
him, Coleman Duncan not found
in my county

March 1831
John K. Walker
Sheriff

2 Service$22 .50$ 2.50

St Louis Circuit Court
March Term 1831

of to the of

The said defendants Charles Wahrendorff &
Edward Tracy , & reserving to themselves all and all
manner of benefit of exception to said Bill of Complaint for
the manifold errors, & insufficiences therein
contained for answer thereunto or to so much thereof or
they are advised, is material, answer and they say that
in the spring of the year 1830 Jonathan one of the
complainants, came to the defendant Wahrendorff & stated that his (Jonathan's brother Gilbert , the slave
of Coleman Duncan was then is your & could get
free by paying & saving the sum of four hun-
dred dollars, and asked said Wahrendorff's advice
respecting the manner in which it should be done:
he then stated further that said coleman wished
him ( Jonathan ) to become bound for the money
in which case he would give sufficient length of credit
to enable Gilbert to earn the money
& that the sum of four houndred dollars was re-
quired to be paid down. The defendant Wahren-
dorff advised Jonathan not to become bound
unless Coleman Duncan would agree to make
a notable deduction from the amount of the
purchase money, in case Gilbert should die
or become permanently unable to work within
the period allowed by the contract. Jonathan to the suggestion of said Wahrendorff &
& asked him to accompany him -said Jonathan to
the office of J. Spalding in order to conclude the
arrangement with Coleman Duncan . The defen
dants further say that immediately thereafter
said Wahrendorff did accompany Jonathan to
the office of said Spalding where the arrange-
ment was was concluded: and an instrument made
seal of Jonathan& Gilbert to Coleman Duncan
for three hundred dollars was executed (a copy of
which marked A. No. 1. is hereto annexed as part of
this and immediately thereafter said Cole-
man & Jonathan accompanied the defendant Wah-
rendorff to his stone, where he said defendant
advanced at Jonathan's request, one hundred
dollor to said Coleman , it being the sum
that was by the agreement to be paid down
in cash and that in all this transaction the
defendant Wahrendorff was in no no win interest-
ed, but acted merely as the friend of Jonathan
& at his request, & from the same motives & no
other,then lent him said hundred dollars.
The defendants further say that the said Jonathan
informed said Wahrendorff during the aforesaid trans-
actions that said Gilbert & Coleman had got into a
dispute that Coleman wished to take him out of
the country & that Gilbert intended to sue for free-
dom, but that as he Jonathan knew that Gil-
bert belonged to Coleman , it would be best to
settle the matter amicably, & that it would be best to make the said arrangement; and that it
was right that Gilbert should pay for himself
said defendents further say that afterwards wait

on the twenty eighth of June in the same year
James Duncan the brother of Coleman , called on
said Wahrendorff & borrowed on the the faith of said
instrument a sum of money & pledged the said
instrument or bond of Jonathan & Gilbert for the
repayment of the same & that there is now due
from said Duncan to these defendants for which said bond is
pledged, the sum of one hundred dollars: and that said defendants have been notified that the balance
due on said Bond, has been transferred to James
S. Thomas and these defendants charge that there
was no nor fraud in said transactions, alledging that they were not of any that the
purchase of Gilbert's freedom was in their belief
the result of a a dispute between the master and
his have, which was compromised fairly at what
they understand to be an underprice for the slave
the saidGilbert & Jonathan his brother choosing rath-
er to pay the sum of four hundred dollars, than
to abide the result, & pay the expenses, of a tedious
suit: and to that purport, the said Jonathan
expressed himself to the defendant Wahrendorff .
The defendants further say that within a week
after said bond was put into the defendant's
hands to secure said hundred dollars, said Jona-
than was notified of such fact & transfer at
which time be made no objection to paying the
same. The defendants further say that said Tracy during all said transactions was absent from
St. Louis & knows nothing except from hearsay
& so makes the above statements. And they suppose that
the instruments copies of which are made exhibits in the Bill
of complaint were executed & that said copies are correct
but do not know & therefore do not admit it Theybelieve said Coleman is not a resident of Missouri , but
do not know whether he is insolvent or not but be-
lieve & charge the the fact so to be that he is not in-
solvent.Nor do these defendants know whether said
Gilbert could have obtained his freedom from said Cole-
man by suit, but believe & charge that both Jona-
than & Gilbert were doubtful of the event, & chose
rather than try the experiment of a suit & pay the
expense & submit to the delay, to compromise the claim
to freedom in the manner aforesaid: and then de--
fendants deny any participation in the transactions
detailed in said Bill of Complaint other than as
above stated: without that that there is any other
matter or thing material or necessary for this defendant
to make answer unto and not herein and hereby
will and sufficiently answered unto, confessed or avoided
traversed or denied, is true,, all which matters and things
these defendants Tracy & Wahrendorff are ready to aver
and prove as this honorable Court shall direct and
award & humbly prays to be hence with their
reasonable costs & changes in their behalf most wrongfully sustained

J Spalding
for Tracy &
Wahrendorff

State of Missouri
County of St Louis ss

Edward Tracy & Charles Wah-
rendorff being severally duly sworn on their oaths
respectively say that the matters & things in above an
swer stated as of their own knowledge are true &
those stated as matters of or belief they be-
live
to be true

Edwd. Tracy
Chas WahrendorffSworn to & Subscribed to the

A.No.1.
(copy)

Ten months after date we promise
to pay to Coleman Duncan or order the sum
of one hundred dollars: & twenty months after
date we promise to pay said Coleman the fur-
ther sum of one hundred dollars & thirty months
after date we promise to pay said Coleman the
further sum of one hundred dollars. The two
last mentioned serves to bear interest from the
date hereofat the rate of six per cent per an-
num for value received. This obligation however
subject to the following condition. That
whereas
this instrument is for the benefit of the under-
signed Gilbert whose labor it is hoped will meet
there payments now if said Gilbert shall die or become from sickness or accident permanently
unable to work, at any time within thirty months
from this date then only the notable proportion
of the above sum shall be paid, Witness our
hands and seals this25th. May 1830

Signed sealed & delivered in
presence of (after its being read
to Jonathan (after its being read
Gilbert J Spalding

No

Answer of Tracy & Wahrendorff

J Spalding
for T & W
filedApril 6th 1831 A Gamble Clk

County of St Louis ss
The State of Missouri To the Sheriff of S Louis County Greeting

We command you as we heretofore commanded
you to summon Coleman Duncan that he be and
appear before the Judge of our Circuit Court sitting
as a Court of Chancery at the next term thereof to
be held at the City of S Louis within and for the
County of S Louis on the fourth monday of July
next then and there to answer the bill of Complaint
of Jonathan and Gilbert , free men of color And
have you then there this writ

Witness Archibald Gamble Clerk
of our said court at office
this 21st day of April 1831 Archibald Gamble Clk

Coleman Duncan not found in my
County

John Shff

July Term 1831

Alias-