William Dallam not found in
any County 12th Nov 1831

John K Walker Shff 50 cts

No 7 St Louis Circuit Court
November Term 1831

Sally (by next friend)
vs
William Dallam
Declaration

Filed July 26th 1831 Archibald Gamble Clerk

This is an action of trespass
assault & battery & false
imprisonment Dam $ 500
Issue a Summons

J.Newman

In the St Louis Circuit Court
County of St Louis , Set, November Term 1831

Sally a girl of colour and an infant
under the age of twenty one years, by George
Brown her next friend complains of William
Dallam in custody & of a plea of tresspass
assault & battery & false imprisonment for that
heretofore, to wit, on the first day of July in
the year eighteen hundred & thirty one at the
county aforesaid, the said Defendant with force
and arms made an assault upon the said
plaintiff & then & there beat wounded & ill treated
her & then & there with force & arms falsely and
unlawfully imprisoned the said plaintiff and
Kept her & detained her imprison there without
any lawful authority or cause for a long space
of time, to wit for the space of tendays then
next ensuing - and the said plaintiff further
says that before & at the time of the committing
of the said several grievances she was & still
is a free person & that said Defendant held
and detained
& still holds & detains her in
slavery wherefore the said plaintiff says
she is greatly injured and hathsustained
damage to fivehundred Dollars & therefore
she sues & etc

John Newman

The State of Missouri
County of Saint Louis . ssTo the Sheriff of the county of Saint Louis Greeting

We Command you to summon William Dallam that he be and
appear before the Judge of our Circuit Court 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 November next then and
there to answer unto Sally a girl of color and infant under the age
of twenty one years by George Brown her next friend of a plea of
trespass assault and battry and false imprisonment to the damage
of the said plaintiff of Five Hundred Dollars and have you then
there this writ

Witness Archibald Gamble Clerk of our
said Circuit Court at Office this Twenty Sixth
day of July Eighteen Hundred and thirty one Archibald Gamble Clerk

copy of the order of the Judge on petition of plaintiff

State of Missouri - Third Judicial Circuit to wit; It is hereby ordered
that on the foregoing petition that the subscribers thereto Henry Sally
and Margaret be permitted to sue as poor persons by George Brown
their next friend to establish their right to freedom and John Newman
Esq is assigned as their counsel- It
is also ordered moreover that said
Henry Sally and Margarette shall have reasonable liberty to attend
their counsel and the court when occasion may require & that said
Henry Sally and Margaret shall not be removed out of the Jurisdiction
of the Circuit court of St Louis County nor be subjected
to any severity
because of their application for freedom- given under my hand
this 22 day of July A.D. 1831

Will C Carr