St. Louis Circuit Court July Term 1831 Monday 15th August 1831

Gustavus A Bird presents to the Court the petition of Anna a
woman of color praying that she may be permitted to institute suit
against Thomas Higginbotham to establish his right to freedom and
that she may be permitted to sue as a poor person thereupon the court
permits the said Anna to sue as aforesaid and directs that an
action of assault and Battery and false imprisonment be commenced
against the said Thomas Higginbotham in the name of the said Anna
and assign Gustavus A Bird Esquire as her counsel and it is ordered that
the said defendant permit the said Anna to have a reasonable liberty
of attending her counsel and the court when occasion may require it
and that the said Anna the plaintiff shall not be taken or Removed
out of the Jurisdiction of this court and that he 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

Petition of Anna a
person of Color that
she may be permitted
to sue as a poor
person to establishher
freedom.

Filed August
15th 1831 A Gamble Clerk

In Circuit Court
third Circuit &

Your Petitioner Anna represent that she is justly
entitled to her freedom but is held in Slavery and is claimed
by Thomas Higginbottom as his slave but your petitioner
is now in the posession & under the power of Pleasant
MBass of St. Louis - your petitioner says that in the summer
of 1830 she was taken into the State of Illinois by one
John Parkinson the son in law of said Higginbottomwhowent
into Illinois with the intention of making that his
residence your petitioner says she was taken into Illinois
as aforesaid the knowledge & approbation of said
Higginbottom & for the purpose of forming a part of
said Parkinson family your petitioner says that she
continued to remain in the family of said Parkinson as a servant in the state of Illinois until within
about 8weekspastwhen she was taken to St. Louis
said Parkinson still lives in Illinois as a resident of
said State your petitioner believes that she was
given by said Higginbottom to his daughterMrs.
Parkinsonthe wife of said Parkinson who took
your petitioner as a portion of whather father
intended to give her. Your petitioner is informed
& believes that she is now offered for sale and
that it is the intention of said Higginbottom
to sell your petitioner to some one who will take her into New Orleans or some
distant place so as to prevent her from suing for
freedom & proving her right thereto and your
petitioner believes she will be sold & removed
from the jurisdiction of the court unless said
Higginbottom on some one for him shall be
required to give security that she shall not be
removed out of the Jurisdiction of this court
your petitioner prays that she may be permitted
to sue for her freedom as a poorperson that

counsel may be assigned to her that a writ of
HabeasCorpus may issue requiring said to
bring your Petitioner before said Court that said
Court may cause to be done what of right ought
to be done & your petitioner prays that such
order may be made in the promises as the
same warrants & her personal safety require &
your petitioner willever pray

Anna her
mark

State of Missouri
St. Louis County

Anna the above named petitioner
being sworn says that most of the
facts stated in the above petition she
knows to be true & all of them she
believes to be true

Sworn & subscribed to before
me this 12th day of August
A D 1831 Anna her
mark Patrick Walsh
Justice of the Peace
St. Louis County

State of Missouri
St. Louis County
Circuit Court third Judicial
Circuit July Term 1831August
13th 1831 the day of said

On of A Bird it is ordered that Anna the
aforesaid petitioner be permitted to sue as a poor
person to Establish to establih her freedom and that
Gustavus A Bird be a assigned as counsel to
commence & prosecute said suit

State of Missouri Circuit Court third JudicialCircuit
November Term AD 1831

Saint Louis County Anna a woman of color
complans of Thomas Higginbotham
of a plea of trespassassault & Battery
& false Imprisonment for that
on the first day of August AD 1831 at St. Louis in
said County the said Defendant with force & arms
made an assault upon the said Defendant &
then & there beatbruisedwoundedilltreated
& falsely & unlawfullyimprisoned her & held
& detained her in prison there from the day
last aforesaid to this time & other wrongs to the
said plaintiff then & there did against the
reason & dignity of the State of Missouri
and the plaintiff avers that before & at the time
of the committing the (said) grievances she was
& still is a free person & that said Defendant
held & detained & still holds & detains her
in slavery By means of which premises the
plaintiff says she is greatly injured & has sustained
damages to Two hundred Dollars therefore
shesaid etc

A Bird for plff

County of Saint Louis
The State of Missouri To the Sheriff of Saint Louis County Greeting

We command you to summon Thomas Higginbotham that he be and
appear before the judge of our Circuit Court at the next November 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 Anna
a woman of color of a plea of Trespass, Assault and Battery & False Imprisonment
by means of which premises the plaintiff says she is greatly injured and
has sustained damages to Two Hundred dollars and have
you then there this writ

Witness Archibald Gamble Clerk of our said Circuit
Court at office this 16th day of August 1831 Archibald Gamble Clerk

I enter my appearance for
& the Clerk
therefore enter Defendants
appearance

Nov 29th 1831

No 12 St Louis Circuit Court
November Term 1831

Anna a woman of color
vs
Thomas Higginbotham

This is an action of trespass
& false imprisonment
& for
Damages $ 200

for plffFiled 16th August 1831 Archibald gamble Clerk

And he the said Thomas Higginbottom
comes and defends the force and
when & and says that he is not guilty
of the said supposedtrespassabovelaid
to his charge or my part thereof
inname and form as the said Anna
hathabove thereof complained against him
and of this he the said Thomas Higginbottom
puts himself upon the county

for Filed nov 29th 1831A.G.

No 12
November Term 1831

Thomas Higginbottom

Anna a woman of
color

filed nov 29th 1831A gamble clk