To the Circuit Court of Saint Louis County and State of Missouri

The petition of Harriet an infant under twentyoneyears of age
by Julia her mother respectfully that your petitioner
is free but that she is held as a slave in St Louis by within
Samuel TMcKinney or Thomas D James a negro trader.
Your petitioner states that in October 1829 Lucinda Carrington
& her children settled in the state of Illinois with the
intention of making that state their permanant residence
& that said Lucinda & her family have resided there
ever since your petitioner states that said Lucinda
on her arrival in Illinois as aforesaid brought with
her your petitioners & her mother claiming & holding
them as slaves & having owned them as such in the
state of Kentucky - your petitioner states that said Lucinda
kept her mother & her in the state of Illinois in the county
of Pike which she had selected for her residence from the
27 or 28th day of October 1829 untill the 26th day
of December in the same year during all of which
time the said Lucinda required services of your
petitioner & her mother as her slaves & kept your
Petitioners mother at labor as such slave in her family
your petitioner states that after it became a talk that
your petitioner & her mother were free among the neighbors
of Mrs Carrington she said Lucinda Carrington caused
your petitioners mother & your petitioner to be taken to
Missouri & there hired out as her slaves your petitioner
states that after she & her mother had been hired
for about nine months in Missouri they were
again taken back to Illinois where they were again
by said Lucinda Carrington kept & treated as
slaves for about eightweeks when they were sent
to Missouri & sold to Samuel FMcKinney
your petitioner prays that she may be permitted to sue
as a poor person to establish her freedom that
counsel may be assigned to her & that such further orders may be made in her behalf as her case
requires & the lawprovides & she will this pray

Sworn to in opencourt
April 9 1833 Julie her mark A Gamble Clerk

No 17
July Term 1833

Petition of Harriet for
leave to sue for freedom
&c

filed April 9th
1833 A Gamble Clk

PetitionRevisedBook 6 page 459
& order for leave to sue

State of Missouri
Saint Louis Circuit Court July Term
AD 1899

Harriet an infant under twenty one years of age
by GA Bird her next friend complains of
Samuel T M Kinney William Walker &
Thomas D James of a plea of trespassassault
& Battery & false imprisonment for that heretoforeto wit on the first day of May 1831 at St Louis
on said county the said defendants with
force & arms an assault did make upon the
said plaintiff & her the said plaintiff did
then & there beat wound & ill treat & her
the said plaintiff did then imprison there without any reasonable or probable cause whatsoever
& kept & detained her in prison there for a
long space of time to witfrom the day
last aforesaid & other wrongs to the said
plaintiff then & there did against the peace
& dignity of the state and said plaintiff
avers that before & at the time of committing
the said several grievances she was & still
is a free person & the defendants held &
detained & still do hold & detain her in
slaveryby means of which promises said
plaintiff says she is greatly injured & hath
sustained Damage to three hundred Dollars
therefore she sues&c.

G A Bird atty
for plff

I am writing to unto the above suit as
the next friend of said Harriet

G A Bird

Served this writ onS.T.McKinney
on the 11th April 1833 by reading it and the
declaration to him and on William Walker
on the 15th day of same month by reading
thewrit & declaration to him, in the city of
St Louis Thomas D James not found in
my County

service2.50$2.50

John K
Walker sheriff Discontinued book 7th page 48

Harriet an infant by
her next friend
G A Bird
vs
Samuel T Mc Kinney
William Walker &
Thomas D James

This is an action for
freedom in form
a assault & Battery &
false imprisonment
Sum $ 300

The clerk willplease
issueasummons

G A Bird
atty for plfffiled April 10th
1833 A Gamble clk

The State of Missouri
County of Saint Louis SctTo the Sheriff of Saint Louis County
greeting

We command you to summon Samuel
T Mc Kinney Williams Walker and Thomas D James
that they 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 S Louis on the fourth Monday of July next
Then and there to answer into Harriet an infant
under twenty one years who sworn by GA Bird her
next friend of a plea of trespassassaultbattery
and false imprisonment to the damage of
said plaintiff of three hundred dollars
And have you then there this writ.

Witness Archibald gamble clerk
of our said Court at office this
tenth day of April 1833 Archibald gamble clerk