State of Missouri Circuit Court Third Judicial Circuit
July Term A D 1833

Saint Louis County ss Harriet an infant under twenty one years
of age by G A Bird , her next friend complains of
Samuel T M Kinney of a plea of trespass assault
& Battery & false imprisonment for that heretofore
to wit on the first day of May 1831 at St Louis
in County the said Defendant with
force & arms & assault did make upon the said
plaintiff & her the said plaintiff did then &
there beatbruise & illtreat & her the said
plaintiff then & there imprison any
legal reasonable on probable cause & kept
detained her imprison therefore a long
of time from the day last aforesaid
untill this time & other wrongs then & there did
against the peace & dignity of the State aforesaid
and said plaintiff says that before & at the
time of the committing the said severalgrievances
the said plaintiff was & still is as free person and that
the said defendant held & detained & still
holds detains said plaintiff in slavery
By means of which premises the said plaintiff
says she has sustained Damage to three
hundred Dollars & therefore she sues

G A Bird Plffs atty

Served this writ on Samuel S.
M Kinney by offering to read
it & the declaration to him on the
2nd day of July 1833 in the city of
St Louis which he refused to
hear read

Service $ 100 Jno K. Walker
plff

No 54 July Term 1833

Harriet by GA Brid
her next friend
vs
Samuel T M Kinney

Declaration in
trespass assault & battery
& false imprisonment
& for

Damages $ 300

GA Brid atty
for Plfffiled April 9th
1833 A Gamble Clk

The State of Missouri
County of S Louis SctTo the Sheriff of S Louis County
Greeting

We command you to summon Samuel
T M Kinney that he be and appear before
the Judge of our Circuit Court at the term 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
Harriet an infant under twenty one years of
age (by Gustavus A Bird ) of a plea of trespass
assault and battery 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
ninth day of April 1833 Archibald Gamble Clerk

And the said Defendant Samuel by
Gamble his attorney comes and defends the force
and injury when &c and says he is not guilty
of the said wrongs and injuries in the declaration
set forth in manner and form as the said
plaintiff hath above thereof complained
against him and of this he puts himself
upon the County

H K Gamble
Atto for Dft

death of S.T.M Kinney P. Lucinda Carrington enters appearance as defendant sub to court & Judgt
for 1cent damages Book 7 page 482

No 54 July Term 1833

Harriet
vs
Samuel T Mc Kinney

plea not guilty

filed July 30th 1833 A Gamble Clk

The Deft excepts to the depositions of Nancy
Bright and William Scholle filed in this case

1st Because there was no legal notice given of the
time and place of taking said depositions

2d Because the depositions were not taken in pursuance of the notice given

3d That the depositions are not properly certified

HR Gamble
atto for Dft

Harriett
vs
Mc Kinney

Exceptions to Depositions

Filed 6th December 1833 Archibald Gamble Clerk