To the Hon Luke E. Lawless Judge of the St . Louis Circuit
Court July Term 1835

Mary Johnson alias Bensieur represents that
she is about thirty two years old that the was
born in kaskaskia Illinois that she was
formerly owned or obtained by one
Michael and was so
claimed by him at his death, who his
last will and testament manumitted
and set free all his servants so claimed
or owned by him at his death and further
for the cost twelve thousand has been
in the city of St. Louis
until within a short time past and
until one Michael Menard claimed
her as a slave who is as your petitioner
is informed and believes, about to summon her
out of the state and so remove her that
she may lose all evidence of her freesom
she therefore prays that your honour
will make an order that she be perm-
itted to sue as a poor person to
establish her freedom and that she
be not removed out of the jurisdiction
of this court and so in duty bound
she will ever pray

Mary Johnson alias herXmark Bensieur
sworn to and subscribed before me this
16th day of June 1835 - .

order that Mary Johnson alias Bensieur
the petitioner in the within petition be
permitted to sue as a poor person in the
establishment of her freedom and that said
petitioner shall have reasonable liberty to
attend her counsel and the court when occasion
may require and that said petitioner shall
not be removed out of the jurisdiction of
this circuitcourt of the county of St. Louis
nor be subjected to any severity because of
her application for freedom

R Lawless Judge Judc. Ct

State of Missouri
County of Saint Louis
ss Circuit Court Third Judicial
Circuit July Term AD 1835

Mary Johnson , alias Bevinue, a
Woman of colour complains of Michael
Menard of a plea of trespass assault &
battery and false imprisonment for that
heretofore to wit on the fifteenth day of
June in the year of our Lord1835 at said
County the said Michael Menard with
force and arms an assault did make
upon her the said plaintiff and her the
said plaintiff did then and there beat bruise wound and ill treat and did then
and there imprison the said plaintiff and
he has kept and detained the said
plaintiff in prison then from the day
last aforesaid until this time
any legal a probable cause whatever
and other wrongs then and there did
against the peace and laws of said
state and said plaintiff says that at
and before the time of committing said
grievances said plaintiff was and still
is a free person and the defendant
held and detained her and stillholds
and detains said the said plaintiff in
slavery wherefore the said plaintiff says she is aggrieved and has sustained damages
to five hundred dollars, therefore she sues
&c.

Mayfield & Barton atty for plff &c

It is hereby ordered that Mary Johnson alias Bevenue the petitioner in the written
petition be permitted to sue as a poor person for the establishment of her freedom and that
said petitioner shall have reasonable liberty to attend her counsel and the court when
occasion may require and that said petitioner shall not be removed out of the jurisdiction
of the circuit court of the county of St. Louis nor be subject to any severity because
of her application for freedom

LE Lawless Judge 3d Judc Crt
a true copy of the order of the judge

The State of Missouri County of St. Louis ssTo the Sheriff of the County of Samt Louis Greeting

We Command you to summon Michael Menard 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 second monday of July next, then
and there to answer unto Mary Johnson alias Bevinue of a
plea of trespass assault and battery 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
Sixteenth day of June in the year
One thousand eight Hundred and
thirty five
Archibald Gamble Clerk

Executed this writ by reading it & the declaration
& order of court in the County
of St Louis on the 16th day of june 1835

Service ' 1.00
James Brotherton Sheriff

No 66
St Louis Circuit Court
July term 1835

An action of trespass
assault & battery and
false imprisonment
Damages '500

The clerk will
let a summons issue

Filed16 June 1835 Archibald Gamble Clerk

July 1833
St Louis Cercuit

The of his
Comed and difends the and when
and says that the said plaintiff an not to have
or maintain his afousaid action against
him - Because he says chat he said defen-
dant at the time mentioned an said plaintiff
declaration, or befow, had not, non claim to-
have, nor hath ho, nor ooth he new claim to-
but and to have nay
title, or interest, or right to the services, of the
said many on the
of the said many - and the said defendant is
to whenfore he prays of the
said plaintiff a or amintain his
action therof against him.

For a further plea in this behalf the said affidavit
says that the said plaintiff ought not to have or main-
tain his aforesaid action thereof against him, because
he says, he is not guilty - And of this the said defen-
dant puts himself upon the county

filedJuly 15 1835

No.66 July Term 1835

Plea 1. Disclaimed

2. Not guilty -

filed July 15 1835
A Gamble clk