Book 7 -- 403 --
U.S. District Court -- 7 -- 410
183

No 67 Saint louis circuit Count
July term 1835

This is an action of assault and battery for and

Marquis filed 16th june 1835
atty for pltt

To the judge of the third judicial circuit of the State of

Your petitioner Paul augusto allan an infant of Same his respectfully presents that he was born at
De in the then Territory, now State of Illinois any alland an inhabitant De
Roche claimed and held your petitioner
as his slave at the place from the birth
of your petitioner until the death of said alland
between two and three years ago. That since the
decease of said alland your petitioner has been held in slavery, and claimed as a slave, augusto alland of said augusto
alland deceased. That a few months since
Bazil augusto alland hired your petiti
oner as a slave, to mr. of the resident of the city of St Louis and
State of missouri in whose custody and
charge your petitioner now is and who
claims and exercises authority over him
the of such hiring .That your petitioner
prays he may be permitted to die as a free
personand establish his right to freedom

Paul augusto alland by his next friend Benjamin Lawhead

State of Missouri County of St Louis

Before me Daniel Hough
a justice of the peace within and for the County aforesaid personally appeared. Paul , au
gusto alland and made onth that the statements
contained in the within petition are true

paul august Xhis allmed mark swom to and subscribed this 16th june 1835DHough J. P.

His hug that the above
paul allow he permitted to
sue his peedr as a son push
and that outher p> majeis be xis
agyent is his counsel and that and pluff have normoble bless
to attend his counsel on the court
when occation may us and
and put the public shall not
be removed with of the of
the event court of the couross louis
above thlyeet to any sevents because
this affaceth for feeds
16 june 1835 vcatin

state of missouri
county of S louis
louisIn the circuit court
july term 1835

Paul augusto alland an in
fant of color under the age of twenty one years by
Benjamin lawhead his well friend complains
of bazil augusts alland and grend Russers
of a plea of trespass for that the said defend
acts on 4th day of june in the year 1835
with foer and arms all the bounty aforesaid
made an assault upon him the said Paul
and then and there beat, bruised and ill treated
and imprisoned him the said paul and kept and
detained him in prison there without any rea-
sonable or probable cause whatsoever, for a
long space of time, tourt, from that day until
the day of bringing this suit, countrary to the law
of this land and againist the will of the said
Paul , and other wrongs to the said Paul then & then did to the great damage of the said Paul
and the said Paul saith that he is injured & hath sustained damage to the amomt of twenty
dollars and therefore he brings his suit and
the said Paul in fact says that before and
at the time of the commission of the grievances
aforesaid he was, o t is, a free person &
that the said defend held and detained & state
hold and detain him in slavery at the county
aforesaid.

Paul augusto alland Benjamin Lawhead his next friend

copy of the order of the Judge permitting suit to be

It is hereby ordered that the above Paul August Alland be permitted to sue for his freedom as a poor person and that as his counsel and that said have reasonable liberty to attend his counsel and the court when occasion
may require and that the petitioner shall not be removed out of the jurisdiction of the circuit court of the county of St. Louis or be subject
to any severity of because of his application for freedom- 16th june 1835

County of Saint Louis ssThe State of Missouri To the Sheriff of the County of Saint Louis greeting

we command you to summon Bazil Auguste Allard and Arend Rulgers
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 Saint Louis on the Second
monday of July next then and there to answer unto Paul August Alland an infant
of color under the age of twenty one years who sued by Benjamin Lawhead his next
friend of a of to the damage of the said Paul of twenty dollars and have
you then writ

witness Archibald Gamble clerk of our said
circuit court at office this sixteenth day of june
in the year of our lord one thousand eight hundred and thirty five Archibald Gamble Clerk

Executed this writ by Reading it and the held
and petition and also the order made by
the honorable Judge to Arend Rutgers on the 18th
day of June 1835 in the county of St. louis and Bazil
Auguste Allard on the 24th day of June 1835 in St Louis County

James Brotherton Shff M Brotherton D ShffService 200

To the circuit court of the county of St. Louis in
the State of Missouri

The petition of Bazil alland a
citizen of of the State of Illinois
that he is lined in this court by one Paul ,, who claims
to be a citizen of Missouri . your petitioner for
that the matter in dispute ends the
sum of five hundred Dollars, exclusive of costs.
that said cause the united states bount for the Missouri
District, submits to comply with the provisions of the law in such case made

Bazile X his alland St. Louis July 13. 1835

Know all men by these that I
acknowledge myself, to be held bound unto Paul a. alland in the
of one hundred - dollars - this 17th day of july AD. 1835

The condition of this obligation is such
that whereas the above named Paul .a.alland
has is suit against Bazil a.
Alland and Arend Rutgers , in the Circuit court of the county
of St Louis State of Missouri to establish his
freedom, wherein the said Bazil a alland
has presented his petition for the removal of the
cause into the next United States court for
the missouri district

the said Bazil a. alland - shall
on the first day of the next said United States court file copies of the county is said cause and the this

july term 1878.

And the said arend Rutgers one of
the defendant in the above case comes into court
disclaims all and any interest on he
has Paul alland- - on to
any interest or pretension of him the said Arend
Rutgers be the said plaintiff may so guest

Disclaimer by Arend
Rutgers

The court by instructs the Jury
that Plaintiff is not entitled
to receive for any services
to 10th may 1839