To the Hon: Luke E. Lawless Judge of the St. Louis Circuit Court
Third Judicial districtJuly Term 1835

Aguis alias , a woman of colour
represents to your honour that she is about
twenty two or three years old that she was
born at Kaskaskia illinois: that her mother
was as she is informed an slave
or servant at her birth; but that slave Agnn
alias never was as she is informed
and believes either for a tenure
of laws or registered in persuance of
the laws of that country that about four
years service he left Illinois &
to the City of St. Louis to live, where she has
resided for the last four years
untill within a few days ago
past, when our Pierre claimed
her as his slave for life; ()

who has taken her and deprived
her of her liberty & freedom; and is as
this affiant is informedandbelieves
about
to new for out of this state and otherwise
remove and dispose of her as slave in
suchamanner that she will lose all
evidence of her freedom and means
of establishing her freedom: she thus
affiant therefore prays that your honour
will order that she may be permitted to
prosecute her suit for freedom as a
poor person; and that she be not moved
out of the Jurisdiction of your honourable
court he in persuance of the Statute
in such cases made and
so in duty found will was pray

Agnis alias Agathi her
mark

State of Missouri
County of St. Louis
ss

Peronally appears before me a Justice of the
peace within and for the County aforesaid, agnes alias agnetha he
and makes each that the fact set forch in the foregoing
petition are true.

Sworn to & subscribed before me
this 30th day of June 1835

Wilson Primm J. P.
agnes alias Agath her mark

It is hereby ordered that the above petitioner by permited
to sueas a poor person to establish her freedom and that
Mayfield and Bowlin be appointed as her counsel
and that said petition shall have reasonable liberty
to attend hercounsel and the court when occasion
may require and that she shall not be taken
or removed out of the jurisdictionof the circut
court of the county of St. Louis or be subjecttoany
severity because of her application for freedom
vacationthis30th day of June 1835

L E Lawless Judge 3 Circuit

State of Missouri
County of St. Louis
In the Circuit Court
This judicial Circuit
November Term 1835

Agnis alias Agathe a woman of colour
complains of Pierre Menard of a plea of
trespass assault, & battery and false imprison-
ment, for that heretofore to wit on this the
seventeenth day of June in the year of
our Lord one thousand eight hundred and
thirty five at the County of Saint Louis
aforesaid the said Pierre 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 and ill treat and did then
and there imprison her the said plaintiff
in prison there untill this time without
any legal or probable cause whatever and
other wrongs to her the said plaintiff then and
there did against the peace and laws
of the state aforesaid, and said plaintiff
says, before and at the time of committing
the grievance aforesaid she the said plaintiff
was and still is a free person and that the
defendant held and detained her the said plaintiff and still
hold and detain her the said plaintiff in slavery, wherefore
the said plaintiff says she has sustained damage
to five hundred dollars, wherefore she sues &C

Mayfield & Bowlin
Attys for plaintiff

No 3 Saint Louis Circuit Court
November Term 1835

Aquisalias Agathe
vs
Pierre Menard

This is an action of
trespass asault & battery
& false imprisonment
for freedom

damages $ 500.

The clerk will please
issue a summon

Mayfield & Bowlin
Attys for plfffiled 30th June 1835 Archibald Gamble Clerk

It is hereby

The State of Missouri
County of Saint Louis To the Sheriff of the county of Saint Louis - Greetings

We command you to Summon Pierre 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 mondayofNovember next then and there to answer
unto Agnis alias Agathe a woman of colour of a plea of trespass
assault & Battery and false imprisonment to the Damage of the said
planitiff of five Hundred dollars and have you then there this
writ

Witness Archibald Gamble Clerk of our
said circuit court at offered this thirtieth day
of June in the year of our Lord one thousand
eight Hundred and Thirty five Archibald Gamble Clerk

copy of the order of the judge

It is hereby ordered that the above peitioner be permitted to sue as
a poor person to establish her freedom and that Mayfield and
be asigned as her councel and that said peititioner shall have
reasonable liberty to attend her counsel and the court when occasion
may require and that she shall not be taken or removed out of the
Jurisdiction of the circuit court of the county of St Loui nor subject to any
severity because of her application for freedom — in vacation this 30th day of June 1835

L E Lawless Judge 3rd Jude circuit

Executed this writ by reading it and the
declaration and petition and also the order made
by the honorable judge to Pierre Menard on the
1st day of July 1835 in the county of St Louis

service $ 1.00 James Brotherton Sheriff
By M Brotherton D Sheriff

Petition to remove suit presented 7-460 - order to stay suit in this court & to remove suit to district court of U S - 7 489
fee bill 210

No 3 Saint Louis Circuit Court
November Term 1835

Agnis alias Agathe
vs Pierre
Menard

This is an action of trespassassault & Battery & false imprisonment for Freedom

Damges $500

The Clerk will please issue a summons

Mayfield & Bowlin
attys for plff

To the Circuit Court of the County of St Louis in
the State of Missouri :

The petition of Pierre Menard a citizen of
the State of Illinois respectfully showeth that
he is sued in this Court by one Agnes or Agathe
some times called, who claims to the a citizen of
the State of Missouri - your petitioner further
showeth that the matter in dispute exceeds
the sum of five hundred dollars exclusive of costs wherefore he prays that said cause be removed
into the next United States Court for
the Missouri District, and he herebysubmits to
comply with the jurisdiction of the law in such
case made and provided.

St Louis
1. July 1835. Pierre Menard

- 7 - page 400

2880

Agnes
vs
Menard

100.80

6.24

.27

107.31

filed Nov 14th 1835A G Clk

Know all men by these presents that I Be
verly Allen am held
agnesaliasagathe in the sum of five
hundred dollars, for the payment thereof
I bind myself my heirs and as witness
now read this their 14. Nov 1835.

The condition of this is not
that whereas one Pierre Menard has
petitioned the Circuit court of the county of
St Louis , Missouri for the removal of a cause
in same court against him the said Agnis alis
Agathe into the next District Court of
the United States for the Missouri District
now if the said Pierre Menard shall on the
firstday of the session of the next district
courtaforesaidenterin said court should
said cause be removed or petitions for
copies of the proceedings the in said cause against
him and also there appear, then there this
to be void else in full force

Beverly Allen