State of Missouri , Circuit Court Third Judicial Circuit.To the Honorable Luke E . Lawless Judge of
said Court.

Your Petitioner Ben represents that
he is now held in slavery in St. Louis by
Thomas I White for the who
claims your petitioner us his slave. Your
petitioner States that in the fall & winter of
eighteen hundred & thirty threesaid said
L there claiming your -
Petitioner as his slave caused your Petitioner
to be hired to Labor at Scuagirts baal
Banks in the State of Illinois where he was
kept at Labor with the knowledge and consent
of said far the space of sworn
by Reason where of your petitioner
says he is entitled to his freedom your-.
Petitioner therefore prays that he may be
permitted to sue as a poor person to establish
his freedom that counsel may be assigned
to him & that such may be made
for his personal Security as the Law warrants
& he will pray

Ben his x mark a man of color>

Ben the above named petitioner on his oath
says that the facts in the above petition state are true.

Ben his x mark a man of color

sworn & subscribed to before me
this day of 1836
after hearing the Petition &

P. Walsh Justice of the peace

State of Missouri
St. Louis CountySs.

I Luke E Lawless Judge of
the Third Judicial Terminal of the State of
Missouri do hereby order that the within
named petitioner Ben be allowed to sue
as a poor person to establish his freedom
and assign to him as his
counsel to commanded & prosecute his Said

and I do further order that said Ben have
reasonable liberty ato attend his counsel &
the Court as occasion may require; and that
he be not removed out of the Juridiction
of the Court, and that he the not subject
to any security because of his application
for freedom.

L.E . Lawless 3rd 18th Jan. 1836

State of Missouri Circuit Court Third Judicial
Circuit March Term AD 1836

St Louis County Ben a man of color complains
of Thomas I & the claim & of plea of trespass
false imprisonment do far that here to on the first day of December in the
year of eighteen hundred & thirty five
the said defendants with forced arms
on a peace do make upon him said Ben
& him said Ben did then & there imprison
any just or probable cause whatever
& have unlawfully kept & detained him in
prison there from them untill the commencement
of this said and the plaintiff
that at & the commetting of
the said secural grievances he &
still is a free person & the defendant had
& detained & still detains him in slavery
where he says he is greatly & hath
sustained Damage to one hundred Dallors
therefore he said

G.A. Bird

State of missouri
St. Louis CountySs.

I Luke E.Lawless Judge of the third Judicial
Circuit of the State of missouri do herebycertify order that the within named
petitioner Ben be allowed to sue as a poor person to establish his freedom
and assign to him Gustavus A Bird as his Counsel to commence & presecute
his suit. and I do furthr order that said Ben have reasonable liberty to attend
his counsel & the court as occasion may require and that he be not removed
out of the Jurisdiction of the court and that he be not subject to any
severiy because of his application for freedom
18th Jan 1836

L. Judge 3rd JudCir

County of Saint Louis ss.The State of Missouri To the sheriff of the county of Saint Louis .
Greeting

We command you to summon Thomas Of White and
Williams L Woods. 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 for
the second monday of march next then and
there to answer unto Ben a man of colour of a plea trespass
false imprisonment to the damage of the said plaintiff
of one Hundred Dollars and have you then there
this writ.

Witness John Ruland Clerk of
our said Circuit Court at
office this nineteenth day of
January AD 1836 Jn.Ruland Clerk

No 50 Saint Louis Circuit Court
March Term 1836

This is an action to establish
freedom.

G.A.Bird. Let a summons issueG.A.Bird. Filed 19th January 1836 Jn.Ruland Clerk

Executed this writ by reading it together with
the decleration and order of the honb. Judge
to White on the 20th day of January
1836 in the county of St. Louis L. Woods
not found in my county

John Brotherton Shff by G Hammond
Dept Shff

service1.0050$1.50

Suit for freedom In
St. Louis Circuit Court
march Term 1836

And the said Thomas
by Hudson his attomy
and defends the force
when and saith that he is
gently of the said supposed
trespass and false imprisonment
above said to his or any
thereof in manner and form
as the said Benjamin above
thereof complained against him
and of this he the said Thomas
himself upon the

Hudson
for

No 50March Term 1835

plea general issue

Filed 16th march 1838 John Ruland Clerk

Depositions of witnesses produced Sworn and
examined on the thirteenth day of October in the year
of our Lord eighteen hundred and thirty eight
at the office of Patrick Walsh in the City of St. Louis
and state of Missouri and by consent of the attornies
James B Bowlin and Alexander Hamilton before
me Patrick Walsh a justice of the peace within and
for the county of St. Louis in the state aforesaid in a certain
cause now depending in the Circuit Court of the Country
of St. Louis aforesaid between Ben a slave plaintiff,
and James woods Defendant on the part of the plaintiff

John Holtz of lawful age being produced
and sworn upon his oath states. That he is
a resident of St.Claire County Illinois that
he has their for 18 or 19 years. That he
is acquainted with the by Ben called
Ben woods the plaintiff in this suit that he
became acquainte with Ben in Illinois >
about five years ago. That said Ben
was then wroking in the cole mines of St. Claire
clair County, where he remained somewhere
about six or eight weeks at labour in the
mines That he was brought three witness by a man by the name of Dickenson
and was at work in connexion with a man
by the name of -. And further
this deponent saith that

and subscribed to before
the day and at the place first aforesaid
justice Samuel Swagart of lawful age being
produceed and sworn upon his oath states
that he is a citizen of Illinois and that about
five years ago he was a citizen of St.Louis County Illinois That he knows
the plaintiff in this suit. That he
because, acquainte with him about
five years ago, in St Claire County
Illinois where he was then working in
the Cole mines, that he boarded at deponents
House, while working in the mine
That said remained then about
six in eight weeks,- That he was
brought there, from St. Louis in Missouri
by a man by the name of grainyer
and he was kept in their
working the mines until he was brought
back to St. Louis about 6 or 8 weeks after
he was brought over- Blueford Robinson
the Cole away and witness belives
he was in the employ of Dickenson which Cole Ben And
further this deponent faith not

sworn and subscribed to before
me On the day and at the place
first aforesaid
Justic his mark

Geroge W. Howard of lawful age being
upon his oath states-
That, he is a Citizen of Illinois St St.Claire
County, that he has been residing their
about eight years- That he was acquainted
with the plaintiff Ben, about five years
ago in St Claire County Illinois when he Ben
worked then- That he there working
in the Cole mixes that he remained there
about 8 or nine weeks, that he was brought Their by a man named
from St. Louis , about the first of november
1833- and remained their at work in the
mines until early in January1834- That
it was the understanding that he worked
there as a servan- That the cole
he was By Bluford Robinson
and another man to St. Louis and be
understood from one or both of the haulers
that were hauling for Dickenson
That witness heard and the persons
hauling speak of Ben as a slave, and
say he was a slave- while he was
there and fruther this Deponent saith not

his x mark sworn and subscribed to before me on
the day and at the place first aforesaid

Eliya Howard of lawful age being
produceed and sworn upon her oath states
that he is a citizen of Illinois and that about
five years ago he was a citizen of St.Claire County That he knows
the plaintiff in this suit. That he
because, acquainte with Ben about
five years ago, in St County
where he was then working in
the Cole mines, that he as deponents
, which working in te mine
That remainded then about
six in eight weeks,- That he was
brought there, from St. Louis in
by a man by the name of
and he was kept in their
working the until he was brought
back to St. Louis 6 or 8 weeks after
he was brought over-
the away and belives
he was in the employ of which And
further this deponent faith not

hisx mark and subscribed to before
me On the day and at the place
first aforsaid Justic

Geroge of age being
upon his states-
That, he is a Citizen of St
County, that he has been residing their
about eight years- That he was acquainted
with the plaintiff Ben, about five years
in St County when he Ben
worked then- That he there working
in the Cole that he remained there
about 8 or nine weeks, that he was brought

Their by a man named
from St. Louis , about the first of november
1833- and remained their at work in the
until in 1834- That
it was the understanding that he worked
there as a servan- That the cole
he was By
and another man to St. Louis and be
understood from one or both of the
that were for
That heard and the persons
speak of as a slave, and
say he was a slave- while he was
there fruther this Deponent saith
not

of age
being and upon her
oath states, That she is a citizen
of - that she has then
in St County a Ten years
That she was with
the plaintiff about five years ago
this fall- That was then working
in the cole in St to
That he remainded their about 8 or 9 weeks
all the time, That he boarded
at the House of Deponent who then lived
in House and Deponent cooked
for the Ben among the That
for
the cooking for the hand and for
it- That he had another slave
Ben there a week, and brought
him away and left Ben That the
and another
man the away which
Ben and the other and fruther
they deponent saith not

herx mark and subscribed to before
and on the day and at the place
first aforesaid justice

I, Patrick Walsh a Justice of the peace within and
for the County of St. Louis in the state of Missouri , do
hereby Certify that John
Geroge and the Deponents
were by me severally sworn to testify the whole truth of
their knowledge the mater in aforesaid;
that they wre examined and their examination
reduced to writing and by there respectively subscribed
in my presence on the day between the hours and at
the place in that behalf first aforesaid

Justices fees $ 2.00 said by Plaintiff

opend filedNovember 10th 1838

John Ruland Clerk $ 2

In the Saint Louis Circuit Count,
November Term, 1838Case Stated

The facts in the case and as follows:-

Ben, the plaintiff, was burn a , and at the
time repared to, before the commencement of this
, was, and state us the property of the defendant,
William D. Moods . About five years ago, and before this
was , the said woods the said
negro to his brother-in-law, and , who was then
about to come out for the state of , to
lord, who not to this state, and after being
look the slave over into St.
County, in the state of , for the purpose of working
him as a in the coal , and oil work
him these as and coal-land for seven or eight works,
after which was brought back to this state, and this
said was commenced by he slave for his freedom. The
in this state, and has done
ever came

Some time during the continuance of the
employment of the slave in , the said agent,
by better, imformed the said then , and
in the state of had
so employed the said slave in the state of ,
to & his
at the of in his operations at the
coal at the time of the
was infomed and that would be
danger in taking the and
get his freedom

It is , that if upon the above
facts the Court shall of opinion the the said
is entitled to his freedom, shall according for : be in term of the Defendant. Dec. 26, 1838.

, of , Jas B Bowlin Aty for Pltff

No 50 March Term 1836

, to

Filed December 28th 1838 Jn. Ruland Clerk

Judgment for pltff Book 9 page 367