To the Honourable Luke E & Lawless page of
the circuit court for the county of St.Louis in the State
of missouri

The petition if a coloured
respectfully show. He is about to institute a for person
I in conformity with the Law relative then to
would show that he was originally the slave of the judge
William James & Missouri that upon the marriage
of his daughter Emily with one James Black she was given into the change of & by him summoned
in the state of Illinois - that she was so removed
when about six to seven years of - that upon
the death of Black she was hired to one William
of also in the state of Illinois the
afterwards after the short stay of one year with her
former master said at
of was taken by a Maria filia also a daughter
of said James to in the state of Illinois
where she from the fall of 1836 to the spring
of 1837, formerly in the usual of
a household amount that she wa there brought
by a me George Wolf to the city of St. Louis
put at different place, but since last January has
been in the home a employ of St.
Louis County who now holds her in slavery & claim her services - that the said James Black claim her his slave & property and resides in as mentioned

Your petitioner would state that she is
a poor person unable to proscute her
permitted to do as a poor person - your for to in
that - form -

X his

county of St. Louis
state of missouri

the above named
petitioner makes affidavite on oath States that
the facts set forth in the above petition are tried

X
mark sworn & subscribed to
this 13th day of
June 1838
of this from

This hereby named that the within
named petitioner be allowed to sue as a poor person to
her right is
as her - - It is also or that she have
reasonable liberty to attend her counsel Court as occassion
may requirethat she be art out of the Jurisdiction
of the court & that she he to any severity
on account of her application for freedom
my land this 13th June 1838.

To Ruland , Clerk of Circuit Court for County
of St. Louis in state of Missouri

The petition of a respectfully
show that the is about to institute
a suit for establishing of her claim to that she being within age of
twenty one years that is today about the age of
seventeen year is that some person
duly qualified should prosecute the suit
for her - the there fore proposes
I & prays that he may be permitted
to act as hernext in the

X his

I Harris I as to become the
next fiend of the above &
in that chance in the matter

L

Circuit Court July term.A.D
1838 County of St. Louis
State of Misouri

Rebecca a colored girl
an infant age of twenty one years by his next friend
Harris L complains of James
Black I Lewis of a plea of trespass
Imprisonment. that therefore to writ or the first
day of Marchone thousand eight hundred thirty
eight at the county aforesaid the said Defendant
with force & arms an assault made in the said plaintiff
her the said
plaintiff in imprisoned
said plff hath kept & her in
prison from the last aforesaid day
to of the in made
& provided & against the peace & dignity of the
the plaintiff that before the time
of the committing of the said and grievances
she was and still is a free person that the Defendants
plea her the plff in the plff days that she is greatly
injured sustained damage to to
the amount of five hundred dollars
she sues -

I plff.

No
Circuit Court July
term. A.D.1828

Suit for under
plff
a poor person. Clerk
will plase -

for -

County of St. Louis , ss. The State Of Missouri , To the Sheriff of the County of St. Louis ---Greeting:

We command you to Summon, James Black & Louis Mattack
if they be in your county to appear
before the Judge of our Circuit Court , on the first day of the next term thereof, to be held
at the City of St. Louis , within and for the County of St. Louis , on the second Monday
of July next, then and there to answer unto Rebecca , a Coloured
Girl, of a plea of trespass for false imprisonment
to the damage of said plaintiff of five hundred dollars
dollars:And have you then there this writ.

Witness, John Ruland , Clerk of our said
Court, with the seal thereof hereto affixed, at office, in the
City of St. Louis , this thirteenth day of
June in the year of our Lord eighteen
hundred and thirty-eight
Jn. Ruland Clerk. by
Depty Geo.

No 237
St. Loui Circuit Court
July Term 1838

Suit for freedom - sUm - $ 500
Sproat atty.

Black acknoweldged
12th June

Filed 13th June 1838 Jn. Ruland Clerk

Executed this writ by offering to read it and the
declaration to James Black, on the 12th day of June,
1838, in the County of St. Louis , all of which he refused
to hear read and acknowledged the service thereof
Louis Mattock not found in my County

James Brotherton Sheriff By joseph W

Service$1.0050$ 1.50

In the St. Louis Circuit Court
July Term 1838.

In trespass
Plea.
And now the said Black and Mattock,
by their attorney sullwan, comes and defend
the force and injury when and say that
they are not guilty of the said supposed trespasses
above laid to their Charge, or any parts
thereof, in manner and form as the said Dff.
hath above whereof against them
And of this they, the said Black and Mattock,
put themselves upon the country -

Sullwan atty:for Dffs -

No 237In the Saint Louis Court
July Term 1838.

In Trespas
plea

Sullivan
atty Filed 12th July 1838 John Ruland Clerk

Book 10 page 68Bk 12 p 26 - Bk 12 p 215
Bk 13 p 51 - suit Bk 13 p 268

In St. Louis Circuit Court Nov.Term.1838

Interrogatoris to be proposed
to William James
of U. - No.
by consent of parties

In St. Louis Circuit Court 1838

underwith and the arthur of william James to John
of the County
the in the of on the
19th day of November A.D. 1838 when and where the said
James , being duly continued and sworn, on his
aforesaid and and and which
said answers see schedule (A)

questions agreed upon by the counsel of plaintiff and defendants in the above case, the night and form of notice being to william james of state of Missouri and sworn to in same names as prescribed by in cases of depositions

question proposed by counsel for plaintiff

1.Did you or did you note make and execute
a certain Deed of trust to Thomas M.
hearing the sixth day of october
eighteen thirth eight, wherein a certain negroe
girl was as conveyed to said for the
and of Caroline Black daughter of
James Black?

2.Did you or did you not hold said slaves
so conveyed as you properly after said conveyance
once in ? and if so in what manner
and how long?

3.Did you ever give, or did you not your
consent to the removal of said Rebecca
to the state of Illinois of so when, and under
what circumstances and was such consent
given before or after making said Deed of
trust?

4.Did you ever make any other deed of
trust of said above named negroes and
especially ofsaid Rebecca to said Thomas
or to any other person, save the
one above and referred to ?

5.are you aware and do you know that
Rebecca the slave in question resided
at any time in Illinois If so state
where, with whom and how long

6.Have you ever heard any assumptions of
Blacks one of the Defendants as
to the residence of himself and family in
the state of Illinois with said Rebecca
If to state

for
for

(Section A)

Question 1st did you or did you not make and execute
a certain Deed of trust to Thomas M.Horine bearing
date the seventh day of October, Eighteen Thirty eight
where in a certain negros girl was so conveyed to said
Horine for the use and behalf of Caroline Black,
Daughter of James Black.

answer I never made to Thomas M . Horine any deed
of trust of the date mentioned, but on the 18th of October
1832, & made a deed to said Horine for three young negroes
in truse for the entire use and benefit of my daughter
Emily Black, and her three children, William , Maria
and Caroline , (the said Emily Black died at in
the sate of Illinois three years ago last summer or the
begining of the fall) That is to say for the use and benefit of my Daughter , until her three children shall
at lawful age, after which time the right of my said
daughter Emily should cease, and the right use and benefit
of the said three negroes should be tested in her three
childrens, in the following manner, to writ, william. Black
should have delivered to him a negro by named Jeffrey
then about seven years of age, when the said william
should arrive at twenty one years of age, Maria M.Black
sholuld have delivered to her, a negro girl named Mary , or
Polly , then about five years of age and her increase when
she should arrive at the age of eighteen years
and Carroline Black was to have delivered to her a
negro girl, named , than about ten or eleven years
of age, and her increase when the said Caroline should
arrive at the age of eighteen years; the said negro Rebecca
had, when I made the said and, trust a large on
head, occasionaly, a burn The said Caroline
Black, to the said negro Rebacca, was
given in said deed of trust, died at my house in the
County of St. Genivence, in the State of Missouri , something
more than three years age, at the age of about three
or four years.-

Question 2nd Did you or did you not hold said slaves so
conveyed as your property aftr said conveyance in trust?
and if, so in what manner and how long ?

Answer I never held said slave Rebecca as my property,
after I gave her to my said daughter Emily and grand
daughter Caroline , as mentioned in my answer to said first interogatory- The gift took place at my house about he for the execution
and date of the said Deed of trust to Horine , with this special
order to th said Emily that the said negro Rebecca was
not to be removed from the state of Missouri

3rd Did you ever give, or did you not, your consent to the
removal of said Rebecca into the State of Illinois so,
when and under what circumstances; and was such consert
given but one on after making said deed of trust

Answer So far from giving my consult to the removal of said
Rebecca to the State of Illinois , I positively and repeated by
forbade my said daughter Emily , and also my other children
from doing so, and I never gave my consent to any such
removal

Q 4th, Did you ever make any other Deed of trust of said
above named negroes and especally of said Rebecca to
said Thomas M Horine or to any othr person, save
the one above and referred to ?

Answer, I never in any manner or form, made any other
deed of trust to said Horine , nor to any othr
person, for said negroes or either of them, than that
dated October 18th 1832, and refered to in my answer
to the first interrogatory?

5, are you aware and do you know that Rebecca , the slave in
question resied at any time in Illinois If so, state where
with whom and how long?

Answer. I do not know that said negro ever resided in Illinois

6th . Have you over heard any admissions of on Black, one
of the defendants as to the esidence of the
himself and family in the state of Illinois with said
Rebecca ? If so, state it.

Answer. I do not recollect that I ever heard from Mr. Black
that the said negro Rebecca , had resided with him
in his family in Illinois , on the other hand, he
has written to me that he had no claim for
himself on the said negro Rebecca and further
not.

William James

State of Missouri
County of the ss:

I John , a of he and for said
County, that on the day of the data, hereof William James of lawful age, and made oath, in the
holy of Almighty , that the foregoing
and answer to the interrogatories propounded which in that
behalf, contains the truth the whole truth and nothing but
the truth of his knowledge in the case of Rebecca vs. Black & that lock,
in a suit now defending in the St. Louis Circuit
Court -

given under my hand this 19th day of November
A.D.1838. John M arthur, Justice ofthe peace fees 1.37 1/2

Opened & filed Nov. 24th 1838

John Ruland Clerk

County of St. Louis , sct.
State Of Missouri , To the Sheriff of St. Louis County,---Greeting:

You are hereby commanded to summon David B . Waterman and
Henry Blackwill
that setting aide all manner of excuSe and delay, he be and appear in proper person
before the Judge of our Circuit Court , on the 10th day of January
1840 at the City of St. Louis , then and there to testify,
and the truth to say in a certain matter of controversy now pending in our said Court,
wherein Rebecca (coloured) is
plaintiff and Black & Mattocks is
defendant on the part of
and have you then there this writ.

Witness, John Ruland , Clerk of our said Circuit
Court , at the City of St. Louis , this ninth
day of January in the year of our Lord eighteen
hundred and forty
John Ruland Clerk, C.C.

Executed this writ in the County of
St. Louis by reading it to Henry Blackwill
on the 9th January 1840 -D. B.
not found

W. Brotherton Sherff

Service50Non1262

Circuit Court November
Term AD 1839

for plff

B. Araterman
( New
in one of Christy )
Henry Blackwell
(Printer in ) 10th January

In the Circuit Court , for the County
of St. Louis state of Missouri .
Tothe above named plaintiff.

You are hereby Notified, That Depositions of Witness to be read in evidence
in the above cause, on the part of the defendant will be taken at
the residence of James Black in town of
in the County of and state of Illinois on the sixteenth
day of marchin between the hours of 8 0'clock
in the forenoon, and 6 0'clock in the afternoon: and that the taking of said depositions, if
not completed on that day, will be continued from day at the same place and between
the same hours, till completed.

James Black &
Lewis Mattock
B.
St. Louis
4 March 1840

Served this Notice in the county of St. Louis
on the 4th day of March 1840 by delivering a true
copy there of to Haris L. the attorney
for plaintiff

Marshall Brotherton sheriff by 50

County Of St. Louis ,Sct.The State Of Missouri , To any Judge or Justice of the Peace or other Judicial Officer of the
State of Illinois
Greeting.

We, reposing special trust and confidence in your integrity and circumspection, do authorize
and require you, that you cause to come before you, such person or persons as
shall be named to you by James & Lewis Matlock
Attorney or Agent, and him or them examine upon his, her or their corporal oath, (to be
by you administered,) touching their knowledge of any thing that may relate to a certain
matter of controversy, now pending in our Circuit Court , for the County of St. Louis ,
wherein Rebecca is
plaintiff and James & Lewis Matlock are
defendant on the part of the afendants and having
so reduced the said depositions so taken by you a aforesaid in writing, you are required
to send the same, together with this commision, enclosed under your seal, to our said
Circuit Court , with all convenient speed.

Witness, John Ruland , Clerk of our said Circuit
Court , at the City of St. Louis , this fourth
day of March in the year of our Lord, one
thousand eight hundred and forty.
John Ruland Clerk C.C.

Deposition of Maria Field a witness, produced, sworn and
at the residence of James Black in the town of
Vandalia in the County of Fayette and State of Illinois , before
me James U. Peery a Justice of the Peace in and for the
County of Fayette and State of Illinois aforesaid, in a certain cause
now pending in the Circuit Court for the County of St. Louis in the
state of Missouri between Rebecca plaintiff and James Black
and Swis Mattock Defendants, on the part of the said Defendants.

Maria aforesaid of lawful age being produced, sworn
and on the part of the said Defendants
and saith.

"That the girl Rebecca was conveyed by to Thoma U.
to be held in trust by him for our of James Black; daughter to be when
she should arrive at full age - that sometime in august 1836
thi deponent took the said Rebecca with in to in the State
of Illinois , when this deponent went then on a visit to her sister
tork the said girl with her as a servant, and intended to return
where with her to the State of Missouri in four or five months,
but that in consequence of the absence of her sisters husband she
concluded to remain with her sister during the with - that she
sent Rebecca to St. Louis in the state of Misouri sometime
in the month of February 1837, and would have sent her
there sooner, but could not in consignment of the
the Mississippi river. That she took the said Rebecca with
in to contrary to the wishes and without the consent
of Thomas U. Home to whom she belonged in trust as
aforesaid. - This deponent knows that she was taken to
Vandalia by Black, but does not know how long she
unmarried there - Rebecca was were hired to a
or any person in Kaskaskia nor did
in Kaskaskia in the State of Illinois , and further said Deponent
saith not.

I James M Peery a Justice of the peace in and for the
County of Fayette and state of Illinois do hereby
Certify that Maria Field the deponent whoe place
of residence is St. Co. in the State of Missouri
was by me sworn to testify the whole truth of her
knowledge touching the matter in controversy in the caue
whereas Rebecca is plaintiff and James Black and
Lewis Matlock defendants and the said deponent
was examined and her examination reduceed to
writing and subscribed by said deponent in my
presence on the 16th day of March 1840 between
hours of 8 Deloch in the forenoon and C Deloch
in the afternoon of the said day at the house
of James Black in the Town of Vandalia and
in the County of Fayette and State of Illinois
given and certifyed the 16th day of March
1840.before me

James M Peery

Justice of the peace for the
County of Fayette & State of Illinois

I James M Peery a Justice of the peace in
and for the County of Fayette and State of Missouris
do certify that in pursuance the commissioner
and notice came before me at the House of James
Black in the Town of Vandalia in the County of
Fayette and State of Illinois , Maria Field who was
by me sworn and examined and her examination
reduceed to writing and subscribed by her in
my presence, and her said deposition is now herewith
retuned, Given at Vandalia this the
16 day of March 1840.

James M Peery

Justice of the peace for
County of Fayetti state of Illinois

State of Illinois
FayetteCountySct

I James W Berry Clerk of
the County Commissioners Court of Fayette County
aforesaid, do hereby Certify that James U. Peery
whose name is subscribe to the foregoing Certificate
is, and was at the term of signing of the same and acting
Justice of the peace within and for the County of
Fayette and State of Illinois , duly commissioned
and qualiied; and that full faith and credit are
and of right ought to be given to all his Official
acts as such.

In testimony whereof P
have herein to subscribe my name
and offered the seal of said Count
at Vandalia this 16th day of
March A.D. 1840. M. Berry Clk

Opened & filed Mch 25th 1840

Jn Ruland Clerk

Depostion for defendants

County of Saint Louis , Sct,
The State of Missouri
To The Sheriff of St. Louis County, - Greeting :

You are hereby commanded to summon David B . Waterman
B. Waterman Henry Black
that setting aside all manner of excuse and delay, he be appear in proper person
before the Judge of our Circuit court, on the 8th day of May 1840
at the City of St.Louis , then and there to testify,
and the truth to say in a certain matter of controversy now pending in our said Court,
wherein Rebecca is
plaintiff and Black & Matlock an
defendant on the part of Plaintiff
and have you then and there this writ.

Witness, John Ruland , Clerk of our said Circuit Court , at the City of St. Louis , this 5th
day of may in the year of our Lord eighteen hundred and
forty.
John. Ruland Clerk; C.C.

March term 1840

for plaintiff

David B Waterman
his wife - (
new market)
Henry Blackwell
(
office)
8th May
not served

County of St. Louis , sct. State Of Missouri , To the sheriff of St. Louis County-Greeting:

You are hereby commanded, to summon James M Duncan

that setting aside all manner of excuse and delay, he be and appear in proper person
before the Judge of our Circuit Court , on the 11th January AD
1841 at the city of St. Louis , then and there to testify,
and the truth to say, in a certain matter of controversy now pending in our said Court,
wherein Rebecca () is
plantiff and Black and Matlock at is
defendant on the part of
and have you then there this writ.

Witness, John Ruland , Clerk of our said Circuit
Court , at the City of St. Louis , this fourth
day of january in the year of our Lord, eighteen
hundred and forty one.
John Ruland Clerk, C.C.

140

for

James M.Duncan William John 11th Jan. 1841

The not found

M.Brotherton Sheff
fee. 37

County of St. Louis , sct. The State Of Missouri , To the Sheriff of St. Louis County - Greeting:

You are hereby commanded to summon David B . Waterman
& Henry Blackwell
that setting aside all manner of excuse and delay, he be appear in proper person
before the Judge of our Circuit court, on the 11th January A.D.
1841
at the City of St.Louis , then and there to
testify,
and the truth to say in a certain matter of controversy now pending in our said Court,
wherein Rebecca (colour girl) is
plaintiff and Black and Matlock is
defendant on the part of Plaintiff
and have you then and there writ.

Witness, John Ruland , Clerk of our said Court, at the City of St. Louis , this fourth
day of January in the year of our Lord eighteen hundred and
forty one.
Jn. Ruland Clerk, C.C.

Execited this writ by delivering a true copy
thereof to a white member of the family
of David B . Waterman our the age of fifteen
years on the 8th of January 1841 and by reading it to
Henry Black well on the 7th of January 1841

M.Brotherton Sheff By C. Brown
deputy 1.00

140

for plff

David B Waterman Henry Blackwell 11th Jan.

March Term AD 1841.

This can continued on
of the of the Deposition of me Thomas M Horine

I am aware of the taking of the said
Deposition on the of the
alone
the deposition If my memory me by It was the understanding between
original for Defts that
all formalities and legal technicalities in the
taking of deposition

for plff

County of St. Louis , sct. The State Of Missouri , To the Sheriff of St. Louis County - Greeting:

You are hereby commanded to summon James Duncan .
John A. B.Waterman, Henry Blackman
that setting aside all manner of excuse and delay, he be appear in proper person
before the Judge of our Circuit court, on the 3rd day of March
A.D. 1841 at the City of St.Louis , then and there to
testify,
and the truth to say in a certain matter of controversy now pending in our said Court,
wherein one Rebecca is Black Matlock is
plaintiff and Black is
defendant on the part of Plaintiff
and have you then and there writ.

Witness, John Ruland , Clerk of our said Court, at the City of St. Louis , this 18th
day of March in the year of our Lord eighteen hundred and
forty one.
Jn. Ruland Clerk, C.C.

Circuit Court March
term A.D.1841.

for

.Duncan
Louis
John. A. D.B.Waterman
henry Blackman
30th March

neither of the within
named witness found

M.Brotherton
62

County of St. Louis , sct.
State Of Missouri , To the sheriff of St. Louis County Greeting:

You are hereby commanded, to summon Henry Blackwell
that setting aside all manner of excuse and delay, he be and appear in proper person
before the Judge of our Circuit Court ,forthwith
at the city of St. Louis , then and there to testify
, and the truth to say, in a certain matter of controversy now pending in our said Court,
wherein one rebecca is is
plantiff and Black and Matlock
defendant on the part of plaintiff
and have you then there this writ.

Witness, John Ruland , Clerk of our said Circuit
court, at the City of St. Louis , this 30th
day of march in the year of our Lord, eighteen
hundred and forty one
Jn. Ruland Clerk, C.C.

not found

M Brotherton Sheff
12

March
Term Cir Court
1820

for plff

Henry Black well (near new market
)

County of St. Louis , ss.
The State Of Missouri ,
To D. B. Waterman
Henry Blackwell James Duncan
Johan A
Greeting:

You are hereby commanded, that setting aside all manner of excuse and delay, you appear
before the Judge of our Circuit Court , on the 21 October 1841
at the city of St. Louis , then and there to
testify, and the truth to say, in a certain matter of controversy now pending in our said Court,
wherein Rebecca (a negro) is
plantiff and Black and Matlock are
defendant on the part of plff
and herein you are in no wise to fail.

Witness, John Ruland , Clerk of our said court, with the
seal thereof hereto affixed, at office, in the City of St. Louis ,
this 13 day of October in
the year of our Lord, one thousand eight hundred and
forty one
John Ruland Clerk, C.C.

M. Brotherton
Shff
Fee 75

Circuit Court
November Term 1841

for plaintiff 21 October

D. B. Waterman Henry Blackwell - at Republican Office
Henry Blackmore. Duncan
John A. Sprigg

Depositions in the this
case for Deft taken into
Court Dec 5 1844 for
Shepley to use in a
case of this same style