To the honourable Luke E. Lawless Judge of
the St. Louis County Circuit Court .

The petition of Brunetta Barnes -
an infant within the age of twenty one years
to wit. the age of fifteen years, who appears by her
next friend Peter Charleville , respectfully re-
presents. That she is a person of colour, and
the daughter of parents who were at the time
of her birth and still are, free- That your
petitioner is unlawfully restrained of her
freedom by a certain Berry Mitchell Meachum in the
city of St Louis and State of Missouri , said Ber-
ry Mitchell Meachum being a man of color and by
profession a clergyman of the Methodist Baptist persua-
sion or belief: your petitioner shows to your honour
that she is detained by the said Mitchell Meachum
and restrained of her liberty by virtue of a
claim proferred by said Meachum to have the ser-
vices of your petitioner as his slave. Your peti
tioner avers that she is of right entitled to her
freedom- that she was born of free parents &
that by no act of her own nor by the proceedings
of any authoritative tribunal has that right
ever been forfeited. but that she is forcibly abrid-
ged of the same by the said Meachum as aforesaid
your petitioner further shows that she is fearful of
being removed from the jurisdiction of this state in con
sequence of this application to your honour or in an-
ticipation of your honour's action thereupon. and
that the said Mitchell Meachum treats her with harshness
and inhumanity. to wit by frequently & cuelly beat
ing her. In consideration whereof may it please
your honour to grant unto your petitioner permission to
sue for her freedom as a poor person: and futher may
it please your honour to grant a warrant directed
to the Sheriff of St. Louis County commanding him
to seize your petitioner & have her before this court
and to summon the said Mitchell Meachum or other per
son in whose possession your petitioner may be
found. to appear before this court on a day and at
a place to be therein specified, and receive such
order as the court may make in the premises &
abide by the same. And that it may please your
honour to grant unto your petitioner such other
and further relief as to your honour may seem
fit and the nature and equity of the case may re-
quire. And as in duty&.

Thos . T . Gantt for Petr

State of Missouri In St Louis Circuit.County of St. Louis . St Court July Term 1840

On this thirtieth - day of-
July 1840. Comes into open Court Leah Charleville
and maketh oath and Saith that she is of her
own knowledge acquainted with the facts set forth
in the aforegoing petition. and that the same as
stated are just & true.

Sworn &subscribed to
this thirteenth - day
of July in the
year 1840 Jn Ruland Clerk
CtCt Leah her Charleville mark

State of Missouri
County of St Louis .
Ss.In St. Louis Circuit
court July Term 1840-

Ordered by the Court that the above mention
ed petitioner be allowed to sue as a poor per
son to establish her freedom. and that Thos
T Gantt and George F. Strother be assigned as counsell
for said petitioner within behalf - and that
the petitioner have reasonable liberty to attend
her counsel and the court on occasion may re

quire, and that said petitioner be not re-
moved out of the jurisdiction of the court and
that she be not subject to any severity on ac-
count of her application for freedom

L E Lawless

Brunetta Barnes by
Peter Charleville her
next friend
vs
Berry Mitchell
petition for free-
dom

Thos T Gantt
for petr

No 40. St. Louis Circuit Court
November Term 1840

Brunetta Barnes (by next
friend Peter Charleville
vs
Berry Mrachum
Warrant & summons

Pet. for freedom.
. Atty

Filed July 30th 1840 Jn. Ruland Clerk

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

Whereas it has been represented to the honourable Judge
of our Circuit Court for the county of St. Louis , now in session
, by the Petition of Brunetta Barnes , an infant within the age
of twenty one years, to wit; the age of fifteen years, who appears
by her next friend Peter Charleville , that she is unlawfully
restrained of her freedom by a certain Berry Meachum ,
you are therefore hereby commanded to seize the said
Brunetta Barnes , the petitioner, wherever she may be found,
and bring her before our said court forthwith, and also that
you summon the said Berry Meachum if he be found
in your county, that he be and appear before our said court now
sitting in the city of St. Louis . forthwith - then and there
to answer unto the petition of said Brunetta Barnes .
who sues by his next friend Peter Charleville , as
set forth in the said petition hereto an
-nexed - and have you then there this writ with your
return thereon. Now you shall execute the
same.

Withness, John Ruland Clerk
of our said court with the seal there-
of hereto annexed, at office in
the City of St. Louis this thirtieth
day of July Eighteen hundred
and forty. Jn. Ruland Clerk

In St. Louis Circuit Court - July Term 1840. State of Missouri
County of St. Louis
Ss.

Ordered by the court that the
above mentioned petitioner be allowed to sue as
a poor person to establish to her freedom, and that Tho-
mas J. Gantt and George F. Strother be assigned as coun-
sel for said petitioner in this behalf- and that the pe-
titioner have reasonable liberty to attend her counsel
and the court, as occasion may require; and that said
petitioner be not removed out of the juris-
diction of the court and that she be not subject to any
severity on account of her application for freedom.

signed, L . E .. Lawless A true copy of the order
Attest, Jn. Ruland Clerk

Executed this writ in the County of St Louis
by hand have now the body of the within
named Brunetta Barnes in open court
31st August 1840

Berry Meachum not found in my
county

Marshall Brotherton
by Wm S. McKnight Shff
Depty Service 1 1.50
1.50

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 Ohio
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 Brunetta Barnes her
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 said Brunetta Barnes is
plaintiff and John B . Meachum is
defendant on the part of the Plff. and having
so reduced the said depositions so taken by you as aforesaid in writing, you are required
to send the same, together with this commission, 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 26th
day of March in the year of our Lord, one
thousand eight hundred and thirtyforty one. Jn. Ruland Clerk C.C.

Brunetta Barnes
vs
John B Meachum
Dedimus to Ohio
for Plff.

St. Louis Circuit Court .

Take notice that on the tenth day of May in the
year of our Lord one thousand eight hundred and forty one between the hours of
Eight, in the forenoon and six, in the afternoon, of that day, at
the office of John Quinland Esq at Bethel
Clermont County in the State of Ohio
depositions will be taken by the undersigned, to be read on the trial of the above entitled case, on
behalf of the plaintiff; and that the taking of said depositions, if not completed
on that day, will be continued from day to day at the same place and between the same hours,
until completed.

To the above named defendant Thos .. T . Gantt
atty for plff

Deposition of witness taken in a case pending in the
St. Louis circuit court Statee of Missouri wherein Brunetta Barnes
is plaintiff and John Berry Meachum is depondont
in pursuance of notice hereto attached and at the
time and place therein mentioned: Neither of
the parties being present Jesse . R. Grant of the
County of Clermont and State of Ohio . of lawful
age being first duly sworn by me as hereafter
certified. Deposes and says that some time in the
year 1826 or 27 the late Peter Grant of Maysville
Ky brought to the house of deponant then in
Georgetown Brown County Ohio a colord woman
named Leah he said Peter Grant Stated that
he had come to assist Leah to establish her
freedom in the Brown County Court of Common
Pleas then in session- a few hours after Arthur
Mitchel the former owner & then claiment of
Leah and John Mitchel the Brother of Arthur -
Mitchel come to the house of deponant. deponant
was previously acquainted with the Mitchels and
learned of them that Arthur Mitchel had lived
some time in Brown County Ohio from one to three
years the precise time not Recollected and had
kept Leah with him as a servant. It was on these
grounds that Leah claimed her freedom the parties
staid at the house of deponant most of the time
until the trial come on which was from four to
six days- deponant thinks he was not present
at the trial but after it was over the Mitchels
Peter Grant & Leah all Returned to his house and
all stated and agreed that Leah had succeded in
establishing her Right to freedom. deponant also
heared the same from Some of the officers of the court
and other persons at the trial- it was then agreed
by the parties that Leah and her child should
Return with Arthur Mitchel as free persons and live
with him as Members of his family, and with that
understanding they all left the house of deponant- Leah
appeared to be from twenty to twenty five years of age she
had a Mulatto male child with her from two to three
years old and was said to be in an advanced state of
pregnancy- deponant thinks that Leah was of light
complexion but does not distinctly Remember
deponant heared that Arthur Mitchel afterwords
moved to the State of Missouri and took Leah and her
children with him. but has no personal knowledge
of the parts, and further this deponant said not

(signed) Jesse R Grant

I John Quinlan a Justice of the peace in and for
the township of Tate in the County of Clermont Ohio
do hereby certify that the above named Jesse R. Grant
was by me first duly sworn to testify the whole truth
and nothing but the truth and that the foregoing
deposition by him subscribed were Reduced to writing
by me and were taken at the time and place
specified in the inclosed notice

In testimony whereof I have hereunto set my
hand this tenth day of May in the year 1841

John Quinlan P.

The state of Ohio
Clermont County
S. S -

I. pl, Morris Clerk of the Court
of Common pleas in and for the County
and State aforesaid do hereby certify that
John Quinlan Esquire before whom
the foregoing deposition of Jesse R. Grant
appears to have been sworn to & subscribed
was at the time of taking and certifying said deposition
and now is an acting justice of the peace in and for
said County of Clermont duly commissioned and qualified
and full faith and credit are dueand ought to be given
to all his official acts as such in all Counts of Word
as well as elsewhere and that his signature thereto
written is genuine - In testimony whereof I have
hereunto set my hand and affixed the seal of said
Court of Common pleas at Batavia in said County
this 12th day of May A. D. 1841.

J. . Morris Clk (Fee County 50 per)

Depositions of
Jesse R Grant

Opened & filedMay 20 1841

Jn. Ruland Clerk

Brunetta Barnes
vs
John B Meachum
Depfor plff