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

Archibald Barnes an infant of colour, under the age
of twenty one years to wit of the age of Sixteen years, admit-
ted to sue here as a poor person by Peter Charleville his
next friend of Saint Louis County and State of Missouri complains
of Berry Meachum of the same state and county
of a plea of trespass and false imprisonment - For that
the said defendant heretofore to wit on the first day of
January in the year eighteen hundred and forty at the
County aforesaid in and upon the said plaintiff did make
an assault: and him the said plaintiff did then and there
beat and evilly treat; and then and there did imprison
and keep detain and hold the said plaintiff in Confine
ment and slavery, and still continues to keep hold &
detain the said plaintiff in slavery and has ever since
the day and year aforesaid kept & held the said
plaintiff in Slavery as aforesaid to wit at the county
aforesaid contrary to the laws of this state, and against the
will of said plaintiff and the said plaintiff avers
that he is now, and was at the time of the committing of the
grievances above complained of and before that time and
has ever continued to be and still is a free person; and
that the defendant then and there held and has ever since
then continued to hold and still holds him the said plaintiff
in Slavery to wit at the county aforesaid - and then &
there did other wrongs tothe said plaintiff against the
peace government and dignity of the state & contrary to
the form of the statute in such case made & provided
to the damage of the said plaintiff in the sum
of one thousand dollars, and therefore he brings suit
and so forth

Gantt&Strother
for plff

In St Louis Circuit Court
November Term 1840

Archibald Barnes by
Peter Charleville his next friend
vs
Berry Meachum
Tresass & false im
prisonment

Damages $ 1000

Let aSummonsissue

Gantt&Strother
for plff

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

We command you to Summon Berry Meachum if he
be found in your County that he be and 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 third Mon-
day of November next, then and there to answer unto Archibald Barnes who sues by Peter Charleville his next friend of a
plea of trespass and false imprisonment,
to the damage of said plaintiff of one thousand
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 Thirty first day of
August in the year of our Lord eighteen
hundred and forty John Ruland Clerk

I acknowledge myself bound for all costs that may accrue in the above cause.

Witness my hand and seal, at St. Louis , this day of 184

contd BK 13 p 12- Sub & Judgt for plff. noml. dam'ges & Judge of liberation Bk 13 p 32 6>

No 120 St. Louis Circuit Court
November Term 1840

Archibald Barnes by his next
friend
vs
Berry Meachum
Summons

Trespass & false imprisonment
Damages- $ 1000

Gantt & Strotherp.q.Filed August 31 1840 John Ruland ClerkFree

Executed this writ in the County of
St Louis by offering to read it and the
Declaration to Berry Meachum on the
1st day of September 1840. which he
refused to hear

Service 1.00 Marshall Brotherton Sheriff
By W.S. McKnight Depty

St Louis Circuit Court

And the said defendant
by his attorney comes and defends the the wrong
and injury when &.c. and says that he
is not gulity of the said supposed trespas-
ses above laid to his charge & of this
he puts himself upon the county &.C.

And for further plea he says that the
said plaintiff was at the said times when
&.c. his slave & this he is ready to
verify, wherefore he prays
&.c.

&
attys for deft

St. Louis Circuit Court

Archibald Barnes
vs
Meachum

plea

Spalding &
attysFiled November 17 1840 Jn Ruland Clerk