To the Hon. the
Circuit Court of the County of St. Louis .

The undersigned Alsey a woman of color
respectfully reprersents that she was born a
salve of me about thirty eight
years ago, near County in
the state of Kentucky where she continued
to reside in the family of her master the said
Crops until she was taken to
the county commonly called the salive about
twelve miles from showing term in the state
of illinois by Robert and
Rachel Crop his wife, a daughter of the said
crop, to whom your petitioner was
given by her said master - That your
petitioner continued to reside in the said state
of Illinois at the slave and at town
with the said this wife Rachel
as their servant for the period of about five
years at the end of which time the said
being greatly involved in debt
her said first master the said
came to the state of illinois took
of your petitioner and took her again to Logan County Kentucky and from her to the
state of Missouri and sold her as a slave
to one Your petitioner states
that she has continer to inside in St. Louis County
Missouri from that time until the presant time and is
now held in slavery and deprived of her just
rights freedom and liberty by one William
sullivan - You petitioner is
informed and belives that under these state of facts, that she is untitled to her freedom, and
she your honorable Court, to allow her to
sue as a poor person in order to establish her
right to freedom in an action of false imprison
ment against the said William sullivan
and she will pray so

Alsey her X mark a woman of
color

State of Missouri
St. Louis County ss.

Alsey a woman of color, being
duly sworn says that the facts set forth in
the forgoing petitioner first and time

Alsey her X mark

The Court bring of opinion, that then is
sufficient matter contained in the petition hereto
attached to authorized the commencement of a suit
makes the following orders.

First. That the said Alsey have to sue as
a poor person to establish her right to freedom, and
that Risque & king be assigned as her counsel.

Second. That the said Alsey have reasonable liberty
to attend her sounsel and the Court, as occasion
may require,; that she be not removed out of the
jurisdiction of the Court, and that she be
not subject to any severity on account of her
application for freedom.

of the th Judicial
Circuit of Missouri

St. Louis Cir . Court , State of Missouri
St. Louis County Ss.

Alsey, a woman of color, complains
of William S.Randolph of a plea of trespass
for that the said defendant, on the first day of
in the year of our Lord one thousand eight hundred and
forty one, made an assault upon the said plaintiff
to writ, at St. Louis in the County aforesaid, and then and
there beat, bruised and ill treatd her, the said plaintiff,
and detained her in prison there, without any reason.
or cause whatsoever, for a long time, to
writ, for the spare of one day, contrary to the laws
of the State of Missouri and against the will of the
said pleantiff. To the of the said plaintiff
one Dollar & therefore she brings suit

Risque .
for

Petition for to sue
for freedom &
in false Imprisonment

The Clerk will issue
laws in false imprisonment
in this entitled
cause.

R M
for Murder &

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

We command you to summon William S.Randolph ,
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 Monday
of March next, then and there to answer unto alsey,
a woman of color, of a plea of trespass
to the damage of said plaintiff of one
dollar: 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 twenty second day of
February in the year of our Lord eighteen
hundred and forty one.
Jn. Ruland Clerk.

The Court being of opinion, that there is sufficient matter
contained in the petition hereto attached to authorize the
commencement of a suit, makes the following orders.
First. That the said alsey have leave to sue as a poor
person to establish her right to freedom, and that
Risque, murdoch & be assigned as her counsel.
Second. That the said alsey have reasonable liberty to attend
her counsel and the Court as occasion may require,
that she be not removed out of the jurisdiction of the
Court, and that she be not subject to any severity on
account of her application for freedom.

Judge of the
8th Judicial Circuit of Missouri . Jn.Ruland Clk
a true copy of the orders.

petition filed 12 p 111 Amended declaration filed by of court 12 p 113 plea filed 12 page 133

agrement filed Bk 12 p 363. mistrial Bk 13 p 211 Verdict for

14 p 170 13 Mo for new trial14 p 177

no 305 St. Louis Circuit Court
march Term 1841

Suit for freedom
risque, mudroch king

filed 22nd Feb. 1841
Jn Ruland Clk
Free

Executed this writ in the County
of St. Louis on the 26th day of february
1841 by offering to read it and the declaration
and petition and also the order of
count to William S Randolph this
defendant are of which he said
defendant refused to heavy

Marshall Brotherton
Free 100

In the Circuit Court of St. Louis County
march Term 1841

State of Missouri
St. Louis County

And now at this day
comes the plaintiff and by of the Court
just had and obtained files an declaration
as follows. Alsey a woman of color, complains
of William S . Randolph of a
plea of trespass for that the said defendant at
St.Louis to wit at the County aforesaid on the
first day of February in the year eighteen hundred
and forty one, with force and assault
the said plaintiff and her there and there
look and imprisoned and restrained her of he
liberty and held her in from the
said day and year last aforesaid until the
twenty second day of Febuary in the year
aforesaid - And the said plaintiff avers that at
the time of the committing of the said grievances
the said plaintiff was and still is a free person,
and that the defendant held and still holds
her the said plaintiff in slavery against
the law of the land and against the will
of the said plaintiff and other wrongs to the
said plaintiff within that time did against
the please be and to the plaintiff one
dolla & therefore she brings suit

In St. Louis Cir Court
march T. 1841

filed by leave of Court
February 26 1841 Ruland Clerk

St. Louis Circuit Court
marh Term 1841

and the defendant
by his attorney comes and defendant the wrong &
injury when and says that he is not
guilty of the said trespass & wrongs in
manner and form as the said plaintiff has
above thereof complained against him
and of this he puts himself upon the
county

and the plaintiff the like

No, 305 March Term 1841
St. Louis Circuit Court

plea

&
Filed 15th Mch 1841 Jn. Ruland Clk

Opened & filed 5 July 1841
Jn. Ruland Clk

to Illinois
for plff.

Depositions for plff

0.50witnesses1.50Justice fee3.00Paid by plff5.00

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

Know Ye,that we, in confidence of your prudence and fidelity, do by these presents authorize
you to cause to come before you, to be examined as witness in a cause depending in
our Circuit Court for the County of St. Louis , in the State of Missouri , wherein ailsey
a woman of color
is plaintiff and William S Randolph is
defendant all
and every such person, and at such time and place, as shall be named to you for that purpose by
the said ailsey her

Attorney or Agent. And we command you to examine all and every such person upon his oath
or solemn affirmation first made or taken before you, to testify the whole truth touching his
knowledge of any thing relating to the said matter in controversy between the said parties;
and that you do take such his examination, and reduce the same into writing. When you shall
have so taken his examination, you are to cause the witness to sign the same, and to that and
each examination, at the foot thereof, you are to append your certificate, setting forth the facts
that the examination was subscribed and sworn to or affirmed by the witness, and the day, as
well as between what hours of the day, on which it was done, as also the place of residence of
the witness, if known to you. Should any paper or exhibit be produced or proven, or be referred
to by the witness, you are to described the same in his examination, or cause it to be so marked
by, him, as to establish its identity, and attach the same to his examination. The examinations
thus taken you will cause to be accompanied by a certificate of your official character, attested
by the seal of State; or should it be more convenient, such authentication and proof of your offical character may be made by the certificate and seal of the clerk of any court of record of any
county of the State, District or Territory in which you reside, stating also in addition to the facts
of his being clerk and that the Court is one of record, that at the time when the depositions
were taken you were an acting judge, (or other such officer to whom this commission is addressed,)
and duly commissioned as such. And you will return the same and all exhibits produced to
you, annexed hereto, carefully closed up and under your seal, directed to the clerk of the Circuit
Court in and for the County of St. Louis , Missouri , with the names of the said parties litigant
endorsed thereon, with all convenient speed.

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

In the Circuit Court
for the County of St. Louis
state of Missouri

To William S Randolph Defendant.

You are hereby notified That depositions
of witness to be read in wisdom in the above untilled
cause, on the part of the plaintiff, will be taken at
the Clerks office of the Circuit Court for the County of
in the town of equality in the County of
gallation and state of illinois on the twenty ninth
day of june 1841, between the hours of eight of
in the forenoon, and six o'clock in the afternoon 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 same hours till completed.

for St. Louis 16 June 1841

served a true copy of this
notice on S.Randolph
the 17 June 1841, at St. Louis .

F.B.

The deposition of John greenshaw Taken or the same
time & pleace to be read as evidenced in the Same
Suit the said deponent being well known by me
and of Lawful age and first duly sworn deposeth as
fallows: That he know a coloured woman by the
name of Ailsey who was at the saline in this County
in the possession of Robert for several
years say five or six years I think,
her here about the year 1819 and I think she remained
here untill 1824 I have seen Cross the Fatherinlaw
of Funkhouser at his Funkhouser house
several times Aisley was there, that
Grand got the same woman and some
Children from Funkhouserbut how many children
I do not know and what become of her afterwards
I do not know & further this deponent saith not

John Crenshaw sworn to and subscribed
before leo white . P.

The Deposition of Daniel Wood taken at the same
time and placed to be read as evidence in the same
suit the said deponent being of Lawful age and first
duly sworn says he knew a coloured woman by the name
of Ailsey who Resided with Robert Funkhouser at the
Saline in this County and over whom Funkhouser
exercised ownership that she ailsey was there
in 1819 and Continued with him several
years perhaps three or four and perhaps more The Deposition of timothy guard Taken as
office of the clerk of the Circuit Court of gallatin
County in the Town of equality and state of illinois
on the 29th day of June AD 1841

agreeably to the mission here unto annexed
and to be read as evidence on the part of the plaintiff
in a suit now pending and undetermined in
the Circuit Court for the County of St Louis
and state of missouri wherein Ailsey a
woman of Color is Plaintiff and william
S Randolph is defendant. The deponent being
know to me and of Lawful age and first duly
Sworn deposeth and saith to wirt

That some years ago he was acquainted with a colored
woman by the name of Ailsey who belong to or was in
of Robert houser at the Salin in
this County where she remainded in housers
same three or four years when he
houser gave up the said Ailsey and two
Children to me to pay a debt and afterwards she
was run off from here by housers friends
and overtaken by me and sent by me to
to a friend for safe keeping where one
the fatherinlaw of housers for her
and her Children when after lawing about them
some time we compromised and he gave up
one of the Children which Shortly afterwards
child and Further this deponent saith nor

Sworn to and Subscribed
before me Leo White P. I. P

I have seen crop the Fatherinlaw of Frunk houser
his house while ailsey lived with him but
do not know who really owned the negro and
further this deponent Saith

Sworn to and subscribed before
me Leo white

State of illinois County
sct

Gallatin county I leonard white
Justice of the peace in aforesaid County do Certify that
the foregoing Deposition of Timothy Guard and John
have and Daniel wood were taken before me
agreebly to the and notice as in the
Caption mentioned that they Severally Signed
their names and ever by me Sworn on the holy to the truth thereof given under my
hand this 29th day of June 1841

Leo white

State of illinois Countysct

I leonard white clerk of the
County commissioners Court in and for the County
and state aforesaid Do Certify that Leon and white
before whom the foregoing Deposition was taken
and whose signature appears to the above Certificate
is and was at the time of taking the same
an acting Justice of the peace in and
for said County duly commisioned and
qualified as such and that full faith
and is due all his official acts as such.

In Testimony whereof
I have hereunto my hand
and affixed the seal of said Court
at equality this 29th day of June AD
1841

Leo White Clk
By White , ,

argument to until
Term & that The .

Filed July 19 1841 Jn Ruland Clerk

Suit for .
Circuit Court St Louis
County for 14 sept 1841.

St Louis 19 July 1841 .
July Term of said Court

If is agreed, that this cause stand
continued. until the next term of this Court and
it is further agred by the defendant that all
execption to the depositions taken on the
of the Plaintiff in this case shall be waived
and no objection made them to, and the same
read in evidence, as if in all restarts properly
taken

B.
for
for

Opened & filed nov 26 1841

Jn Ruland Clerk

for

Postage 18

26
183
Deposition of Johnson

of the Circuit Court
St. Louis

Missouri

State of Illinois County of Madison

Deposition of John
of the County and State of aforesaid taken
in the 25th day of june AD 1841 between the
of 10 in the morning and 6 o clock in
the evening of the same day, at the officer
of Capland of the
of said city and state to the
to be read in Evidence in a
before the St. Louis Vincent court me
the state of missouri between Alsey a
of colour plantiff and defendant as
follows the said john johnson death
and say that about the year 1819 I
was living the christian County and
had a negro girl by name of Alsey
in my family belonging to
Cross, and on a certain day I Cannot see
the precise a houser came to my house and said
he had come for the negro girl
above named and as he was known to
the family and myself I did not present
him fresh taking the negro, and he did so &
the next time I saw the girl Alsey in a short time Mr Cross
got me to accompany him in search
of his negro and found him at the house of
William camp in the state of
where she had been brought by as Mr. Campbell told us and he
Mr. Campbell would not give up the negro
girl and compelled us at the print of a
to Mr cross then suedMr. Campbell in the court of County the Suit was put off
some time by Mr. Campbell until about
the year when obtained the
said girl at law and had authority
to take his negro and I was sent by
after her, who had been carried back
to illinois by Mr. Campbell where I form
her, and took her home to her master in
so to whom she belonged as
property to my certain knowledge
fallon to him by

John sworn to and subscribed before
me at my officer
in on the 25th
day of june AD 1841

County of St. Louis , ss.The State Of Missouri , To Coleman Duncan and James Duncan

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 fourth day of January
next 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 Alsey a woman of color is
plantiff and William S Randolph is
defendant on the part of the plaintiff
and herein you are in no wise to fail.

Witness, John Ruland , Clerk of our said Circuit court, with the
seal thereof hereto affixed, at office, in the City of St. Louis ,
this 29th day of December in
the year of our Lord, one thousand eighteen hundred and
forty one Jn. Ruland Clerk, C.C.

this on Columan Duncan
by the same to him and on james duncan by giving him a true copy of the
same, this day.
29 Dec. 1841

F.B.

for
C. Duncan

james Duncan

St. Louis Circuit Court .

Take Notice, That on the tweenteenth day of December in the
year of our Lord one thousand eight hundred and forty one, between the hours of
nine, in the forenoon and six in the afternoon, of that day, at
the officer of Louis in the City of
St. Louis, County of St. Louis and state of Missouri
depositions will be taken by the undersigned, to be read on the trail 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.

F.B. for
St. Louis Dec 14-1841 To the above named Defendant

Served the within notice in the county of it
St. Louis the 15th of Dec 1841 by leaving a time copy of it at the
of william with a
White member of his family over the age
of fifteen year

M Brotherton by Fee 50 cts

20th &
attorneys for daft that deposition was to be taken
this day before Louis on the same
day met Tiffany who asked me if I was
ready to take the deposition, I informed him
that James Duncan the witness had not yet
come over, that he lived and the
will said Tiffany I will agree that the deposition
may be taken on any other day, if he does not, come to day
provided you let me know when you want to take notice will said I let us reduce into writing no
it is not nicepay my word is good for it. and

Deposition of witness produce, sworn and
examined on the 29th day of December a.D.
eighteen hundred and forty one, by consent of
parties, at the office of justin witmore in
the city of St. Louis , the county of St. Louis
and state of missouri, between the hours
of nine in the fournoon and six in the
afternoon, before we alphonso witmore a justice
after peace within and for the county and
state aforesaid in a certain cause now
pending in the St. Louis Circuit Court of
St. Louis county and state of missouri, between
alsey (of color) plaintiff, and William
Rudolph defendant on the part of the plaintiff.

James Duncan , of lawful age being
and sworn and examined on the part of
the plaintiff and saithknew,
that he knows a coloured woman
whose name is Alsey who was in posession
of Robert was a
son-in-law of a logan county
an old man with that this woman lived with some five or six years at the
saline sick, gallantin county, Illinois
as a slave, and she, the said alsay, lived there
as a slave, by gift from the father in law of
the said , as this deponent understood -
the person here present is the
alsey, above mentioned The aforesaid
beacuse claimed the said alsey as his property at
the time and place aforesaid. The residence of
Mr.crops above mentioned was about one hundred and sixty or seventy miles from
the said
Mr.crops speak of the said alsay living with the
said about three years ago this for the defense objects
to the making any
statements as to the ( of .)
Deponent states that from the year 1818
to about 1825 the said alsey lived with the
in the state of Illinois
at the place aforesaid. Deponent states that
he understood from Mr.Crops that he had
given the said alsay to the said on certain conditioners, and from
that he had brought her
to Illinois from Kentucky (The statements
of Crops hered as above recited by
Deponent the Defendants counsel objects to.)

Deponent, being crossexamined by defendants counsel states, that he was at
in illinois the period above stated,
about once or twice a year, having servants hired to at the same time
who have since obtained their freedom
Deponent states that he has frequently sum
in St. Louis , since 1825, at different
times. Deponent further states that he has frequently
knowledge where alsey came from, to the
saline in illinois expect what crops and
had told him. Deponent knows. Robert
to his sorrow, and is sorry to know such
a man. Deponent states that he would give
a hundred dollars to see the said alsay get her
freedom.

Deponent states that he had been to say told that
Judge Robert Wash was defending this suit but
not until he was evening wite this office ;
and that he was to learn it, and
that he learned it from Mr.Mudroch the
plaintiff counsel never had any personal
differently with Judge Wash , and his only
fee proud from the judge having made
decisions against him which were neither
legal nor constituitional The deponent
further states that the reason why he said the
he would give a hundredd Dollars ti see the
said alsay get her freedom, was because
he, judge wash had given such decisions against
him, in cases of suits for freedom, brought by
his own servants. Deponent was not make
there statements because he would wish to wrong
Judge Wash , but very much dislikes the
man

James duncan

sworn and subscribed to before me and in my
on the day at the place and within
the hours in that behalf aforesaid

Justices of the peace

I, Alphonso, a justices of the peace
within and for the county of St. Louis and state
of missouri, so hereby certify that James
Dunccan, the Deponent resides in illinois
that he was by we sworn to
testify the whole truth of his knowledge
touching the matter in controversy aforesaid,
that he was examined, and his examined by to writing, and by him
subscribed in my presence in the say be
turn the hours and at the place in that
behalf aforesaid.

Justice of the peace

opend & Jan 5th 1841

Clerk

$ 1.89

County of St. Louis , ss.The State Of Missouri , To W.
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 fifth day of January
1842 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 Alsis, a woman of color is
plaintiff and N. S. Randolph is
defendant on the part of the plaintiff
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 3rd day of January in
the year of our Lord one thousand eight hundred and
forty-two
Jn. Ruland Clerk, C.C.

For G. M. West

To appear5 Jany 1842
Executed

M. Brotherton
plff Fee, 50

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

We command you to attach James Duncan
by his body and him safely keep, so that you have his body
before the Judge of our Circuit Court , now in session at the City of St. Louis , within and for
the County of St. Louis , on the 6th day of January 1842 then
and there to testify and the truth to say in a certain matter of controversy, now pending in
our said Circuit Court , between
Alsy of color
plaintiff, and William S. Randolph defendant wherein
the said James Duncan has heretofore been summoned
on the part of the said
plaintiff

Witness, John Ruland , Clerk of our said Circuit
Court , at the City of St. Louis , this 6th day of
January in the year of our Lord one thousand
eight hundred and forty two
Jn. Ruland Clerk, C.C.

attachment

for James Duncan Executed M. Brotherton

Fee 1.00

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

We command you to attach James Duncan & George W . West
by thin bod is and them safely keep, so that you have thin bod is
before the Judge of our Circuit Court , now in session at the City of St. Louis , within and for
the County of St. Louis ,for forthwith16 January, 1842 then
and there to testify and the truth to say in a certain matter of controversy, now pending in
our said Circuit Court , between Alsay (of color) is
plaintiff, and William J. Randolph is defendant wherein
the said James Duncan & george W. West have heretofore been summoned
on the part of the said plaintiff

Witness, John Ruland , Clerk of our said Circuit
Court , at the City of St. Louis , this 6th day of
January in the year of our Lord one thousand
eight hundred and forty two
Jn. Ruland Clerk, C.C.

Attachment

for x James Duncan
x George W . Executed M. Brotherton
plff
fee 2.00

County of St. Louis , ss.
The State Of Missouri , To B Uzzle and
Greeting:

You are hereby commanded, that setting aside all manner of excuse and delay, you appear
before the Judge of our Circuit Court , on monday the10th day of
January 1842 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 Alsey, a woman of color is
plaintiff and William S . Randolph is
defendant on the part of plaintiff
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 7th day of January in
the year of our Lord one thousand eight hundred and
forty-two
Jn. Ruland Clerk, C.C.

plff

for B
appear on
executed M. Brotherton
plff
Fee 62

St. Louis Circuit Court .

Take notice, that on the first day of March in the
year of our Lord one thousand eight hundred and forty two between the hours of
eight in the forenoon, and six in the afternoon of that day, at
the office of Samual , in the town of
of state of illinois
depositions will be taken by the undersigned, to be read on the trial of the above entitled case,
on behalf of the defendant; 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.

11 February 1842
& To the above-named plaintiff

12

served the within notice by delivering a true copy
thereof to Alsay the within named plaintiff, on
the 12th day of February 1842, in the County of
St. Louis -

Warshall Brotherton Sheriff By
Joseph service 50 cts

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

Know Ye, that we, in conidence of your prudence and fidelity, do by these presents authorize
you to cause to come before you, to be examined as witnesses in a cause depending in
our Circuit Court for the County of St. Louis , in the State of Missouri , wherein alsey
is plaintiff and William S. Randolph is
defendant all
and every such person, and at such time and place, as shall be named to you for that purpose by
the said defendant his
Attorney or Agent. And we command you to examine all and every such person upon his oath
or solemn affirmation first made or taken before you, to testify the whole truth touching his
knowledge of any thing relating to the said matter in controversy between the said parties;
and that you do take such his examination and reduce the same into writing. When you shall
have so taken his examination, you are to cause the witness to sign the same, and to that and
each examination, at the foot thereof, you are to append your certificate, setting forth the facts
that the examination was subscribed and sworn to or affirmed by the witness, and the day, as
well as between what hours of the day, on which it was done, as also the place of residence of
the witness, if known to you. Should any paper or exhibit be produced or proven, or be referred
to by the witness, you are to describe the same in his examination, or cause it to be so marked
by him, as to establish its identity, and attach the same to his examination. The examinations
thus taken you will cause to be accompanied by a certificate of your official character, attested
by the seal of State; or should it be more convenient, such authentication and proof of your oficial
character may be made by the certificate and seal of the clerk of any court of record of any
county of the State, District or Territory in which you reside, stating also in addition to the facts
of his being clerk and that the Court is one of record, that at the time when the depositions
were taken you were an acting judge, (or other such officer to whom this commission is addressed,)
and duly commissioned as such. And you will return the same and all exhibits produced to
you, annexed hereto, carefully closed up and under your seal, directed to the clerk of the Circuit
Court in and for the County of St. Louis , Missouri , with the names of the said parties litigant
endorsed thereon, with all convenient speed.

Witness, John Ruland , Clerk of our said Circuit Court ,
at the City of St. Louis , this eleventh day of
February in the year of our Lord one thou-eight
hundred and forty two
Jn. Ruland Clerk C.C.

Depositions of produced sworn and examined
at the office of said in the town of vrina county
of of before acting
of the in and for said county is a cause
now pending in the St. Louis Circuit Court State of Missouri
between Alsey plintiff and William & Randolph defandant
on the part of the Defandant

John who being of lawful age produced
sworn and examined part of the defandant
deposit and saith that several years since I was
living in county state of kentucky and had
living on staying at my a negro girl named Alsey
belonging to of lagan County Kentucky
and an a certain time to
my house and said he had cause for the girl Alsey
and as he was a relation of crop I at the time
that he had authority and did not privent his taking her
which he did I soon heard that the negro had been
taken off and that crop was very much distressed
at the circumstance at the time of take of
the negro was going to Buller county when he had been
living as he told me in the state of kentucky. After crop
found whom his negro was cross sent after her to and I found her at the U S and I was inormed
that had sold or mortgaged the negro to I
grand and I did not get her I informed crop he came
to my house and I went with him in search of the negro
she had been never by Grand back to kentucky where we
found her at William campbell's in County
in the state of kentucky and crop in to take him
by form and campbell presented arms and we had to
leave crop in Circuit
Court and after some time he law and I was sent by crop to Illinois for the negro whom she had been nun by campbell and with intention to run off the negro at her as Campbell told himself and mark
of her Crop took counsel learnd that campbell was
instalmentand that the lap of all the negroes & cast
would be the result if campbell run there off crop
there calcuted to compromise and gave up part (as
the negro had same childrens for the ballance which was given
up to me at Shawmutaun Illinois and I took them
how to there master in lagan Ky to whom she
belonged as bonafide property from what I heard I believe
that crap did not give leave for the negro to be taken
from my house at first and further the deponant
saith not

John Johnston

I Reynolds an acting justice of the peace in and
for the county of Johnson and State of Illinois do
certify that John Johnstan the deponent whare pleace
of residence is in the county of Johnson State of Illinois was
by me swom to testify the truth of his knowledge
touching the matter in controversey in the
aforesaid that deponent was examined and his examination
reduced to writing and subscribed by said deponant in my
presence on the first day of March in the year
Eighteen Hundred and forty two between the hours of
eight in the forenoon and six of the afternoon at the
office of Samuel capeland Esqr in the town of
Vienna in the county of Johnsan and State of Illinois
given and certified the 1st day of March 1842.

Reynolds

I Reynolds an acting Justice of the peace within and
for the county of Johnson and State of Illinois do
as certify that in persuance of the within or annexed
commission and notice came before me at the office of
Samuel Capeland in the town of Vienna in the county
of Johnson state of Illinois John Johnstan
who was thier by swon and examined and such
examination reduced to writing and subscribed by him
in my presence and his said depositions are now
herewith returned given at Vienna in the County of Johnson
State of Illinois this 1st day of March 1842.

Reynolds

State of Illinois
County of Johnson

I samuel Capepland
Clerk of the County
Court in and for Johnson
in the State aforesaid a hereby certify that
Reynolds before whom the foregoing
deposition & proceedings him had
was at that time the time of taking the
same and is now an acting Justice of
to peace for said County & State aforesaid
duly commissioned & qualified as the law
in such cases particularly
& as such full faith and credit are
due & of right showed be given his
official acts as such

In testimony whereof I
subscribe my name &
the seal of said Court,
at Vienna the seat of justice
for said county &
in this 1st day of March 1842 Samuel Clerk by

Opened & filed April
11th 1842

. Ruland Clerk

for

In the Circuit Court , for the County
of St. Louis State of Missouri .

To above Plaintiff

You are hereby, Noticed, That Depositions of Witnesses to be read in evidence
in the above cause, on the part of the Defendant will be taken at
the office of John Elder Esq
in the County of Edwards and State of Illinois on the Eighteenth
day of Marchinstant between the hours of 8 o'clock
in the forenoon, and 6 o'clock in the afternoon: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, till completed.

St. Louis March 4th 1842.
.

Alsey lives with

B..-

Served this notice on the 4th day of March 1842, in the
County of St. Louis , by leaving a true copy thereof, at
the usual pleace of abode of Alsey, the within named
plaintiff, with a white person of the family over
the age of fifteen years.

Marshall Brotherton Sheriff By Joseph Clury service 50 cents

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

Know Ye, that we, in confidence of your prudence and fidelity, do by these presents authorize
you to cause to come before you, to be examined as witnesses in a cause depending in
our Circuit Court for the County of St. Louis in the State of Missouri , wherein
Alsey is plaintiff and William S . Randolph
is defendant all
and every such person, and at such time and place, as shall be named to you for that purpose by
the said William S . Randolph his
Attorney or Agent. And we command you to examine all every such person upon his oath
or solemn affirmation first made or taken before you, to testify the whole truth touching his
knowledge of any thing relating to the said matter in controversy between the said parties;
and that you do take such his examination and reduce the same into writing. When you shall
have so taken his examination, you are to cause the witness to sign the same, and to that and
each examination, at the foot thereof, you are to append your certificate, setting forth the facts
that the examination was subscribed and sworn to or affirmed by the witness, and the day, as
well as between what hours of the day, on which it was done, as also the place of residence of
the witness, if known to you. Should andy paper or exhibit be produced or provem, or be referred
to by the witness, you are to describe the same in his examination, or cause it to be so marked
by him, as to establish its identity, and attch the same to his examination. The examinations
thus taken you will cause to be accompanied by a certificate of your official character, attested
by the seal of State; or should it be more convenient, such authentication and proof of your official
character may be made by the certificate and seal of the clerk of any court of record of any
county of the State, District or Territory in which you reside, stating also in addition to the facts
of his being clerk and that the Court is one of record, that at the time when the depositions
were taken you were an acting judge, (or other such officer to whom this commission is addressed,)
and duly commissioned as such. And you will return the same and all exhibits produced to
you, annexed hereto, carefully closed up and under your seal, directed to the clerk of the Circuit
Court in and for the County of St. Louis , Missouri , with the names of the said parties litigant
endorsed thereon, 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 two.
Jn.Ruland Clerk C.C.

Depositions of witness produced whom and examined at the
office of John Elder in the County of Edwards State of Illinois
before me John Elder an acting justice of the peace in
and for the County of Edwards and State of Illinois in
a cause now pending in the St. Louis Circuit Court State
of Missouri where in Alsey in plaintiff and William
S Randolph defendant on the part of the defendant
Racheal Donald being of lawful age produced
sworn and examined on the part of the defendant
deposith and saith- That she is the wife of
Robert was till his death that when
we lived in Kentucky County we had a negro girl
named Alsey borrowed of my father
of County under was preparing
to move to Illinois and I of my authority
sent the girl Alsey to my father he being poor
not having any female servant but her- We moved to Illinois and under returned to Kentucky
and brought the said girl Alsey to the where
we kept her sometime. When are
took an of her by same means and I forbid
him to touch or remove her as she did not belong to
by any grant purchase or otherwise
that ever came to my knowledge to guard took her
off (to Kentucky as I heard) my father sent to the salaries
for the by an uncle but he was prevented
from taking her by guard claim and he want
away my father had a law sent about the negro in
Kentucky as I heard and guard her as I have seen her
several times in my fathers family frequently
since and further the deponant not

Donald

I John Elder an acting justice of the peace within
the county of Edwards and State of Illinois do hereby certify
that racheal Mc Donald the deponant where place of
is in the County of Edwards State of Illinois
was by me sworn to testify the whole truth of her knowledge
touching the matter in controversy in the aforesaid that
deponant was examined and her examination reduced to writing and subscribed by said deponant in my pursance
on the Eighteenth day of March Eighteen hundred
and forty two between the hours of 8 o colok in the forenoon
and six of the afternoon at the office of John Elder
in the County of Edwards and State of Illinois
given and certified the eighteenth of March 1842.

John Elder

E.C.Reeves of lawful age being produced swon and examined
on the part of the defendant deposith and saith same
years since perhaps 1818 or 1819 my father crop living in logan County
Kentucky had a negro girl named Alsey who was
to my sister wife of Robert then living
in butler County Kentucky was preparing
to move to Illinois - The girl came home
said sister had sent her after she came home
my father let the girl go to an unchs in to see her mother who was living with
while she was from my came
to my fathers and said his wife wanted the girl Alsey
my father was from harm my mother told that the negro was hers and he could not
get her and he left and the next we heard the girl
had been taken by to Illinois my Father
sent as I heard to Illinois for the firl & did not
get her my Father went himself and did get her
the girl had been run to Kentucky
my Father had a law sent about the negro and
he her to Logan in the spring
of 1824 I think he kept her in Kentucky till
the face of 1829 then moved to St. Louis
& kept till 1834 selling her to a of
north St. Louis as I understood being in Illinois
at that time my self and further the deponant
saith not

Edra C Reeves

I John Elder an acting Justice of th peace in and for
the County of Edward and State of Illinois do hereby
that C where place of residence is

in the County of white State of Illinois was by
sworn to testify the whole truth of her knowledge
touching the matter in controversy in the cause aforesaid
that deponent was examined and her examination
reduced to writing and subscribed by said deponant
in my presence on the Eighteenth day of March in
the year Eighteen Hundred and forty two
hours of 8 o clock in the forenoon and six o clock
in the afternoon at the office of John Elder in
the County of Edwards and State of Illinois
given and certified the Eighteenth day of March 1842

John Elder .

I John Elder an acting justice of the peace in
and for the County of Edwards and State of Illinois
on certify that in persuance of the wether commission
and notice came before me at my office
in the County and State last aforesaid Racheal Donald and Edra C Reeves who were these
by sworn and examined and such examinations
reduced to writing and subscribed by these respectively
in my presence and their said depositions
are now herewith returned

Giving at my office in the County of Edward
and State of Illinois this Eighteenth day of March 1842

John Elder .

State of Illinois
Edwards County Ss.

I Walter L Clerk of the
County commissions court in and
for said Edwards County hereby certify that John Elder
where signature appears to the foregoing certificates now is
and was at the time of signing the same an acting
Justice of the peace in and for said County duly
commissioned and qualified and as such false for the &
Credit is and of right ought to be given to all his official
acts

Given under my hand and seal of
Office at the 18th day March A.D. 1842
L Clerk
C.C.C.&C.

Opened Filed April 11th
1842 Jn Ruland Clerk

for

Opened & filed Decr 7th 1842.
Jn Ruland Clerk

Depositions

costs of deps 5.00 to Justicewitnesses1.50Postage 1.007.590.508.00

Postage 1.00
murdoch

St. Louis Circuit Court

Take notice, that on the eighth day of November
in the year of one Lord one thousand eight hundred and
forty two, between the hours of nine in the forenoon
and five in the afternoon, of that day, at the office
of Henry Eddy. in County of
Gallatin and State of Illinois depositing will be
taken by the undersigned, to he read in evidence on the
trial of the above untilled case, on the part 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.

F.B . Murdoch for

To above named
or his attorney
St.Louis October 10. 1842

Same to the . Randolph a true copy of the above notice at St. Louis
the 14 October 1842.

F.B.Mudroch

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

Know Ye, that we, in conidence of your prudence and fidelity, do by these presents authorize
you to cause to come before you, to be examined as witnesses in a cause depending in
our Circuit Court for the County of St. Louis , in the State of Missouri , wherein Alsey
(of color) is plaintiff and William S. Randolph is
defendant all
and every such person, and at such time and place, as shall be named to you for that purpose by
the said Alsay or her
Attorney or Agent. And we command you to examine all and every such person upon his oath
or solemn affirmation first made or taken before you, to testify the whole truth touching his
knowledge of any thing relating to the said matter in controversy between the said parties;
and that you do take such his examination and reduce the same into writing. When you shall
have so taken his examination, you are to cause the witness to sign the same, and to that and
each examination, at the foot thereof, you are to append your certiicate, setting forth the facts
that the examination was subscribed and sworn to or affirmed by the witness, and the day, as
well as between what hours of the day, on which it was done, as also the place of residence of
the witness, if known to you. Should any paper or exhibit be produced or proven, or be referred
to by the witness, you are to describe the same in his examination, or cause it to be so marked
by him, as to establish its identity, and attach the same to his examination. The examinations
thus taken you will cause to be accompanied by a certificate of your official character, attested
by the seal of State; or should it be more convenient, such authentication and proof of your official
character may be made by the certificate and seal of the clerk of any court of record of any
county of the State, District or Territory in which you reside, stating also in addition to the facts
of his being clerk and that the Court is one of record, that at the time when the depositions
were taken you were an acting judge, (or other such officer to whom this commission is addressed,)
and duly commissioned as such. And you will return the same and all exhibits produced to
you, annexed hereto, carefully closed up and under your seal, directed to the clerk of the Circuit
Court in and for the County of St. Louis , Missouri , with the names of the said parties litigant
endorsed thereon, with all convenient speed.

Witness, John Ruland , Clerk of our said Circuit Court ,
at the City of St. Louis , this tenth day of
October in the year of our Lord one thou-eight
hundred and forty two
Jn. Ruland Clerk C.C.

The depositions of Daniel Wood
and -
taken between
the hours of nine o' clock and five
before James an acting justice
of the peace in and for the County of Gallatin
in the state of Illinois at the office of
in , in said County
on theeight day of november one thousand
eight hundred and forty two in persuance
of the within commission of notice
to be read in in a certain suit
at law in the St Louis Circuit Court now pending and undetermined wherein alsay
(of color) is plaintiff & William Randolph
is defandant.

Daniel Woods - a witness on the part
of plaintiff being first to testify
the whole truth truth touching his knowledge
of any thing relating to the matter in controversy
between the said Alsay of the & William Randolph in to the several
interrogatives of plaintiff -

Do you know the
to this suit?

answer I not said Randolph ,
I new a negro named
that was in the position of Robert
in the year 1819 on 2nd - To whom did the said Elsay ?
and
the
woman Alsey.

how? long did Alsay live in gallantin County
I do not know how long the woman
I come in the fall
of 1819for she lived two years afterwards

Int 4th means of knowing the length
of residence of and also as to whom she belonged
answer I recorded in the family of a two years and saw him
the said Alsey
and he said he got him by his wife, the
to to his wife then in
the of

Int 5th Did the father of
the family of was
living in gallantin County - - him
often to your knowledge,

I never saw of his being
but one whist Alsey was them

Int 6th what was the name of
father and did you ever have
with him respecting Alsey?

his name was
I never had any conversation with
of they them
he
by the at the same term and
place land by the deponant.

7th was then a mother claimant
to the said be sids
if state all a it

excepts to

claimed the
by bill of and and place do
here in the of William and
for and

plff exepts

of did say at any time
that he had no wrought to the said negro
Alsey

brass sad for the
in Kentucky said that
would gain the negro for she longed to

plff excepts

how long was the negro Alsey he

I do know but I think they
will not in this county a great while he
came

4th how long did
and what circumstances
attendid her in relation to the said negro

answer I do not think that he slaid them
move than a day or two I think that Crops
come dawn the same thing a about the negro
these the grasses was not sold ,
as he had let
the negro Alsey but he had not said over any, night
of her

5th at the some time you heard he and
say than he got the negro
Alsey from and Crop did not also
under stand that he got and mentioned
of her with out the on
consent of crops

answer I under stood from some of the
family about the that he had brought
Alsey off with and consent but
not from him

state of Illinois County

I James M Jones an acting justice of the peace
and for said county of gallatin do certify
that the foregoing deposition of Daniel Wood
who resides in said county was duly
taken by me at the office of Henry
in town in said County in of the on the
eighth day of november with of our one thousand eight hundred and
fourty two between the hours of nine o clock
and five the said Daniel has been first duly to testify the whole
truth touching his knowledge of any
thing in relation to the matter in controversy
and now pending in the St. Louis vincent
court wherein alsey (of color) is plaintiff
and William S Randolph is
defendant and that the same was
subscribed by the said Daniel Wood
at the said time and place which certify under my hand this eight day
of november AD 1842

James

This said examination of witnesses being
continued till the 9th day of November, 1842
at which time the examination was resumed
at the office of said Eddy in
between the hours of 9 o'clock a.m. and
5 o'clock p.m.- and Timothy general
appeared as a witness who being first duly
sworn to testify the whole truth touching his
knowledge of any thing in relation to the
matter in controversy, between the said Alsey
and the said William . S. Randolph , in the St .
Louis Circuit Court , now pending & undertermened,
and answered interrogatories as
follows:-

1.By the plaintiff. Were you acquaionted
with Alsey, a negro woman, plff in this suit
and with the said william S.Randolph , the St.Louis circuit!
and if how long, and under what circumstances ?

Answer - I do not know the Defendant
Randolph at all I know a black
woman called Alsey belonging to the Robert
sometime in eighteen hundred
and twenty three where I bought how from
. with other property
to pay a certain debt due from
said and held her in my
pasesion for two or three months in
I there her to
in Kentucky where suit was brought
by craps a me for
her paid the negro woman Alsey was
recovered by judgement an the 8th March
1824.

2. question by the plaintiff- How long had Robert R., lived on resided in the for works near
when you purchased Alsey fron him?

Answer- Four or five years

3 question by Plaintiff. Do you know that
the said Alsey was ever removed out
of said trial, from the time that said
first brought her into said
, until you sent her to ? -

Answer I did not

4th question by plff. How long did said
negro woman Alsey reside in
after she came into your
and who with?

Answer- between two or three
months and resided with John
a of said Town.

5th question by the plaintiff is
or was it then, within the fact reserved
for salt works, near town?-

Answer it is not now matter
was it then

Crop Intrrogation is by the deft and answers by the
deponant

Do you know of any actual true for sale or gift
of the said Negro Alsey to the said
by Crop ?

Answer I do not

2nd- Do you know that the said Negro Alsey
bird with during the time your stay
he in the ?

Answer I do not know how long she
lined with him

3rd Do you know where or
brought said Negro into the Reson

Answer I do not

Interrog 47th was the said Negro transfered to and
held by you as a ?

answer she was

Timothy

State of Illinois county sct

I James an acting
justices of the peace in and for said County of
Gallatin do certify that the of
Timothy guard who resides in said County of
was duly taken by me at the office
of Henry in in
said county in pursuance of the did
the ninth on the month day of november
in the year of our sad one thousand eight
hundred and forty two (the examination of
witness from the any with
day of november 1842 ) between the hours of
nine o clock sell and five the
said timothy guard having her first duly signed
to testify the whole truth touching has knowledge
of any thing in relation to the matter
in and now pending in the
Circuit Court where in alsey (of color) plantiff
and William S Randolph defendant
and that the same was by
the said Timothy guard at the mid time
and place which I certify under my hand
this ninth day of november

James

Also the of john how
taken at the same time and place
the said 9th day of November 1842. The
said witness being of lawful of first duly sworn
is follows.

question by plaintiff Did you know alsey
a negro woman, brought into this state and
into to the had reserved for the salt works
near town, by Robert
did you know
her, and how long was she residing
with said within said

Answer I knew her, from the
year 1819 till 1823 or 24 I saw her
off tour, clearing the above time in
the of said
and of she was ever about the
state, that time I do
not know it.

2. question by plff What was
your employment that
time, and your means of knowledge

Answer I was loving at the
half moon during that time, where all the salt with and employed
in drawing water said
was a salt maker & got his water
from the half moon walls, and I was
after there at and
knew the said negro woman will
and the family of will.

3d Question by Plff.what is the
of within the that
by the constitution of Illinois for the said at
the was it than?

Answer It is not was not
at the time I refer to

In time by the deft and answers by
the deponent.

Interrogatory Do you know whether
the Mayor Alsey belong to
?

answer I heard wife say
the negro woman Alsey herewith was here
Fathers (3 ) negro
It was also commonly under that
she was negro

plff excepts

- During the time Alsey was with
was she with in the and was she held as a slave?

Answer - She was with in
and was held as a slave

Cross interrogatory by plaintif

How do you know she was held as
a slave?

answer she was held as a ,
and I heard
say she was her, slave

John

State of Illinois

I an acting justice of the peace
said county of gallatin do certify that the foregoing
disposition of johngreensboro
resides in in mid County of Gallatin was duly taken
by me between the of nineo' clock
and P U at the office of Henry Eddy
in and county in in
of the & noice, on the ninth
day of November in the year of our still the one thousand eight hundred and
forty two - the examination of witnesses having
the is eight day of November
1842 - the said john been sworn to the where
of any thing in relation to the
matter in controversy and now pending in the
St. Louis wherein alsey (of color)
is plaintiff and william Randolph is defandant
and that the mid examination was
subscribed by the
time and place - which
had this ninth day of november AD 1842

James, , Louis

State of County

I white Clerk of the
in and for
said of do certify that
James was an acting of
the in and
and , on the by and
ninth days of November 1842 and that as full is due his
acts at the time of the
and I further certify that the county
which I am Clerk
a of

In of
which I have
name and
the send of
this
15th day of November 1842 White

for
and taking
$5-00

County of St. Louis , ss.The State Of Missouri ,To Randolph (of the firm of Randolph & )
. , on
main blow market
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 12th day of September
1843 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 Alsey (of color) is
plaintiff and William J. Randolph is
defendant on the part of the plaintiff
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 9th day of september
in the year of our Lord one thousand eight hundred and
forty-three.
Jn. Ruland Clerk C.C.

Executed the 12th September
1843 in george M Walsh and Robert
not found
in my County

fees$1.00.12$1.12

for, Randolph
of the first of

and for

appear on 12 september 1843

Now at this day serves the said defendant
by his attorney and files his mother for a
new trial for the following reasons

1.That the verdict is against law

2.That the verdict is against evidance

3.That the verdict is against the weight of evidance

4.That the verdict is against both law evidence

5.That the Court erred in the instruction
given by the court to the jury

Alsey
W S Randolph

for new
trial

for

September 14 1843

Clerk

St. Louis Circuit Court

Be it me
that on the of this
case the plaintiff counsel read
evidence the following deposition
(insert them) the plaintiff
proved that before and at the
commencement at of this suit, the
defendant held claimed and used her as
a slave : that she was the her
by james Duncan in his depostition

The defered out the read in evidence
the following despoitions,
(here insuit the defendants, depositions)

No other evidence was given in
case case The plaintiff counsel
then asked and the count gave
the following instructions (have insuit it).
The court there of its
own motion gave the following
instruction (here )
having given a The plaintiff, the defendant within
form days moved the court to
aside the same aside and grant a new
trial for the following reasons these
filed in writing (have insert
the motion & reason for a new trial) which motion the court , to
of the court
said motion the defendant by his
counsel execpted & prays the court
to sign & seal. This his of execptions
which is done accordingly

Judge 8th .
of

St Louis Circuit Courts

Bill of exceptions

Filed nov 1 1843
Ruland clk

Supreme Court of Missouri July Term 1844

error to St. Louis Circuit Court

Now as this day come a given
the parties aforesaid, by their respective attorneys, and
the Court here being now suffeciently adviced of and
concerning the premises, do consider and adjudge, that
the judgment aforesaid in found aforesaid by the said
Circuit Court rendered be and in all things affirmed
and Stat in free force, and that the said apperence
cover against the said appellant, her casts and changes
by her expended herein, and have thereof execution.

State of Missouri Sct.

I, Hampton L. Clerk
of the Supreme Court of the State of Missouri , do certify
that the above and forgoing judgment, rendered as the
July term of said Court (1844) in the case of William S.Randolph aganist Alsey (of color), is correctly copied
from the records of said Court remaining in my
Office

given under my hand with the seal of said Court affired, as Office in the
City of jefferson, this Sixth day of
January eighteen hundred and forty five.
H.L.

305 March term 1841

St. Louis

recieved and filed 3rd February 1845
John Ruland Clerk

That if the plaintiff establishes the part
by proof that she was held to services and color
in the state of illinois she is entitled to freedom
unless the defendant shows a contract of living of
the plantiff from year to year the within the for salt
town in Illinois as is provided by the 2 section
of constitution of he

That by the ordinance by 13 july 1787. slavery was
prohibed the throughout the territory North west of the
this were and that by the constitution of the
state of illinois is also throughtout that
state.

That the burden of proof his on the plaintiff
in this case to make out her right to freedom

This was given

Instructions

1.If the jury beliving from the evidance that the
plaintiff was held to services and color in the
state of illinois by with the knowledge
and constant of crop that she is entilled to freedom.

That the Holding slave to survive
a labor within the last reserved for salt works
under a contract of
him the slave to freedom

Randolph

1st Prove the residence of the plff in Illinois
Depositions- and of plaintiff.

2nd Prove, the of by by or

3 show the adoption of the ordinance of 1787. . 1. 475 article 6. U.S.13 July 1787

4 show the adoption of the by after the
constitution of the u.s. was joined 2 laws u.s.

5 Show the out of , establishing Illinois territory3 July 1809, and recognising the ordinance
of 1787. Laws u.s. pay 198 . 4-

6. Show the constitution Stat of Illinois . article 6
page 43- in 26 aug 1818.

7. Show the out of admitting Illinois into
the union 3 1818. 6 vol.L.u.s.442
suit. Read in argument .
3 page 194. p.27a. 3 .
constructions.

prove plff in Illinois and
ther show evidence as above.
and read cases 1 P.725, & 472.

2. That the jury may rightfully infer such know.
ladge and constult from the circumstances of the case.

3. That if the plaintiff was taken to Illinois by
without the knowledge or consent of
Crop and them held to taken as aforesaid she would nevertheless be entilled to
freedom unless, Crop upon finding out that she
was in Illinois in the custody of .
used due diligence in recovering her by of law or otherwise

4. That if the jury believe that Crop knew of
plaintiff residence in Illinois , and yet
did not use proper deligence to recover her
, they may property infer that
she remained there with the consent of crop.

refused instruction

That the fact of these slave
beings written the reserved for the
salts works near is matter
for the jury, to be proved like any
other fact.

Instruction by the Court.

If the jury fired from the evidence
that persons other than crop held
plff in servitude in Illinois & that
crop delayed to prove
a recovery of her, they are
to take that circumstance as
well as any other circumstances
that the evidence may
develop- and give them is they think they
deserve, and if the jury shall
find therefroms that crops
affected to the plaintiff, being
held to servitude in Illinios,
is certified to her hreedom

Given on last

That the burden of of his an the plaintiff
in the case to not her right to freedom

That in their case, the plaintiff, in order
to get free hs to prove not only a residence
written the court year
but that such was in
of the constitution of Illinois .

That a residence of a slave within the reserved
for with works near from 1818 to 1826.
by the consent of doesnot of
cause, set the slave free.

That the circumstances qualifying such
residence as above stated, so as to make
it work the freedom of the slave
are by law to be proved by the plaintiff.

Instruction given
by
asked by defendant
not to given

We the jury fever for the
Defendant.

J.S.Sain
Foreman

We the jury find the defendant
guilty of the trespass and false imprisonment,
& form as the said plaintiff has alleged
against him

Verdict

3. If the jury belive from the evedivence that defendant
was aware of the plaintiff & hired him for a
year to a which he the defendant
was a member, and that said plaintiff was sent
to the State of Illinois by a member of that given
to do work there remained there to do it,
he was they , & remained without
the knowledge, consent or of the said
defendant, they are bound to find for the defendant.

Refused
(on first trial)
Jan 16/44.