petition to sue for
freedom
and order of

In the Hon. Bryan Judge of
the St. Louis Circuit Court

The Petition of , a woman of color
respectfully represented that she is now claimed
by C. as a slave - that she is now
over twenty one years of age and is about fifty five
years - old - that she is the child born of Pegg. - that
said Pegg her mother was formerly a slave of belonging
to one Richard Dollars of County in
the state of Maryland - That said Richard
by deed bearing date the twenty seventh day of February
in the year seventeen hundredand eighty seven
duly executed, acknowledged and recorded according
to the laws of Maryland , did
and set free the said Pegg, the of your
petitioner at the expiration of six years from the
date of said deed - and did also
of said deed and free from slavery all the
children born of said Pegg “where they should
arrive at the age of twentyone a of which
said deed with to exhibitedthatthe the petitioner has resided in the
City and of St. Louis and that of
further thelastten years - that she believes she
is entitled to her freedom upon the grounds above
stated - and therefore prays for leave and for and
order to he made your hour to sue as a
poor person in order to establish her right
her freedom. That Counsel may be
assigned to her, and that she may have reasonable
liberty to attend her counsel and the may require, that she he not
removed out of of the jurisdiction of this
coun, and she be not subjected to
any severity in account of her application for freedom.

her x

State of Missouri
County of St. Louis ss

I, Bryan , judge
of the St. Louis Circuit Court being satisfied
that the within petition of contains
sufficient matter to authorise the commencement
of a suit as therein for do hereby order
that , the within named petitioner
be allowed to sue as a poor person to establish her
right to freedom - and do assign when for
counsel H R. Gamble & Joseph B. Walker -
and I do hereby further and - that the said
petitioner have reasonable liberty to attend her
counsel and the Court as occassion may require
that the he not removed but of the jurisdiction
of the Court and that tthe he not subject to
any severity an account of her application
for freedom.

of the 8th judge of the State of
Missouri
5

State of Missouri
County of St. Louis ssIn the St. Louis Circuit
Court
July Term 1842

a person of color, by her
attorneys and by leave of the court according
to the statue in such case made and provided
of clames of plea of trespass for
false For that whereas the said
defendant he dofor to wit on the first day
of march in the year eighteen hundred and
forty two, with force and arms of the county
aforesid, made an assault upon the said
plaintiff and then and there and
treated the said plaintiff and then and
there imprisoned the said plaintiff and kept
and detained the said plaintiff imprison
from that terms till the present against
the will of and plaintiff and kept
plaintiff there and there .did law and against the peace
of the state and the said plaintiff overs
that before and at the time of the
the grievances aforesaid she was
and still is a free person and that the
said dependant held and still holds
her in slavery wherefore the said plaintiff
says that she has been greatly
and both subscribed damage in the
of five hundred dollars and therefore she
brings her suit

Gamble x
for

James O is and non
this Day by his and the force
says that he is not guilty of said supposed trespass
or any or of them inmanner from
as plaintiff alon thereof complained
against him of this he himself upon the county

P.D

No 112
St. Louis Circuit Court
July Term 1842

in trespass false imprisonment
and suit for freedom
$ 500
filed by consent

Gamble D Walker
jimmy jackson depositions for plaintiff
James O Fraser
filed July 29th 1842
Jn Ruland Clerk

To the Honorable the Judge

Deposition for plaintiff
James

Opend april 1.
1843
Ruland Clerk

Return of to take testimony prove
Maryland

To the
Clerk of the Circuit Court of the County
of St. Louis Missouri

St. Louis

St.Louis Circuit Court .

Take notice, that on the tenth day of October in the
year of our Lord one thousand eight hundred and forty two between the hours of eight o'clock in the forenoon, and eight in the afternoon of that day, at the house of John Dallam in the town of
in the County of Harford and State of Maryland
depostions 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 depostions, if not completed
on that day, will be continued from day to day, at the same place, and between the same
hours, until completed.

gamble x Walter
for
To the above.named Defendant St.Louis august 10th 1842

I acknowledge service of a copy
of the within notice made
me this tenth day of august a.d. 1842

J..

Notice

County Of St. Louis , Ss.The State Of Missouri ,To any Judge, Justice of the Peace, or other Jucicial Officer of the State of
Maryland
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
Jinney
Jackson (a woman of collor) is
plaintiff and James O. 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 plaintiff Clinney her
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 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 , thiseleventh day of August in the year of our Lord one thousand eight hundred and forty two. Jn.Ruland Clerk C.C.

The of then commission
will appear by a salve hereto
annexed

A.L.

Commission
to the State of Maryland

To the Honarable the Judges of the Circuit Court of the County
of St. Louis in the State of Missouri

The undersigned one on the Justice of the peace of
the State of Maryland in refer county, respectivelly returns
by virtue of the Commission hereunto issued out of the
said Circuit Court in a cause therein pending in which jinney
Jackson is Plaintiff & James O Fraser is Defendant and in pursuance
of the notice accompanying said commission, which is also
to annexed, he did on the tenth day of October in the year
1842 between the hours of Eight in the forenoon & 8 o'clock in the
afternoon, attend at Michaelsville in said County of Harford. being
the time & place mentioned in said notice, and then & there look the

of John . the person also mentioned
in our notice in relation to the cause aforesaid, having first
can oath with said John upon of almighty that the evidence which he should
“give touching his knowledge or rememberanced in relation other
“matter of controversey between Negro Jinney Jackson Plaintiff
"and James O . Fraser Defendant, in the Circuit Court
"of the County of St.Louis in the State of Missouri should be the
“truth the whole truth & nothing been the truth so help him
“God” Which said Depositions in as follows suit -

I John I. Commonly called John Dallow
of Maryland , do depose, that James the son of
Richard Dallam late of said , that James now
in my severity second year of age, being severity two in january
next- that my mind & memory, I belived are
last my eyesight very defection so much so as
incapable of either reading or writing (the paper here unto annexed
professing she a copy of a duo of from Dalland
. negro & other negroes bearning date the 26th Feby 1787 &
“copy of Deed of from Richd Dalland
to sunday Negroes. Exhibit A” was here filed oas a part of the testimony
in the case read to witness by your commissions) “that my fathr
the said Richard ar the time said deed of bears
date owned & the several negroes therein named, and have always understood & beleived that he set said negroes
together with others free. That my father the said
Richard was or the date ofsaid to wit in
February 1787 in good health) this mind sound
paired, for same time between the your mentioned in said deed by the name of Pegg. I have a distinct recollection
of she lived with me on a form called the Mile Squar
in this County in the year 1791 there had two children, one
of whom was named Jin or Jinney and was were about two or three
years of age. That Pegg was then in good health & some where
about my age. That negro Jimmey lived with my father
from 1791 until the year 1807 when she went live
with my brother Richard in the town of and

my father sent Jimmey out out to me & she lived with
me until I came away I left Jimmey on the farm
with read of the negroes, in & under the care
of my brother william - that in the year 1807 I
against went to Kentucky & found Jimmey living where
I left him and in 1809 when I again returned from
Kentucky I think Jimmey was living with Richand B Dalland - That is the year 1817 (Eighteen hundred seventeen )I again went to kentucky & Jimmey was ther
living in the barrens to herself with her husband & children
which was the last time I saw her & what has since
become of her of my own knowledge I am unable
to tell- to the best of my knowledge and belief my
father never owned any other negro woman by the
name of Pegg but the one I have before mentioned-

Jimmey was rather of a yellowish complexion & short of
State- further I know not

his
John x

which said Deposition the undersigned hereby certifies
was sworn to in manner aforesaid & subscribed to in his

presence and at the time & peace aforementioned

The undersigned further returns that the paper
to the original deed
of on to negro
Pegg to thus & form of among the records in the
Clerk's office of Court which said
exhibit, together with the deposition of the said john Dalland. A refered to noice and
Commission are herewith returned enclosed
under the hand & seal of the undersigned

A.

Maryland ss

J Henry of harford
the same being a Court of Record hereby certify that
, before whom the before going deposition of john
. was taken & who has subscribed his name was
the there of so doing one of the justices of the peace of the said State in and
for County Commissioned & sworn
Certify that the said is a deputy Clerks of said
Court

In testimony whereof I hereto subscribed
and affix the seal of said Court this
eleventh day of October AD 1842Clk

Maryland .Ss.

To all whom these presents shall come Greeting: I Richard Dallan of Harford
County in the State of Maryland for diverse good causes & considerations me thereunto moving do hereby
declare free, & enforce from the negroes, following to wit Pegg. to be free at the expiration
of six years: Judith at the expiration of ten years: Poll at the expiration of eleven years: Dick at the
expiration of seventeen years: Andrew at the expiration of seventeen years: Sall at he expiration of
thirteen years; Phillis at the expiration twelve years; Grace at the expiration of nineteen years;
Janney at the expiration of twenty years from the date hereof: and all the children born
of negroes to be obsolutely free at the age of twenty one. Hereby acknowledging the said
Negroes discharged from all claim of service & right of property whatever from me my view
or administrations- As witness my hand & seal this twenty sixth day of February with
your of our Lord one thousand Seven hundred & Eighty seven.

Rich Dalland

County ss.

On the twenty seventh day of February in the year of our Lord 1787 personally
appeared begore me the Subscribed our of the Justices of the peace for the County aforesaid Richard
Dalland party to th within instrument of writing who acknowledged the said instrument to be his act
and deed & signature & seal thereto annexed to respectively his

John
Received & recorded the8th March 1787 by John Lee gibsonClk
Clk

State of Maryland Harford County to wit;

I Henry Clerk of Herford County Court this same being a Court of record & hereby Certify
that the aforegoing Deed of or Instrument of writing is truly transcribed from J.L.G. to H.
57 & 58 one of the land Record Books of said County - And I also hereby certify that it appears from
the Record of sid County that William who appears to have taken the acknowledge ment
to said Deed of & whose name is thereto signed was at the time of so doing one of the said
States justice of the Peace duly commission & sworn to said on the th day of February A.D. 1787.

On testimony whereof I hereto subscribe my name & the
seal of Harford County Court his first day of October in the
year of our Lord one thousand eight hundred & forty two
Henry Clk
of

Maryland Ss.

I chief Judge of the sixth
Judicial District of the state of Maryland compound
of Hanford and Baltimore County do certify that the
aforegoing attestion by Henry Dorsey Clerk of Harford
County Court are in due from of law the
proper officer given under my hand and seal this eighth day of October in the year Eighteen
hundred and forty two

Maryland Ss.

I Henry Dorsey Clerk of Harford County Court the
same being a Court of Record hereby certify that the Honarable
stevenson archur esquire who appears to have given and
signed the above certificate was at the time of so doing chief
Judge of the sixth Judicial District of the State of Maryland
Composed of Harford & baltimore counties duly commissioned
& qualified and to all his acts as such full
faith and credit is and ought to be given as well in
Courts of Justice as there out

In testimony whereof I here subscribe
my name and affit the seal of
Harford County Court aforesaid at
this 8th day of October A.D. 1842-
Henry Dorsey Clk
of

copy of deed of
manumission from
to
sundry negroes

Exhibit Al

fies the 10th Oct 1842 with
the undersigned & seal by
him to John J.M.Dallan
upon his examination

A.L.

Maryland ,ss.To All Whom these Presents shall come, Greeting:

IRichard Dallan of HarfordCounty, in the State of
Maryland , for divers good Causes and Considerations me thereunto moving, do hereby Declare
Free, Manumit and Enteranchise the Negros following, to wit :Pegg To be Free at the expiration of
Six years, judith at the expiration of Ten years, Poll at the expiration of eleven years
Dick at the expiration of seventeen years, andrew at the expiration of Seventy years
Sall at the expitration of thirteen years, Phillis at the expiration of Twelve years
grace at the expiration of nineteen years Fanny at the expiration of Twenty years
from the Date hereof ; and all the children born of negroes Negros To be absolutely Free at the
of Twenty one Hereby acknowledging the faid Negrodifcharged from all claim of service and Right of Property
whatever from me, Heirs, Executors or Administrators-As Witnes my Hand and Seal, this
Twenty sixth Day of February in the Year of our Lord, One Thousand seven
Hundred and Eighty seven

Harford County, .

On thetwenty seventh Day of Febuary-in the Year of our Lord 1787 personally
appeared before me, the Subscriber, one of the Justices of the Peace for the County
aforesaid, Richard Party to the within Inftrument of
Writing, Who acknowledged the said Inftrument to be his Act and Deed, and the signature and
Seal thereto annexed, to be respectively his.

John

of
Several Negros
need to be recorded
the 8th Day of
March 1787
same Day recorded
in
No

by

exhibit B
filed 8th October with
.

County of St. Louis ,ss.The State Of Missouri To Richard B. DallanGreeting:

You are hereby commanded, that setting aside all manner of excuse and delay, you appear
before the Judge of our Circuit Court , on the1st november 1843at 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 is
plantiff and 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 27 day of October
in the year of our Lord, one thousand eight hundred and
forty three
In. Ruland Clerk, C. C.

for

Richard B. Dallan
1 nov

Execute the 28th October
1843

Sheriff
By
fees 50

the St. Louis Circuit Court the St. Louis Circuit Court

It is hereby agreed between the attorneys
for the plaintiff and the defendant in
the above suits pending in the st. louis
Circuit Court brought by the plaintiff
to recover their freedom that judgements he entered up in of the
plaintiffs in of the above case
as upon submition to the Court and that the plaintiffs shall pay all
costs in the suits recovered of the defendants
all said judgements are to be entered
up of such time hereafter as the attorneys
for the plaintiffs very best

St. Louis 17 January1844

for
for

to