State of Missouri
County of St Louis ssIn the St Louis Circuit Court Nov Term 1845

Thomas Jefferson a man of
Color complains of George A Calton & Jonathon B
Moulton of a plea of tresspass for that said
defendents on the first day of January Eighteen
hundred and forty five with force and arms
made an assault upon plaintiff to wit
at the County aforesaid and then and there beat
bruised and ill treated him the said plaintiff and
then and there imprisoned him the said plaintiff
and kept and detained him in prison then and
there without any reasonable cause whatever for
a long time to wit, the one month then
next following contrary to the statute Law of the said, against the will of sd
plaintiff and the peace & diginity of the State
And said plaintiff avers that before the Committing
of said grievances, he the said plaintiff was
and still is a free person. and that defendants
then held and still do hold him in slavery
to said plaintiffs damage five hundred
dollars and therefore he sues

Field Murdock & Dawson
pq

To the Hon John M Krumm Judge of the St Louis Circuit Court

Your petitioner Thomas Jefferson a man of color aged about
Thirty two years, humbly complaining respectfully
represents to your honor that he was born a slavein
the State of Virginia , That in the Spring of Eighteen
hundred and thirty five he was brought by his master
one Charles Drexter to St Louis in the State of Missouri
where he (your petitioner) resided untill the Spring of
Eighteen hundred and thirty nine. That in the
month of March or April of the year last mentioned
said Drexter sold your petitioner to one Samuel
Prosser . That said Prosser then resided and now
resides at Jacksonville in the State of Illinois
That said Prosser immediately after becoming the
owner of yourpetitioner removed your petitioner
to the County of Morgan in the state of
Illinois , where said Prosser your petitioners then
master, held your petitioner in slavery & compelled
him to labour as such on a farm in said County
of Morgan & State of Illinois for a period of
about Eight months. Then next following the
month of April in the year Eighteen hundred
and thirty nine. at the expiration of which period
your petitioner was again brought back to St Louis
by sd Prosser and that some Six months since
said Prosser sold your petitioner to one George
A Calton, and Jonathan B Moulton , who have
ever since, and still do hold your petitioner in
bondage. Your petitioner believing he is entitled
to his freedom, prays your Honor to grant him
cause to sue as a poor person to establish said
freedom according to the provisions of the Statute
in in such cases. & he willever pray &c

Thomas hisxmark Jefferson

George M Richards being sworn
States he knows the petitioner
and believes
the facts contained in
foregoing petition to be true

Geo. M. Richards
Sworn to & Subscribed before me
this29 day of April 1845
Jn Ruland Clerk

Sworn & subscribed
before me this 26th day of
April A.D.1845

John WinrightJustice of the Peace

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

We command you to Summon George A Colton &
Jonathan B Moulton that they 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 Thomas
Jefferson of a plea of trespass to the damage of said plaintiff five hundred
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 fifth day of
May in the year of our Lord eighteen
hundred and forty five. 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 L.S.

Plea filed 16 p 403.nonsuitNov. 30. 18463 p 390.

No.24 Saint Louis Circuit Court November Term 1845

Summons 5th May
Trespass Das
500

Murdock & Dawson

Filed April 29th 1845

Jn Ruland Clk

It is ordered by the Court that Thomas
Jefferson be allowed to sue as a poor
person to establish his right to freedom
and that Messrs Murdock & Dawson
are assigned him as Counsel he shall have
reasonable liberty to attend his Counsel
and the Court as occasion may require,
that he be not removed out
of the jurisdiction of the Court, and
that he be not subject to any severity
on account of his application for
freedom.

(190)

Executed this writ in the County
of St Louis on the 5th day of May 1845 by
offering to read it and the declaration to
George A Colton and Jonathan B Molton
the defendants, which they each refused to
hear

William Milburn Shff By A C Osburn Dety

Service$2.00service warrant3.00$5.00

In the St Louis Circuit Court November Term 1845

Andrew H H Dawson being
duly sworn states that it is his belief & he
has good ground to suspect & belief that
if an order is not granted in the
above case directing the Sheriff to take
possession of the above plaintiff, that the
sd defendants willremovesend said
plaintiff in order to present his successful
prosectuion of his suit & hereby prevent
his recovery of his liberty

Andrew H H Dawson John Ruland Clerk

No.19
St Louis Circuit Court November Term 1845

filed29 April 1845

Jno Ruland Clerk
Richmond J Carle

petition filed & statutory order made & Warrant issued at 10 am Wednesday16p175

County of St Louis sct
the State of Missouri To the Sheriff of County of
St Louis Greeting:

It appearing to the Honorable Circuit Court John M Krum , Judge of the St Louis Circuit
Court from affidavit filed that there is reason to suspect and believe that Thomas Jefferson , a
man of color, who has been allowed by the order of the
said Court to sue as a poor person to establish his right
to freedom, will be sent away in order to prevent his successful
prosecution of said suit, and thereby prevent his recovery of
his liberty. You are hereby commanded to seize the
said Thomas Jefferson wherever he may be found, and
bring him before me Honorable Judge of said Court at the Courthouse in the
City of St Louis at nine O'clock A.M. on tomorrow
morning the thirtyethApril 1845, and also to summon
any person or persons in whose possession he may be
found in and particularly George A Colton and Jonathan
B Moulton to appear before our said Judge at the same
time and place, 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 29th day of April
1845. John Ruland Clk

Executed this writ in the County
of St Louis on the 30th day of April 1845by
reading it to George A Colton & Jonathan
B. Molton and by seizing the body of
Thomas Jefferson the withnamed and
having his body before the Hon John
M Krum this 30th day of April 1845
as I am herein commanded

William Milburn ShffFee $3.00By A. C Osburn Depy

Warrant to Sheriff

In the Saint Louis Circuit Court
of November Term A
D.1845.

And the said defendants by Leslie & Lord
their
attorneys come and defend the force and
injury when &. And say that they, neither of them
are not guilty of the said suffered trespasses above
laid to their change, or any or either of them in
manner & form
as the said plaintiff hath above
complained against them.

Leslie & Lord attys
for Defendents

In Circuit Court

Plea not Guilty

Leslie & Lord
for Defts filed Nov22nd 1845
John Ruland Clerk

County of St. Louis ,Ss.The State of Missouri ,
To Miron Leslie, Milton W. Hopkins & Wm Carr
Lane
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 30th day of November A. D. 1846
at 10. O'ClockA.M 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 Tom. Jefferson is
plaintiff and Coulton & Moulton Ure
defendants, on the part of Defts
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 25th day of
in the year of our Lord one thousand eight hundred and
forty-six Jn. Ruland Clerk, C. C.

In Circuit Court

Subpoena for 30.Nov

X M. LeslieX M. W. HopkinsWm Carr Lane for Defts.

ExecutedNovember 30th 1846
Except. W not found
Samuel Conway Sheriff

Fee 1.50

G Stevens Depy