To, the Hon Alexander Hamilton Judge, of the St Louis, County Circuit Court ,

the petition of Peggy Perryman respectfully represents that on or about the first of december past, - - she was residing, with her friends, in Arkansas ,
in the peaceable enjoyment, of her freedom and
civil rights, to which she was enitled by her parents,by being free persons, her father, a free
person of color, in said state, and her mother was lawfully married, to her her father, an Indian of, the Black foot tribe Your Petitioner represents,
that about that time she was suddenly seized,
by persons, to her before unknown gaged, and transported, and finally sold into servitude that, her her relatives, by the mother side and, all not,
only free since, the memory of man but are distinguished, among their tribe, your
petitioner represents as such free born person she, is entitled, to her freedom from the engagement of which she is, wherefore she prays, in considerationof the promises she, may have leave, to sue,
as a poor person, in order to establish,
her right, to freedom and that counsel, to her for that purpose, order be made, as to secure
of prosecuting, her said, as in duty bound she,

Peggy , her X pPrryman,1848
Howard

by the court, in the,

petition, shall during
suit have reasonable liberty of all and the court that she and,, of the state or jurisdiction that she shalln not be subject to any severity on account of her application,
for her freedom,
and that she be permitted to sue, as a poor person,

A Hamilton,
.

In the circuit court,
of saint louis county,
April term, 1848

And this day comes the defendant and his, attorneys and moves the court, to dismiss the above potential suit, for the
following reasons

1st given
the commandment of , for casts might be
against for the as
is required the

2d Because no attorny, is given
the of statute to permit such a,
suit of one held as, a as a poor
person

3rd because, no suficient, reason
is for to make it,

4th because there, is in fact no suit pending for want of sufficientprocess

5th because there, is no unit,.

6th because there, is no service,.

Field + HallAttys for Deft.

Motion to Dismiss
& reasons,

Field, Hall
attys for deft, filed,june 15. 1848
JN Ruland clk,

In Circuit, court of
Saint Louis County,November Term 1848 State , of Missouri ,
County of saint Louis,

Peggy Perryman ,
a free woman, of color, complained of
Joseph Philibert, of a plea, of trespass,
for false imprisonment, for that whereas heretofore to wit, at the city and county of saint louis, and state of missouri, as about,
the spring of the year one thousand eight hundred
and forty seven as your petitioner recollects, the said Joseph Philibert drendant aforesaid then, and there with, force and arm assaulted, the said Peggy and her the,
said Peggy then, and there took, and
imprisoned and restrained, her of her liberty,
and her the said Peggy held in servitude from,
the spring of the year 1847 at which time, as your
petitioner, is informed the said defendant,
purchased her from one Bartley untill, the present time,
and still holds her in servitude, without any
reasonable or probably cause, against the
law, of the land and against the will of her, the said Peggy , and that she Peggy , before and at the time of the, said greivances was, and still, and that the said defendant holds her in servitude,, and servitude,
and to the great damage, of
and therefore, she sues,

to dismap suit 18p 347.

No
St Louis Circuit,
April Term, 1848

Trespass for false imprisonment,

Filed June,1848
Jno Ruland
clk

Executed this order of Court by reading, it and the
Petition and declaration to Joseph Philibert in the
County of St Louis April 28th 1848

Samuel Sheriff
By Deputy

Service 50Copy 1,10

To the Hon Alexander Hamilton , Judge of the St Louis County Circuit, court

The Petition, of Peggy Perryman respectfully represents, that on or about the
first day of december 1845 She residing with, her friends, in Arkansas , in the
enjoyment, of her freedom, and and civil rights,
to which she was entitled, her parents being,
free persons, her father, a free person of color, of
color in said state, and her mother who
was lawfully married, to her father an
Indian, of the Black Foot tribe. your
petitioner represents, that about that time
She was suddenly seized, by persons to
her before unkown, gaged and transported,
and finally sold, into servitude, that
her relatives, by the mother side and all not only
free since, the memory, of man, but and distinguished, among their tribe, - your
Petitioner represents, as such free person, she
is to her freedom from at
which she is now restrained, by Joseph Philibert Wherefore, she
prays, in consideration, of the promises, she
may have had to sue as a poor person, in order to establish, her right to freedom
and that counsel, may be to her for
that, purpose and that such order be made
as to secure, her in the privelege, of presenting,
her said claims and, as in duty bound, she
will pray

Peggy ,X Perryman, Sworn, to Subsribed, before me to this 5th of july 1848.P.J. Howard clk Criminal Court

Cicuit Court of St. Louis County,
November Term,
1848

Defendant comes and defends the,
of the said plaintiff,

Dory Field + Hall Attys for Deft

Atty for Dept

Filed,nov. 20. 1848
clk
18p 386

No 255 Saint Louis Circuit Court November Term 1848

suit for freedom

filed December,5, 1848 summons to april 1849

plaintiff attend counsel, to 19 p 26
motion to dismap,.

In Circuit Court of St., Louis County nov T, 1848State of Missouri , County of St Louis

Peggy Perry,man a
free woman of color complains, of Joseph Philibert, of a plea of trespass, for false imprisonment, for that whereas the city and county of St Louis and
State of MO during,, the spring of 1848,
as as your petitioner presents,
the said Joseph Philibert, Defendant
then and there, with force and, arms
assaulted, the said Peggy , and then and there took, and imprisoned, and
restrained, her of her libery, and her the
said Peggy , held in servitude, from
the from the spring of, the year 1847 at which time as your said petitioner
the said deft, her from one Bartlett ,
untill the present time, and still holds
her in such servitude without, any
reasonable, or probable cause, aganist
the law, of the land and against the will of her, the said Peggy , and the said
further and that before
and at the of the committing of the
said greivances, was and still is a free person, that the said Deft, held and still
holds her in servitude and, slavery against
the and to the great, damage of,
the said Peggy , therefore she sues,

Peggy Perryman ,

It is ordered by the court in the
within, cause that the petitioner,
shall be allowed to sue as a poor person, and shall during, the of will have reasonable, liberty of attending
her counsel, and the court, and that
she, shall not, be removed, out of
the state, or jurisdiction, of this court,
and shall not be subject, to any
severity, on of of her application,
for freedom and that she is permitted, to sue, as a poor person

Personally, and
says that Peggy Perryman is,
a poor person and unable to
prosecute her suit but as a poor, person

to this 4th day of
Dec 1848

In Circuit Court of St Louis County,nov 1848
State of Missouri ,
County of St Louis ,

Peggy Perryman a free woman of color complains of Joseph Philibert of a plea of Trespass, for false imprisonment for that, at the city and County of St Louis and State of MO during the spring of 1847, your petitioner recollects the said Joseph Philibert defendant then, and there, with force, and arms assaulted, the said Peggy , and then, and
there took, and
imprisoned, and her of her liberty and her, the
said Peggy held in serviude, from
the spring of the year,1847 at, which
time the present, time and still holds her, in such servitude without any reasonable or probably casue against,
the law of, the land and against, the will of her, the Peggy , and she, the said further, and declares that she before,
and at the time, of the committing of, the
said greivances, was and still, is a free person and, that the said Deft, held and still,
holds her, in servitude and slavery against,
the will of, and and to the great damage of the said Peggy , and therefore she sues,

Peggy Perryman ,

It is ordered, by the court, in the
within case that the petitioner shall be allowed,, to sue as a poor person and shall, the of this suit have reasonable liberty of attending her counsel and, the court and that she shall not be removed out of the state of or jurisdiction of this court,
and shall not be subject to any severity on account of her application,
for freedom and that she be permitted to sue, as a poor person,

Personally

to 4th day of
Dec 1848
clk

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

We command you To Summan Joseph
Philibert 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 next, then and there to answer unto Peggy
Perryman (ofcolor) of her petition for
freedom. filed V dr3th 1848.
And have you then there this writ.

Wintness, John Ruland , Clerk of our said Court, with the seal thereof hereto affixed, at office, in the
city of St. Louis , this 18th day of
December in the year of our Lord eighteen
hundred and forty Eight 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

Excuted this unit in the county of St. Louis on the 19th
day of December 1848 by reading it to Joseph Phili, bert said County
and further executed the same on the same day by
offering to read the declaration to the said Joseph Philibert,
which he refused to hear

Louis T Labeaume Sherrif
BySein Fremon dept Service $ 1 00

County of St. Louis , ss.The State of Missouri ,
To John /CalverbGreeting:

You are hereby commanded, that setting aside all manner of excuse and delay, you appear be-
fore our Circuit Court for the county aforesaid, on the 25th January
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 Peggy Parryman is
plaintiff and Jos. Philibert
defendant on the part of plaintiff
and herein you are in no wise to fail.

Witness, Wilson Primm, Clerk of our said Court,
with the seal thereof hereto affixed, at office, in the
City of St. Louis , this 20th day of
January in the year of our Lord one thousand
eight hundred and forty-7Milen ePrimm Clerk C.C.

Nov. D. 1848

John Calnent
( for 39)

Executed this 24th day of January 1849

L. J. Labeume shiff
By fee 50 Coues Town this uag rz

In the St Louis Circuit Court ,
November
1848

,

Motion to dismiss,

Filed February 9th 1849February 9th 1849 Wilson Primm ck

In the Circuit Court
of St. Louis country
April Term 1849

me said defendent comes and defe
the demand, of plaintiff,

Hall attys for Deft,

plea

Field + Hall
Attys for deft Filed april 17 1849 Wilson Primm, clerk
99

In the st louis circuit court
April 1849

it this an
the 9th day of February 1849 the said defendant, is the his and

to an
the 6th day of is the is the 1849 the came an
whan the upon which of the
is the
and
at the
and this of he
and a
of is the
a 20th day of nov. 1848
and on the 17th day of april 1849
his of upon
is

Bill, of Exceptions,

filed oct 6 1849
M. S. Cerre clk

County of St. Louis , Ss.The State Of Missouri , To john Calverb-Batiste sr.
Greeting:

You Are Hereby Commanded, that setting aside manner of excuse and delay,
you appear before our Ciruit Court for the County aforesaid, on the 18th
february 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 Peggy Perryman , is
plaintiff and Joseph Philibert, is
defendant on the part of plt,
and herein you are in no wise to fail.

Witness, Michael S. Cerre , Clerk of our said Court,
with the seal thereof hereto affixed, at office, in the City of St. Louis , this 9th
day of Fenruary in the year of our Lorde one thousand eight hundred and fifty M S Cerre Clerk, C.C.

Circuit courtNov 1849

+ Mo CalversMon. Batislean ( 12 no 488)

Excuted on Calvers,

L Labeaume,
fee 60

County of St. Louis , ss.The State of Missouri ,
To Curtis Kennedy
Reuben Bartlett
Broadway 292
neune placeGreeting:

You are hereby commanded, that setting aside all manner of excuse and delay, you appear be-
fore our Circuit Court for the County aforesaid, on the 18th day of
February 1850 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 Peggy Perryman is
plaintiff and Philibert is
defendant on the part of Deft,
and herein you are in no wise to fail.

Witness, M. S. Cerre Clerk of our said Court, with
the seal thereof hereto affixed, at office, in the City of St .
Louis , this 11th day of February
in the year of our Lord one thousand eight hundred and
fifty M. S. Cerre Clerk C.C.

for Deft,

Executed on
Bartlett the other
not found

L T Labeaume shff
fee 60

County of St. Louis , Ss.The State Of Missouri ,
To John Calvert Mon Batiste
Greeting:

You Are Hereby Commanded, that setting aside all manner of excuse and delay,
you appear before our Circuit Court for the County aforesaid, on the 25//-
Feb1850 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 Peggy ,
is plaintiff and Jos,
Phillibert is
defendant on the part of
and herein you are in no wise to fail.

Witness, Michael S. Cerre , Clerk of our court,
with the seal thereof hereto affixed, at office,
in the City of St. Louis , this 13//-
day of Feby
in the year of
our Lord one thousand eight hundred and fifty
M. S. Cerre Clerk, C.C.

for peff

Mo Calvert
Mon Batiste.

Executed on
Calvert Batiste
not found

Louis T Labeaume shff
Fee 60
Ent 72.

60

10

100

60

60

50

3.40

1.20

4 60

County of St. Louis , Ss.The State Of Missouri , To Curtis Kennedy, Reuban Bartlett,Greeting:

You Are Hereby Commanded, that setting aside all manner of excuse and delay,
you appear before our Circuit Court for the County aforesaid, on the 25
Feby 1850 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 Peggy of color,
plaintiff and Jos. Philibert,
defendant on the part of deft,
and herein you are in no wise to fail.

Witness, Michael S. Cerre , Clerk of our said Court,
with the seal thereof hereto affixed, at office, in the City of St. Louis , this 13 day of
July in the year of our Lord one
thousand eight hundred and fifty M. S. Cerre Clerk, C.C.

for for deft,

R. Bartlett, Curtis, Kennedy

Served, this subpoena, in the county
of St. Louis on the 18th day of feby 1850

Louis T Labeaume shff, By Fees 1.00,

County of St. Louis , Ss.The State Of Missouri ,
To Batiste Chouteau
Greeting:

You Are Hereby Commanded, that setting aside all manner of excuse and delay,
you appear before our Circuit Court for the county aforesaid, on the 18th
March 1850at 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 Peggy Perryman is
plaintiff and Philibert is
defendant on the part of plaintiff
and herein you are in no wise to fail.

Witness, Michael S. Cerre , Clerk of our court,
with the seal thereof hereto affixed, at office,
in the City of St. Louis , this 13th
day of march in the year of
our Lord one thousand eight hundred and fifty M. S. Cerre Clerk, C.C.

spa
Batiste Charleau

not found
Louis T Labeaume , shff
tea 10cts