In the Circuit Court
of St Louis County
State of Missouri
April term 1852

Plaintiff states that she
is a free person and that she is in possession of
and held as a slave by defendant. Plaintiff
states that she became entitled to her freedom
and is a free person because she was taken from
the state of Missouri in the year of 1847 or 1848 by
her then owner and master John MC Kenney to Terri
tory belonging to the United States , called Indian
Territory north of thirty six, 36, degrees thirty, 30, minutes of
north latitude in which territory slavery is prohibited and
that she remained in the aforesaid territory near Fort Scott,
and performed labour for said MC Kenney he
claiming her as his slave until about the month
of september 1850. Plaintiff states further that her said
Master MC Kinney resided in and made the aforesaid
territory his home and kept plaintiff in his possession
during the time mentioner from 1847 or 1848 until as aforesaid to until about
september 1850 and then bought her back to
the state of Missouri and therefore
she claims to be a free person. Plaintiff states that
before and at the time of commencing this suit that
she was a free person and was held and is still held as a
slave by defendant and she prays judgement for
her freedom and release from the claim of defendant and
all others to her as a slave

Laura By her Atty Joel C Richmond

Joel C Richmond , attorney for plaintiff makes
oath and says that he believes the matters
matters and things as stated in the
foregoing petition are true.

Joel C Richmond
Att for plaintiffSworn to & subscribed
10th Jany . 1852
M. S. Cerre clk

To the Honorable Alexander Hamilton Judge
of the Circuit Court of the County of
St Louis and state of Missouri .

Your petitioner Laura
, a woman of colour, states that she is a free
person and as such is entitled to her freedom. But
that she is held as a slave and is in possess
ion of Henry . B. Belt. She states that she is
entitled to her freedom because she was taken
in 1847 or 1848 by her then owner and master
John MC Kenney from the state of Missouri
to the United States Territory, called Indian Territory,
near Fort Scott. In which Territory slavery is
prohibited said territory being north of thirty six, 36, degrees
thirty (30) minutes, north latitude. she states further that
said MC Kenney resided and made his home in the
aforesaid territory from the time above mentioned
until about september 1850 and that she your
petitioner remained with and performed labour for
said MC Kinney in the aforesaid territory during the
time heretofore stated and therfore she claims
to be free. Your petitioiner also states that she
is a poor person without any estate and prays
that she have leave to sue as a poor person
according to the statute in such cases
provided.

Laura By her Attorney
Joel C Richmond

Joel C Richmond , attoney for the above named petitioner
Laura , makes oath and says that he believes that the
matters & things as stated in her petition are true.

Joel C Richmond

Sworn to and subscribed
Jany 10th, 1852

M. S. Cerre Clk

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

It is hereby ordered that
the within named petitioner Laura a person of
colour be allowed to sue for her freedom as
a poor person without giving security for costs
and that shebe allowed reasonable have reasonable liberty
to attend her Counsel and the Court as occasion
may require and that she be not removed out of
the Jurisdiction of this Court and that she be not
subjected to any severity on account of her suit
for freedom.

Given under my hand as Judge of
the Circuit Court of the County of St Louis
and state of Missouri this day of January
A.D. 1852

A. Hamilton Judge 8th Judicial Cir.Mo.

Circuit Court

Filed 10th Jany 1852, Leave to sue as poor person

M. S. Cerre Clk

County of St. Louis ,S.SThe State Of Missouri To the Coroner of St. Louis County, Greeting:

We command you to summon Henry B Belt to appear
before the Judge of our Circuit Court , on the first day of the next
term thereof, to be held in the City of St. Louis , within and for the
County of St. Louis , on the third Monday of April next, then and there to answer the complaint of Laura as set forth in the annexed petition
and have you then there this writ.

Witness, Michael S. Cerre , Clerk of said
Court
with the seal thereof hereto affixed, at office, in the city of St. Louis , this Tenth day of January in the year of our
Lord eighteen hundred and fifty two. M. S. Cerre 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
185

Executed this writ on the 12th day of Janry 1852
By delivering to H B Belt a true copy of the
writ and all so Reading the order of the Circuit
Court there on the same to said

H. B. Belt Coroners fees $1.00. E English Coroner

No. 22.
Saint Louis Circuit Court
April Term 1852

Laura (of color)
vs Summons
Henry B. Belt

Pet for freedom Richmond

It is hereby ordered that the within named petitioner Laura
a person of Color be allowed to sue for her freedom as a
poor person without giving security for Costs and that
she have reasonable liberty to attend her Counsel
and the Court as occasion may require and that
she be not removed out of the Jurisdiction of
the Court and that she be not subjected to any
severity on account of her suit for freedom.
Given under my hand as Judge of the Circuit Court
of the County of St Louis this day of January AD
1852.

A Hamilton Jud, 8th Judicial
Cir. MO.
a true copy attest
M. S. Cerre Clk
Filed January 10th 1852
M. S. Cerre Clk
$3 due
Copy Worth 28 cents

Order. 21.p. 421. 467

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

Joel C Richmond attorney
for the plaintiff in the above entitled
cause
being duly sworn on his on his oath states that since the commencement of said
suit and serviceand service on the defendant that
he the said defendant sold the plaintiff and
that James M Riley and James Christy became
the purchasers of said plaintiff and that
on the 16th day of February 1852 that the said
James Christy and --- E Curtis
did decoy the said plaintiff from the place
at which she had been confined
to wit the
jail of Bernard M Lynch whose slaves are kept
for and by by stating to her that they wished
her to go and see her attorney and that
instead of taking her to see an attorney that
the said Christy and Curtis with other per
sons to this affiant unknown did by force & threats
compel her the said plaintiff to go
on board of the steam Boat " Isabel " which was
at that time at the port of St Louis in the
state aforesaid and that the defendant and the
said Christy & Curtis shipped or caused the said plain
tiff to be shipped on board of said steamBoat
Isabel and to be carried to New Orleans in
the state of Louisiana or to some other place
out of the jurisdiction of this court for
the purpose of selling her as a slave the said
boat being at the time spoken of bound for New Orleans
Affiant states that the aforesaid Curtis didtake the said plaintiff from the Jail of the said Bernard M Lynch which is in the
aforesaid city of St Louis and that he
the said Curtis with others to this
affiant unknown did force and compel by threats
and violence the said plaintiff to go
on board of said steam Boat Isabel after
she plff had informed them, the said Curtis and
others, that she was a free person and
affiant is informed and believes that the said
Curtis and the others who assisted him in
forcing said plff on said boat were aided
and abetted by the said James Christy in
all that was done to decoy and force
the said plaintiff in the manner and
form heretofore mentioned and that the said Curtis and others have
caused the said plaintiff to be carried
out of the Jurisdiction of the Court.

Affiant also states that it was well known
to the said Curtis that the plaintiff in this
cause had brought suit for her freedom as
he was the person who bid for the said plaintiff
when she was sold by defendant and that he
the said Curtis was the agent or Clerk of the said
James M Riley & James Christy And affiant states that he believes that the
said Riley & Christy were told
at the time plaintiff was sold as afsd
of her suit for freedom at the time he
bid for and bought the plaintiff. Affiant
also states that he informed the said Curtis on the
day on which plaintiff was sold as aforesaid
that she had sued for her freedom. Affiant
states that he has called upon the defendant
in this cause and upon the said James Christy and
Curtis and asked as counsel for the
plff for some information of the whereabouts
of said plaintiff and that they have all failed or refused
to give him any information on the subject
Affiant states that the said plff was confinedfrom the time which she was sold by
the defendant which was about the 10th of January
last until the time she was taken away by the
said Curtis in the negro jail or yard of the
said Bernard M Lynch and that she
was carried too and taken from said jail or
negro yard by the aforesaid Curtis Affiant
states that it was not known to him until the 24th
of this month Febr 1852 that said plaintiff had
been carried off in the manner spoken of when
he received a letter from a passenger on said steamboat Isabel on one who
purports himself to have been such at the time said
plaintiff was taken on board of and carried off
on said steamer Isabel said letter ate at
Memphis Febr 15th 1852.

Joel C Richmond Att for plaintiff

Joel C Richmond attorney for plaintiff in
the within & foregoing cause makes oath
and says that the statements contained in the foregoing affidavit are true as he
verily believes.

Joel C Richmond

Sworn to and subscribed before
me, this twenty fourth day of
February 1852.

Adolph Kehr Notary public

In the Circuit Court

woman of colour
suit for freedom

Filed 26th Feb 1852
M. S. Cerre Clk Affidavit

In the Circuit Court for St. Louis County Laura of Color plaintiff
against
Henry B Belt defendant

In obedience to an order
of this Hon Court made at the present November
Term 1851, a copy of which is herewith filed in
and by which order James Christy with one
E Curtis is required to show cause to this Honble
Court on the second day of March 1852 why
an attachment should not issue against them
for a comtempt of the order of said Court. And
now the said James Christy comes and says that
it is not true that he with said E. Curtis on
the 16th day of July 1852 or at any time decoyed
the said Laura from the place where she was
confined & from the Jurisdiction of this Hon Court
and the said James Christy denies that he
at said time had any knowledge whatever that
this Hon court had ever made any such order
as the one referred to in the order a copy of which
is hereto annexed. And the said James Christy
presently denies that he ever removed or decoyed
said Laura from the place where she was con
fined and beyond the jurisdiction of this Court
after he had any knowledge that she was prose
cuting her suit for freedom.
The said James
Christy further states and gives the Court
here to be informed that he the said James
Christy never knew nor had he any notice or
information that the saidLaura Laura had
instituted any suit for freedom until

the sheriff of said County served upon him
the Copy of the order of this Hon Court hereto
attached. This respondent denies that he
violated any order of this Hon court after
having due notice of the existence of said
order and he denies that he has at any
time done any act or thing in contempt of
any order of this Hon Court and denies
all and each of the statements contained
in the order (a copy of which is herewith filed)
in which this respondent is charged with having
decoyed and moved from the place where she
was confined the said Laura beyond the jurisdi
ction of this Court after having noted that
said Laura was prosecuting her suit for free
dom and in violation of the order of this
Hon Court. The said James Christy hereby
protests that he has not committed any
contempt or knowingly violated any order
of this Hon Court Wherefore he prays to be
hence discharged with this costs .
James Christy the above named respondent on his oath says he believes the aforegoing
answer and the matters therein as stated
are true.

James Christy

Sworn to and subscribed 2nd March 1852
M. S. Cerre Clk

In the St. Louis Circuit Court November Term 1851

Whereas Joel C Richmond attorney for the
plaintiff in this cause has filed his affidavit in
the court alleging among other things

That one E Curtis and James Christy did
on the 16th day of February 1852 decoy said
said plaintiff Laura from the place where she was con
fined & from the jurisdiction of the court during
the pendency of her suit for freedom and with
full knowledge by the said James Christy and
E Curtis of the orders of this Court that she
the said Laura should not be removed
out of the jurisdiction of the court during the
pendancy of said suit and with full knowl
edge that said Laura was prosecuting her
suit for freedom. Therefore it is ordered by
the Court that the said James Christy & E Curtis
show cause to said court on Tuesday next the 2nd day
of March 1852 at 10 oclock A M at the Court
House of the city of St Louis why an attachment
should not issue against them for a con
tempt of the order of said Court in the
.

AHFeby 26th

State of Missouri County of St. Louis SS

I Michael S. Cerre Clerk of the Circuit
Court within and for the county aforesaid certify the foregoing to be
a true copy of the order made by said Court in said cause
Whereto whereof I hereto set my hand and affix
the seal of said court at St. Louis this 27th Feby 1852

M S Cerre Clk

Answer of James Christy

In the Circuit
Court

filed Mch 2nd 1852
M. S. Cerre Clk

County of St. Louis , SS.The State Of Missouri ,To E Curtis & James Chrity & James M Riley William
B. Miller Laura W &
Reuben 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 2nd day of
March 1852at the hour of 10 AM at the City of St. Louis , then and there
to testify, and the truth to say in a certian matter of controversy now pending in our said
Court, wherein Laura , a woman of colour suit for freedom is
plaintiff and Henry B Belt is defendant on the part of the plaintiff 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 27th day of February in the year of our Lord one thousand, eight hundred and
fifty two. M S Cerre Clerk C. C.

Laura vs Belt

suit for freedom

Circuit Court
Executed (Except Feby 27)
W B Miller Wm Hopkins
& L. Hopkins not found
Fees $2.30 E. English -
Coroner

County Of St. Louis . SS.The State Of Missouri Tothe Coronoer of St. Louis Corder Fine
Bernard M Lynch Adolph Kehr
Benjamin B Doyton & Henry B Belt 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 2nd day of
Marchat 10 o clock AMat the City of St. Louis , then and there to tes
tify, and the truth to say in a certain matter of controversy now pending in our said Court,
wherein Laura (a woman of colout in suit for freedom is plaintiff and Henry B Belt is defendant on the part of Plaintiff 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 27th
day of February in the year of
our Lord one thousand eight hundred and
fifty two M S Cerre Clerk C. C.

suit for freedom

Circuit Court
Executed the within
by summoning the with
in named witnesses as directed on the 27th day Feby 1852. E . English fees $2.50 cts, Coroner

In the Circuit Court for
St Louis County Laura a woman of Colour plff
against
Henry B Belt defendant

In obedience to an
order of this Hon Court made at the present
November Term 1851 of said Court in
the above entitled cause, requiring this
respondent to show cause why an
attachment should not issue against
him for a contempt of an order of
this Hon Court Cause and shown the
following to act, respondent states that
no order was ever served on him
in the above cause nor did he know
that any order ever had been
made in the above entitled cause
This respondent states that he did
hear that said Laura had instituted
suit for her freedom but that this
respondent was no party to the
issue and did not consider that
he had any thing to do with said
suit, he states that said Laura was sold
by the sheriff of said county and
as the agent for Riley & Christy he
bid for and purchased said
Laura for them, and after he
purchased said Laura he requested
Mr. Hughes an attorney of the St Louis
Bar to look into the matter

and advise what ought to be done
in the premises, and this respondent
states that said Hughes advised
that said Laura ought to be sold
This respondent states he gave no
further attention to the matter as he
relied on the advise given him by
said attorney.
This respondent denies
that he decoyed said slave from the
place where she was confined and
he denies that he removed said
Laura out of the jurisdiction
of this Hon Court, Knowing that
he was violating any order of this
Court, he states that all that he
did in the premises was as agent
for other and without any knowledge
on his part that he was violating
any law or any order of this Court &
he denies that he has committed any
contempt of any order made by this
Hon Court Wherefore he prays
to be hence discharged .

Hudson Atty for
respondent

Edward Curtis on his oath says he
believes the above & the matters therein as
stated are true.

Edwd Curtis

Sworn to & subscribed March
2nd 1852

M. S.Cerre Clk

Answer of
Edwd Curtis

Filed Mch 2nd 1852 M. S. Cerre Clk

In the St. Louis Circuit Court
November Term 1851

Whereas Joel C Richmond attorney for
the plaintiff in this cause has filed
his affidavit in this Court alledging among
other things that one E Curtis and James
Christy did on the 16th day of February
1852 decoy said plaintiff Laura
from the place at which she was
confined & from the Jurisdiction of this
Court during the pendency of her suit for
freedom and with full knowledge by the
said James Christy & E Curtis of the order
of this Court, That she the said Laura
should not be removed out of the juris
diction of this Court during the penden
cy of said suit and with full knowledge
that said Laura was prosecuting her suit
for freedom. Therefore it is ordered
by the Court that the said James Christy and E Curtis
show cause to said Court on Tuesday next
the 2nd day of day of March 1852 at 10
o'clock AM at the Court House of the City of St. Louis why an attachment should
not issue against them for a contempt of
the orders of said Court in the premises

A H Feby 6th

rend="bracketed">State of Missouri
County of St. Louis SS.

I, Michael S. Cerre Clerk of the Circuit within and for the County aforesaid, certify the foregoing to be
a true Copy of the order made by said Court in said cause
Witness whereof I hereto set my hand and affix the
seal of said Court at office, in the city of
St. Louis , this 27th Feby 1852.

M. S.Cerre Clk

Executed this writ on the 27th day of February 1852
by delivering to James Christy & E Curtis a true copy of
the within and offered to read the same which they refused
to heare in St. Louis County & State of Missouri .

E. English
Coroner Fees $ 2

Filed 3rd March 1852

M. S.Cerre Clk In the Circuit
Court
Curtis

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

suit for freedom

Plaintiff by her Attorney Joel C Richmond
by way of reply to the answer of E Curtis made
to the order of this Court in the above entitled cause
for him, the said Curtis to show cause on the 2nd
day of March 1852 why an attachment should
not issue against him the said Curtis for a
contempt of this Court in the above entitled
Cause and plaintiff states that he the said E Curtis
did have full and complete notice and knowledge of
all the orders made by the Court in the above
entitled cause in the suit of plaintiff for her freedom and
that he the said Curtis was fully informed of the same
by the plaintiff Laura & other persons.
Plaintiff states that the said E Curtis did on the 16th day
of February 1852 decoy amd force the said plaintiff
from her place of confinement and did remove her
the said plaintiff from out the jurisdiction of
this Court having a full knowledge that he was viola
ting the orders of the Court made in the suit of
plaintiff for freedom. Plaintiff states all that has
been done by the said Curtis in regard to and
touching the said plaintiff since the commence
of her suit for freedom has been done with a full
knowledge that he was violating the orders of
the Court made in the aforesaid suit of the
plaintiff for freedom. Plaintiff by way of
demurrer to the answer of the said E Curtis to the
aforesaid order of this Court made in this cause
states that said answer is no defence to the motion against him made in this cause against him
the said E Curtis to show cause why an attachment
should not be issued against him the said
Curtis as ignorance of the orders of this Court
made in regard to Causes therein pending is
no excuse for violations of such orders.

Laura , by her Att
Richmond

Joel C Richmond attorney for plaintiff makes oath and
says that the matters and things as stated in the
foregoing answer are true as he verily believes.

Joel C Richmond Att for Plff

Sworn to and Subscribed
before me this 3rd March 1852

Adolph Kehr Notary Public

suit for freedom

Answer of plff to
Curtis response on
motion for attachment

Filed 3rd March 1852 M. S. Cerre Clk Filed 3rd March 1852In the Circuit Court County
of St. Louis State of
Missouri

suit for freedom

Plaintiff by her attorney Joel C Richmond by
way of answer to the response of James Christy
made to the order of this Court in this cause that
he the said Christy should appear on the 2nd day
of March 1852 and show cause why an attach
ment should not issue against him the said
Christy for a contempt of the Court in this cause
states that he the said Christy did in manner &
form as stated in said order force decoy and
take from her place of confinement Laura
the plaintiff and that he the said Christy by the aid
and assistance of one E Curtis did on the 16th
day of February 1852 force decoy and take her
the said Laura the plaintiff in this cause from out
of the jurisdiction of this Court after suit
had been brought by plaintiff for her freedom
and process served on the defendant Henry B Belt
Plaintiff states that at the time she was removed
as aforesaid by the said James Christy and E Curtis out
of the Jurisdiction of the Court that the said Christy
and Curtis had full knowledge and due notice of the
orders of the Court made in this cause and among
said orders is that which directs that the plaintiff
be not removed out of the Jurisdiction of this Court
during the prudency of her suit for freedom
Plaintiff denies that said James Christy was unad
vised at the time he removed plaintiff as aforesaid
that she the plaintiff had commenced a suit for her
freedom but states he the said Christy did before & at that
time have an entire and full knowledge that said suit
had been commenced for the freedom of plaintiff.
Plaintiff Plaintiff states that the said Jaems Christy did
violate that order of this Court which directs that
plaintiff should not be removed out of the ju
risdiction of this Court during the pendency
of her suit for freedom after he had received due notice
of the same and that he the said Christy and E Curtis
did remove plaintiff out of the Jurisdiction of this
Court after suit had been commenced for her free
dom and process served on the defendant Henry B
Belt all of which appears of record in this cause.
Plaintiff by way of demurrer to the answer
of the aforesaid James Christy to the order of the Court
made on him in this Court states that said answer is
no defence to the motion for an attachment
against him the said Christy as ignorance of
the orders of this Court in cases therein pending is no excuse
for a violation of the same.

Laura By her Att Richmond .

Joel C Richmond atorney for plaintiff makes
oath and says that all the matters and things as stated
in the foregoing answer are true as he verily
believes.

Joel C Richmond Att for Plff

Sworn to and subscribed
before me this 3rd March 1852

Adolph Kehr Notary public

suit for freedom
Answer of plff to
the response of Christy
on motion for attachment

Filed 3rd March 1852M S.Cerre Clk