To the honorable Luke. E. Lawless , Judge of the St. Louis
Circuit Court .

Your petitioner Pierre , a mulatts, respectfully
represents, that his mother, a negrefs, named Rose , was born in montreal in Lower Canada , about the
year 1768.

He further represents, that in the year 1791,
or there about, your petitioner's mother then being about
twenty three years of age, was taken by one John stock from
Montreal to Prairie chien in the south-western
territory of the united states, where she remained with
said strok rendering service to him and his family untill
the time of his death which happend as your petitioner
is informed and belives about the year 1794.

The further states that about the year 1795,
one andrew todd took your petitioner's mother and
brought her from prairie Chien to St. Louis , now
the City of St. Louis , and on the 28th day of October of the
same year, by bill of sale of that date, 666,
sold her to one Pierre Joseph Didier , claiming to have
lawfully acquired her of the state of said John stock
deceaded.

The further states, that on the 8th of august
1798, by bill of sale of that date, sp.arch no 750, the
said Didier sold your petitioner's mother to one
auguste chouteau together with her two children,
deseribing them in said bill of sale as a
"named Rose , a native of montreal in Canada , aged
“about thirty years, and her two sons two
“years old, and ten months old, both
“born in this County. “In this bil of sale the said
Didier declars that he given no warranty
as to the tittle to said slaves.

Your petitioner further states, that his mother remained in the service of Choutean , until the
time of his death. Whilst in the service of the said
Chouteau said Rose became the mother of several
children, amongest whom is your petitioner, born
about the second day of December 1807.

after the death of said Choutean , your
petitioner was sold as property belonging to his
state, and was purchased by one Edward Choutean
who subsequently sold your petitioner to and
Therese Cerre Chouteau , by whom he is now held
and claimed as a slave in said County.

now your petitioner claims that he is a
free man, first became him mother was born face,
being a native of a British province in which
slavery was not tolerated, and secondly, because
if his mother were boun a slave, she become
by her residence at Prairie Chien a free
person under the Ordinance of 1787.

Your petitioner therefore prays that he may
bepermitted to bring suit as a poor person against
the said Therese Cerre Choutean in order to establish
his right to freedom; that your honor will
order that he have resonable liberty to attend
his Counsel who may be afsigned him, and the
Court over which your preide, as occasion may
require, that he be not removed out of the
ofsaid Court, and that he be not subject
to any severity on account of this his application
for freedom and as in duty bound your petitioner
will ever pray

This is the Pierre markx of

State of missouri ss.

St Louis County, to ;

It being my opinion that
the within petition contains sufficient matter
to an charge the commencement of a suit, I order
First. That Pierre , the petitioner be
accomed to bring suit as a poor person against
Therese Cerre Choutean to establish his right
to freedom, and i assign him as his counsel
Witson Primm.

Second.I order that said Pierre 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 County, and that
he be not subject to any severity an account of
this his application for freedom.

County of Saint Louis

Before me, Frederick , a Justice
of the peace for within County aforesaid, came Pierre , and
made oath, that the facts contained in this petition are true according
to his best knowledge and beleif.

Markx of Pierre ,
qua tertis

Sworn to and subscribed
before me this 24th. day of September,
A.D. eighteen hundred & forty.
,
Justice of the peace.

In the Circuit Court
November Term 1840
St. Louis County, Court ;

Pierre , a mulatts,
Complains of there Cerr Choutean of a plea of
trespass. For that the said defendant on the first
day of September in the year of our Lord one thousand
eight hundred and forty, at the County aforesaid, with free and arms made an assault
upon the said plaintiff, to wil at the County
aforesaid, and then and there beat fruised and
ills-treated him the said plaintiffs and then
and there imprisoned him the said plaintiff
and kept and detained him in prison there,
without any reaonable or probable could
whatsoever, for a long space of time, to writ,
for the space of twenty from hours then next
following, Contrary to the laws of this tate
and against the will of the said plaintiff

and the said plaintiff avers that before
and at the time of the Committing of the
said several gievances, he the said plaintiff,
was, and still is a free persons, and that
the said defendant held and still holds
him the said plaintiff in slavery, to writ,
at the County aforesaid.

By reason of which said several premies
the defendant says he is injured, and has sustained
damage to the amount of Five hundred
dollars, and therefore he bring his suit

Pierre by his attorney

No 192

vs
Therèse

This is a such for freedom
in form of an action of
tree pap for false imprisonment.

Plaintiff sues informa
panperis.

for

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

We command you to Summon Therese Cerre Chintean
if she befound 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. Loui , on the third Monday
of November next, then and there to answer unto Pierre a
mulatto of a plea of trespas
to the damage of said plaintiff of 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 Twenty ninth day of
September in the year of our Lord eighteen
hundred and forty
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 .

Bk 13 p 16 - seeath of deft . & suit Bk 13 p 326

vs

No 192
St. Louis Circuit Court
November Term 1840

Summons
Suit for Freedom
Primim p.q.

Filed September 29. 1840
John Ruland Clerk

Executed this writ in the county of Saint Louis by delivering
a true copy of it and the petition I declaration and also
the order of made by the Honorable Luke . E Lawloss to Therese Cerré Choutean on the 10th day of November
1840

Marshall Brotherton Shff
By Joeph. C. Brown
Fees $ 1.00

archiva no. 666

Jodd
to
Dr.

Bill of Sale
Copy for Mr. Primm

State of Missouri .
County of St Louis ss.

I John Ruland clerk of
the Circuit Court and Ex official Records for the
County aforesaid,. certify the foregoing to be a y
true and corredt copy of archis no as the
same remains on file in my office.

In witness where of I have
hereto set my hand and affixed
the seal of said Court at office
in the city of St Louis this
24th day of September A.D 1840
John Ruland Recorder
by

Archive no. 750

Dider
to

Bill of sale Copy for Mr.Primm
Fee 57

State of Missouri
County of St Louis ss.

I John Ruland Clerk of the
Circuit Court and ex Offices Recorder for the Count
aforesaid, certify the foregoing to be a full,
and correct copy of Archiva no 750 as the same
remains on file in my office.

In Witness where of I have hereto set my hand and affixed
the seal of said court at Office
in the City of St Louis this
24th day of september a & D 1840.
John Ruland
by

St. Louis Circuit Court
Nov. Term 1840

vs.

and the said defendant
by her attonmy come and defendants the wrong
where and says that she is
not of the said several trespasses
in the said declaration mentioner in maner
and form as the said plaintiff hath
above thereof complained against her
and of then she puts herself upon the
county

for

St. Louis Circuit Court

vs.

Filed November 17 1840
Ruland Clerk

facts, that she as entitiled to her freedom, and
she prays 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 imprisonment
aganist the said William sullivan Randolph
and she will pray .

Alsey herx a woman of color
mark

State of Missouri
St. Louis County Ss.

Alsey a woman of color being
duly sworn says that the facts out forth in
the foregoing petition on first and

Asley herx mark a colord woman
Sworn to
the 20th day of february
AD1841.
Louis J Justice