To the Honorable Luke Lawless
Judge of the Circuit Court of St. Louis County:In the State of Missouri

The Petition of negro Charles respectfully represents:
That he is held in slavery by Peter Verhagen
of the city of St. Louis in the State of Missouri : Your Pe-
titioner begs leave to state, that sometime in the year of our
Lord eighten Hundred and Thirty-seven. (he thinks in Feb-
ruary or March of that year) he was ordered denoted and
sent into the State of Illinois by a certain Joseph Rosati ;
who at that time claimed him, your Petitioner, as his slave
tern the power of ownership over him your Petitioner, for
the purpose of doing work in and about the House then
for fitting up for a Nunnery; that your petitioner did go
into that State for the purpose aforesaid and there remained
for the space of Ten or Twelve days, during which
time he (your Petitioner) was engaged in whitewashing the
House, in Painting and Plastering; that he (your petitioner)
afterwards returned into this State & has remained as he
was before, in the servitude and as the slave of the said
Joseph Rosati ; until within a few days past, when
the said Joseph Rosati having left this city, he, your
petitioner has been in the servitude and acting as the
slave of the said Peter Verhagen

Your Petitioner believes that the laws of the land do
therefore entitle him to freedom. To those laws he here
makes his appeal, and prays that your Honor will grant
him leave to sue as a poor person, in order to establish
his right to freedom; and that Tristen Polk and C. C.
Carroll Esquire may be assigned as his Counsel; and that he
may have reasonable liberty to attend his Counsel & this hon-
orable court, as occasion may require; that he be not removed
out of the jurisdiction of this court & that he be not subject to any
severity on account of his application for freedom, may it please your
Honor to grant him order to that effect. And as in duty bound; he will ever pray

May 16th 1840 Charles

St. Louis Circuit Court

May 16th 1840 - Ordered: -
That negro Charles be allowed to
sue as a poor person to establish
his right to freedom : and that
Tristen Polk & C. C. Carroll Esquire
be assigned him as Counsel: Also,
that said Charles have reasonable
liberty to attend his Counsel & this
court as occasion may require; &
that he be not removed out of the
jurisdiction of this court & that he
be not subject to any severity
on account of his application
for freedom

Field May 16 1840 Jn. Ruland Clerk

State of Missouri
County of St Louis Ss:In the St. Louis Circuit Court
July Term 1840

Charles , a man of color, the plaintiff in this action
by his attorney T . Polk & C.C. Carroll ,, complains of
Peter Verhagen , the Defendant, of a plea of trespass for
that the said Defendant on the first day of May Eighteen
Hundred and forty, at the said County of St. Louis , with force
and arms, made an assault upon him the said Plaintiff
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 Plintiff, and kept and de-
tained him in prison there, without any resonable or probable
cause whatsoever, for a long time, Court: for the space of twenty
days then next following, contrary to the laws and customs of this
State, and against the will of the plaintiff; and the said
Plaintiff avers that before & at that time of committing the a-
foresaid grievances, he was & still is a free person, and that
the said Defendant held and detained him and still holds
and detains him in slavery against law & right and
against the will of the Plaintiff at the County
aforesaid; and other wrongs to the said Plaintiff then and
there did to the great damage of the said Plaintiff and
against the peaceanddignity of the State- Wherefore the
said Plaintiff saith that he is injured & hatsustained damage
to the amount of Five hundred Dollars & therefore
he brings this suit-

C.C. Carroll
T.Polk
for Plaintiff

No.In St. Louis Circuit Court
July Term 1840

Charles a man of color
vs
Peter Verhagan

Clerk will summonsC.C. Carroll
T . Polk
p.q.May 1840
Filed May 16 1840 Jn Ruland Clerk

Petition filedPlff allowed to sue as poor person & counsel assigned 10 p 459

County of St. Louis , ss.
THE STATE OF MISSOURI ,To the Sheriff of St. Louis CountyGREETING:

We command you to Summon Peter Verhagen 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 Monday
of July next, then and there to answer unto Charles a man
of Color of a plea of trespass
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 Eighteenth day of
May 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 18

Executed this writ in the county of
St Louis on the 19th day of May 1840
by offering to read it and the petition
& declaration and also the order of the
Honorable Judge to Peter Verhagen the
within named defendant all of which he
said defendant refused to hear

Marshall Brotherton ShffBy Joseph . C. Brown Dpty Service $ 1.00

No 203 St Louis Circuit Court
July Term 1840

Charles a man of Color
vs
Peter Verhagen
Summons

Suit for freedom
Dams - - $ 500

Carroll & Polk
pq

Filed May 18th 1840 John Ruland Clerk Free

Transfered to court of common pleas BK 12 p 319

No 203 In the St Louis Circuit Court
July Term 1840.

And the said defendant by his attorney,
comes and defends the force and injury when and
says that he is not guilty of the said supposed
trespasses above laid to his charge or any or
either of them in manner & form as the said
plaintiff hath ab in his said declaration
alleged and of this he the said defendant
puts himself upon the County &C

Primm p.d. and the said Plaintiff does the like P.Q.

No 203 St Louis Circuit Court
July Term 1840

Charles
vs
Peter Verhagen

Plea
not guilty

p.d.Filed July 20 1840 Jn Ruland Clerk

THE STATE OF MISSOURI ,To the Constable of St. Louis Township, in the County of St. Louis , Greeting:

We command you to summon James Fontbonne & John P. Fisher
that all excuses and delays being set aside they personally be and appear before the undersigned, a Justice
of the Peace within and for the County aforesaid, on the 31st
day of Julyat ten o clock A. M. at his office, in the township of St. Louis , to testify
on the trial of a case wherein Charles a man of Color is
plaintiff and Rev. Peter - Verhagen is
defendant on the part of the
Plaintiff and of this they are not to fail at their peril; and have you
then there this writ.

Given under my hand. this 31th day of July A. D. 1840 Justice of the Peace.

Charles a man
of Color
vsSubpoena
Rev. Peter Verhager

Justice ,,18Witnesses James Fontbonne John P. Fisher

Executed this writ
By Summoning James
Fontbonne and
John P Fisher
in St Louis City
31st. 1840

Louis Brevil

By C. H. Bryan
D . C Fee 50

Charles a man of colour
vs
Peter Verhagen In the Circuit Court , for the County
of St Louis State of Missouri .To the above named afendant

You are hereby Notified, That Depositions of Witnesses to be read in evidence
in the above cause, on the part of the plaintiff will be taken at
the offices of Elihn of Shepard in the City of St Louis
in the County of St Louis and State of Missouri on the Thirty first
day of JulyInst between the hours of 8 o'clock
in the forenoon, and 6 o'clock in the afternoon: and that the taking of said depositions, if
not completed on that day, will be continued from day to day at the same place and between
the same hours, till completed.

Charles by his Attys
C. C. Carroll T. Polk July 27 1840

I acknowledge service of the above notice July 27, 1840

Wilson Primm atty
for defdt.

Depositions of witnesses produced swornand
examined at the office of R Shepard
in the City of St Louis in the county of St Louis &
Stateof Missouri Elihew H. Shepard a
Justice of the Peace within and for the county of
St. Louis and State of Missouri in a certain
cause now pending in the Circuit Court
for the County of St Louis and State of Missouri
between Charles as man of Colour- Plaintiff
and and Peter Verhagen Defendant
on the part of the Plaintiff

James Fontbonne priest of lawful age being
produced sworn and examined on the
part of the plaintiff deposith and saith
that he is acquainted with both plaintiff
and defendant in this case about four
years and three months and at the time he
became acquainted with the parties the
Rev Joseph Rosati was Bishop of this
Diocess in which St. Louis is and
resided in this city until he left here
in the month of May last say about
the 12th. Charles the plaintiff belonged to
the Bishop Rosati . The Bishop Rosati

the defendant in this case left his spiritual
business to be transacted in his absence
to the Rev Peter Verhagen the defendant and his
temporal affairs to Judge Mary P Leduc
In the house hold affairs Mr Verhagen
has the general contract and therefores
has the direction of Charles the plaintiff In
this suit in the spring of the year 1836

I was at Cahokia in the state of Illinois
and saw charles at work there at
the Bishops house for the sisters with
the permission of the Rev Bishop Rosati
and the Bishop knew that Charles was
there he had told me before that Charles
would go to work for this deponents
sister some gentleman came over for
him in a cart but I do not know
that it was Mr. Gaddeau or not
Charles was a Cook in the Bishop's house
at St. Louis and Wililam his the plaintiff
`` Brother Cooked in his absence and
lived about the house My sister one
of the sisters of St . Joseph at Caholia depends
on the Bishop and I presume she
asked for Charles to come and assist
her The Bishop told Charles that he
wished him to paint the house in
which the sisters resided in Cahokia
The deponent is a Catholic Priest

Sworn & Subscribedbefore
me this 31st day of July
1840 Shepard Justice
of the Peace St Louis County James Fontbonne Priest.

State of Missouri

I Shepard a Justice of the peace
within and for the county of St. Louis and state
of Missouri do hereby certify that James
Fontbonne priest the deponent whose place
of residence is in the city of St Louis in the
County of St Louis and State of Missouri

was by me sworn to testify the whole
truth of his knowledge touching the matter
in controversy, in the cause aforesaid
that deponent was examined and his examination
reduced to writing by me and
subscribed by him said deponent in
my presence on the thirty first day
of July, between the hours of eight
o clock in the forenoon, and six
O'clock in the afternoon at that day
at the office of Shepard in the
city of St Louis in the County St. Louis
and state of Missouri

Given and certified this 31st day of July 1840 W Shepard Justice
St Louis County

State of Missouri

I Shepard a Justice of the peace
within and for the County of St Louis and
State of Missouri do certify that in
of the annexed notice came before me
at the office of the Shepard in the
City of St Louis in the County of St Louis
and State of Missouri James Fontbonne
priest was there by me sworn
and examined and such examination
reduce to writing to writing and subscri-
bed by hire in my presence- and his
deposition is now with return
at the city and County of St Louis Mo
this 31st day of July 1840 Shepard Justice

St Louis County Missouri

Opened & filed Nov: 17 1840.

Jn Ruland Clerk

Charles , (a man of color)
vs
Peter Verhagen , dft

Costs of Justice Shepard $ 1.50

L . Court : .50

COUNTY OF ST. LOUIS , SCT.
THE STATE OF MISSOURI ,To any Judge or Justice of the Peace or other Judicial officer of the State of Illinois
GREETING.

We, reposing special trust and confidence in your integrity and circumspection, do au-
thorize and require you, that you cause to come before you, such person or persons as
shall be named to you by Charles a man of colour, his

Attorney or Agent, and him or them examine upon his, her or their corporal oath, (to be
by you administered,) touching their knowledge of any thing that may relate to a certain
matter of controversy, now pending in our Circuit Court , for the County of St. Louis ,
wherein Charles a man of Colour is
plaintiff and Peter Verhagen is
defendant on the part of the plaintiff and having
so reduced the said depositions so taken by you as aforesaid in writing, you are required
to send the same, together with this commission, enclosed under your seal, to our said
Circuit Court , with all convenient speed.

Witness, JOHN RULAND , Clerk of our said Circuit
Court , at the City of St. Louis , this tenth
day of June in the year of our Lord, one
thousand eight hundred and
thirtyforty John Ruland Clerk C.C.by Wm Ames Depty

Opened & filed April 21st 1841

Jn Ruland Clerk

Charles a man of Colour
vs
Peter Verhagen
Dep for plff

Dedimus to Illinois

Deposition of witnesses produced sworn and
examined, at the office of François La croix in the
Town of Cahokia in the county of St Clair and State of
Illinois , before me François La croix a Justice of the
peace in a certain cause now pending in the St. Louis
circuit court State of Missouri , between Negro
Charles plaintiff and Peter defendant
on the part of the plaintiff

François Nadeau of lawful age, being produced, sworn
and examined, on the part of the plaintiff deposeth
and saith

That a few days after Nuns, "or Sisters, came to live in
Cahokia I went over to St. Louis and Brought over
on this side of the river a negro man by the name of Charles
at the Nuns. I suppose this was either in march or
april in the year of 1836 after the said Charles came
to the Nuns. I saw him at work at the said Nuns
that is to say I saw him plaster paint and white wash
and to the Best of my recollection he remained there
fifteen or sixteen days, and Directly after the said Charles
came come to the Nuns he went to work, I always
since I have come to St. Louis known the said
Charles to be a slave of the Bishop of St. Louis and
I Believe that the said Charles came over by the
consent of his master the Bishop

his
François Nadeau
mark

I François La croix do hereby certify, that François Nadeau
the deponent, whose place of residence is in St. Clair county
in the State of Illinois was by me sworn to testify the
whole truth of his knowledge touching the matter in
controversy in the cause aforesaid, that deponent was
examined, and his examination reduced to writing, and
subscribed by said deponent, in my presence on the
Thirteenth day of June in the year eighteen hundred
and forty between the hours of ten oclock in the fore
noon and six o clock in the after noon at the office
of François La croix in the town of Cahokia in the county
of St. Clair and State of Illinois

Given and certified the 13th day of June 1840 François La croix
Justice of the peace

François Demettes of lawful age being produced, sworn
and examined on the part of the plaintiff deposeth
saith. about for year ago I was passing
by the house of the Nunes, or sister, in the town of
Cahokia . and I saw Charles a Negro man belong-
ing to the Bishop in St Louis . at work as I believed
but I do not know weather is was painting or
whitewashing. and I freequently saw him walk-
ing in the street of Cahokia . I Believe that the
said Charles came in Caholia by the consant of
his master for I. saw Mr Rosati the Bishop
of St Louis . in cahokia: and the said charles. -
came in Cahokia too. and work one day and a half
while the Bishop was present. this was about the first or second day of June in 1839.

François his mark Demette

I François La croix, a Justice of the peace do hereby
certify. that François Demette the deponent, whose
place of residence is in the town of cahokia in St Clair county
in the state of Illinois was by me sworn to testify the
whole truth of his knowledge touching the matter
in controversy in the cause aforesaid, that deponent
was examined, and his examination reduced in writing and
subscribed by said deponent, in my presence on the thirteenth
day of June in the year eighteen hundred forty between
the hours of ten oclock in the forenoon and six oclock of
the afternoon, at the office of François Lacroix in the town
of caholia in the county of St Clair and State of Illinois
Given and certified the 13th day of June 1840

François La croix
Justice of the peace

François Vaudrie . of lawful age being produced
sworn and examined. on the part of the plaintiff
deposeth and saith. that about four year ago I
known Negro Charles which is plaintiff in this cause
to have work at the : Nuns, or sister of the Town of cahokia
for I waited on him while he was plastering. I also
have helped him in painting and white washing.
and more I recollect that the said plaintiff have
work at the said nuns sixteen days. and during
that time I saw Mr Faunban come to the Nuns
and saw the said charles(plaintiff) working.

François his mark Vaudrie

I, François La croix> a Justice of the peace do hereby certify. that
François Vaudrie the deponent, whose place of residence is
St Clair county in the State of Illinois , was by me sworn to
testify the whole truth of his knowledge touching
the matter in controversy in the cause aforesaid that
deponent was examined and his examination reduced to
writing, and subscribed by said deponent. in my presence
on the thirteenth day of June in the year eighteen
hundred and forty, between the hours of ten oclock in
the forenoon and six oclock of the after noon at the
office of François La croix, in the town of cahokia in
the county of St Clair and State of Illinos

Given and certified the 13th day of June 1840 François La croix
Justice of the Peace

I François La croix a Justice of the peace within
and for the county of St Clair in the State of Illinois
do certify. that in pursuance of the consent of the
parties notice, came before me, at the office of François
La croix in the town of cahokia in the county and state
last aforesaid, François Nadeau , François Demétte
and François Vaudrie who were there by me sworn
and examined, and such examination reduced to writing
and subscribed by them, respectively in my presence
and their said depositions are now herewith return
ed

Given at Cahokia in the county of St Clair
and State of Illinois this 13th day of
June 1840 François La croix
Justice of the peace Fees of the within
$ 10. to 8.18 3/4

Notice was waived by me in taking the
foregoing depositions

Wilson Primm
atty for defdt

State of Illinois
County of St . Clair
ss

It is hereby certified that François L Croxbefore
whom the forgoing depositions were taken was on the this tenth
day of June A D Eighteen hundred and forty an acting
Justice of the Peace within $for said County of St Clair $ still
is an acting Justice of the Peace in $ for said county duly com-
missioned $ qualified and acting as such, that forth
& on one to all his acts as such in all
elsewhere

In Testimony whereof I James M .
Reynolds Clerk of the County Commissioners
in and for St . Clair County
the same being a Court of Record & having a seal
have hereunto subscribed my name and affixed
the seal of office this sixteenth day of
July Anno Domini Eighteen hundred
forty.

J. M . Reynolds
Clk

COUNTY OF ST. LOUIS , SS.
THE STATE OF MISSOURI ,TO James Fontbonne
GREETING:—

You are hereby commanded, that, setting aside all manner of excuse and delay, you appear before our

ST. LOUIS COURT OF COMMON PLEAS, at the City of St. Louis , on the 19th Inst-
then and there to testify and the truth to say in a certain cause pending in said court, wherein
Charles (a man of Colour) is plaintiff and
Peter Verhagen is defendant on the part of the
plaintiff and herein you are in no wise to fail.

WITNESS, JOSEPH W. WALSH, Clerk of our said Court, with the seal
thereof hereto affixed, at office, in the City of St. Louis , this
16th day of August in the
year of our Lord one thousand eight hundred and forty- oneJ. W. Walsh CLERK.

Executed
M. Brotherton Shff

Fee 50 cts

James Fontbonne
vs
Charles (a man of color)
vs
Peter Verhagen

Wit for Plff
James Fonthonne

County Of St. Louis , Ss.
The State Of Missouri ,To James Fontbonne
Greeting:—

You are hereby commanded, that, setting aside all manner of excuse and delay, you appear before our

St. Louis Court of Common Pleas, at the City of St. Louis , on the15th day of December
1841 then and there to testify, and the truth to say in a certain cause pending in said court, wherein
Charles (a man of Color) is plaintiff and
Peter Verhaegen is defendant on the part of the
Plaintiff and herein you are in no wise to fail.

Witness, Joseph W . Walsh , Clerk of our said Court, with the seal
thereof hereto affixed, at office, in the City of St. Louis , this
29th day of October in the
year of our Lord one thousand eight hundred and forty-one.J. W. Walsh Clerk.

No. 75. A Novr: Term 1841

Charles a man of Color
vs
Peter Verhaegen
Spa

Summon for Plff James Fontbonne 15th December

Writ executed, there being no Court

M Brotherton Sheriff

County Of St. Louis , Ss.
The State Of Missouri ,To James Fontbonne
Greeting:—

You are hereby commanded, that, setting aside all manner of excuse and delay, you appear before our

St. Louis Court of Common Pleas, at the City of St. Louis , on the17th day of February
1842. then and there to testify and the truth to say in a certain cause pending in said court, wherein
Charles (a man of color) is plaintiff and
Peter Verhaegen is defendant on the part of the
plaintiff and herein you are in no wise to fail.

Witness, Joseph W . Walsh , Clerk of our said Court, with the seal
thereof hereto affixed, at office, in the City of St. Louis , this
11th day of January in the
year of our Lord one thousand eight hundred and forty- twoJ. W. Walsh Clerk.

No 75 -A- Feby Term 1842

Charles (a man of Color)
vs
Peter Verhaegen
Spa

Sum: for ptff James Fontbonne

not Found
M Brotherton
Shff

Fee. 12 17th February

County Of St. Louis , Ss.
The State Of Missouri ,To James Fontbonne
Greeting:—

You are hereby commanded, that, setting aside all manner of excuse and delay, you appear before our

St. Louis Court of Common Pleas, at the City of St. Louis , on thethird day of May
1842 then and there to testify and the truth to say in a certain cause pending in said court, wherein
Charles (of Color) is plaintiff and
Peter Verhagen is defendant on the part of the
plff - and herein you are in no wise to fail.

Witness, Joseph W . Walsh , Clerk of our said Court, with the seal
thereof hereto affixed, at office, in the City of St. Louis , this
16th day of april in the
year of our Lord one thousand eight hundred and forty-two.In Walsh Clerk.

no 75 Augt May Term 1842

Charles (of Color)
vs
P. Verhagen

Spa for plff
for 3d May 1842

James Fontbonne This witnesses is a
Vide Pethe and is
material
fuss made about
him last court 19 2.12 1.50 90 471

Excuted
M Brotherton
Shff

Fee .57

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

We command you to attach Peter Fontbonne
if he be found in your County, and him safely keep, so that you have his body before the
Honorable Judge of the St. Louis Court of Common Pleas, at the City of St. Louis , on the sixth
Inst then and there to testify and the truth to say, in a certain cause pending in said
Court, wherein Charles (a man of Colour is plaintiff and
Peter Verhagen is defendant; and, further, to answer
for a contempt by him committed in not attending said Court as witness, although regularly
summoned so to do on the part of the said plaintiff

Witness, Joseph W . Walsh , Clerk of our said Court, with the seal
thereof hereto affixed, at office, in the City of St. Louis , this
third day of May Inst in the
year of our Lord one thousand eight hundred and forty-twoJ. W. Walsh Clerk.

Charles (a man of color)
vs
Peter Verhagen

Attach for Peter

Fonbonne for Friday
next the 6th first

Executed
M. Brotherton
Shff

Fee $ 1.00 Abides suit

If the jury shall believe from the evidence
that petitioner Charles was sick at the time
he went to the state of Illinois and that he went
there for the purpose of recruting his health, then
that does not constitute such
a residence as is contemplated by the ordinace
of 1789 or the Consitution of Illinois .

refused

If the jury believe that the Plaintiff (being a
slave) was sent by his master, living in Missouri , to the
State of Illinois or went there with the Consent of his
master and that with by the or consent of his
master he was employed in painting, plaistering, and white-
washing the House of his master in Illinois remaining there severaldays. he is entitled to his
freedom under the Constitution of that state and this is the
case whether said slave went over and performed said work
voluntarily or not, it all being with by the
and consent of the master

We the Jury find that
the Defendant is guilty
of the trespass in manner and form as the plaintiff has
in his declaration alleged

Richard E Lee .Foreman

In the St Louis Court of
Common Pleas. Term1841.

The defendant in this case, moves
the court to grant him a new trial for the following
reasons:-

The verdict is against law,

The " " " evidence

The " " " law, and evidence.

The court erred in its instruction to the jury.

The court erred in its refusal to instruct the
jury as prayed for on behalf of defendant.

Primm L Taylor for
Defendant.

75 Aug 41

Charles
(a man of color)
vs
Peter Verhagen .

motion for a new
trial.

Primm L Taylor
for defendant.Filed 9th May 1842.J W Walsh clerk

Wm L Kid

Jos. Murphy

Harry W. Chaubey

R.D . Laey

Bacheus n Roberts

Geo L . Eoff

Saml

Wm Mills

Ben F . Buchanan

Charles Engles

Richd E Lee

Robt E Owen

Attention Return