To the honourable Luke E. Lawless . Judge of the
St. Louis County Circuit court.

The petition of Archibald Charleville Barnes of
St. Louis County and State of Missouri . who is an infant
within the age of twenty one years to wit the age of
sixteen years, and who appears by his next friend
Peter Charleville respectfully represents. That
your petitioner is a person of colour, and the
son of parents who were at the time of his birth
and still are, free. That your petitioner is un
lawfully restrained of his freedom and held
in confinement by a certain Berry Mitchell
Meachum a man of colour residing in St. Louis Missouri
who claims your petitioner as his slave. Your
petitioner shows to your honour that the said
Mitchell Meachum does treat the your petitioner with
great inhumanity harshness and severity:
and that, your petitioner fears that the
said Mitchell Meachum will remove him unjustly and
unlawfully beyond the limits of the State
of Missouri (as he has aften made threats of
doing) in consequence of this application
to your honour. Your petitioner avers that,
he is now free: that he was born free: and
that by no act of his own, nor by any pro-
ceedings of any anthoritative tribunal has
his right to his freedom been forfeited: but
that he is forcibly abridged of the same
by the said Mitchell Meachum as aforesaid.

In consideration whereof may it please your
honour to grant unto your petitioner permission
to sue for his freedom as a poor person: and further
may it please your honour to grant a warrant dire
cected to the Sheriff of St Louis County, commanding
him to seize the your petitioner & have him before this
court, and to summon the said Mitchell Meachum or other
person in whose hands the said petitioner may
be found. to appear before this court on a
day and at a place to be therein specified and
receive such order as the court may make in the
premises: and give security to abide by the same
And that it may please your honour to
grant unto your petitioner such other & fur-
ther relief as to your honour may seem fit and
the nature of the case may require and as in
duty &c.

J. J. Gantt . for heto

State of Missouri
County of St. Louis In St. Louis Circuit Court
July Term 1840-

On this thirtieth day of July - in the year
eighteen hundred and forty comes into open
court Leah Charleville
-
and being duly sworn deposeth and saith
that the facts set forth in the above petition
are within her knowledge and that they
are true as therein stated -

Sworn & Subscribed to this
thirtieth day of July -
in the year eighteen hundred & forty Leah her mark Charleville Jn Ruland Clerk Ct Ct

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

Ordered by the court that the above mention
ed petitioner be allowed to sue as a poor person
to establish his freedom and that Thos. T. Gantt
and George F. Strother . be assigned as counsel for
said petitioner in this behalf. and that the
petitioner have reasonable liberty to attend his counsel and the court as occasion may re
quire, and that said petitioner be not re-
moved out of the jurisdiction of this court and

that he be not removied subjected to any
severity on account of this application
for freedom

L E Lawless

Archibald Barnes
by Peter Charleville his
next friend
vs
Berry Mitchell
Petition for freedom

Thos . T .. Gantt .
for

No 41. St. Louis Circuit Court
November Term 1840.

Archibald Barnes (by next
friend, Peter Charleville ,
vs warrant & summons
Berry Meachum
Pet: for Freedom

Filed July 30th 1840 Jn. Ruland Clerk

County of St. Louis .
The State of Missouri To the Sheriff of the County of St. Louis Greetings

Whereas it has been represented to the Honorable
Judge of our Circuit Court for the County of St. Louis
now in session by the petition of Archibald Barnes
an infant within the age of twenty one years, to wit:
the age of sixteen years, who appears by hisnext
friend Peter Charleville , that he is unlawfully
restrained of his freedom by a certain Berry
Meachum . You are therefore hereby commanded
to seize the said Archibald Barnes the petitioner
wherever her may be found and bring him before
our said Court forthwith, and also that you summon
the said Berry Meachum , if he be found in your
county, that he be and appear before our said Court
now sitting in the city of St. Louis . forthwith - then
and there to answer unto the petition of said
Archibald Barnes who sues by his next friend
Peter Charleville as set forth in the said petition
hereto annexed- and have you then there this writ
with your return thereon now you shall execute
the same.

Witness John Ruland Clerk of our
said Court, with the seal thereof
hereto annexed, at office in the
City of St. Louis this thirtieth day
of July eighteen hundred and forty. Jn. Ruland Clerk

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

Ordered by the court that the above
mentioned petitioner be allowed to sue as a poor per-
son to establish his freedom. and that Thos. T. Gantt and
George F. Strother be assigned as counsel for said
Petitioner in this behalf: and that the petitioner
have reasonable liberty to attend his counsel and
the court as occasion may require, and that said Pe-
titioner be not removed out of the jurisdiction of this
Court and that he be not subjected to any severity on ac
count of this application for freedom.

L E. Lawless
A true copy of the order
Attest, Jn. Ruland Clerk

Executed this writ in the County of St Louis
and have now the body of Archibald
Barnes in open court 1st august 1840
Berry Meachum not found in
my county

Marshall Brotherton
Shff
by Wm McKnight Dept Service 1 non est .50 1.50

Know all were by there presents that we
John Berry Meachum as principal and
Geroge - as security are indebted unto
the State of Missouri in the sum of seven
hundred fifty dollars for the payment whereof
we ourselves our executors &adminis-
trators firmly by these presents. Sealed with
our seals and dated this 1st August eighteen
hundred forty.

The condition of this recognizance is such
that whereas Archibald Barnes has filed his petition
in the St Louis Circuit Court & procured an
order for leave to sue said Meachum for free-
dom; now if the said archibald, the petitioner, shall
during the pending of the suit, have reasonable
liberty of attending his counsel and the Court
and shall not be removed out of the jurisdiction
of said Court, and shall not be subjected
to any severity on account of his application
for freedom; then this obligation shall be
word else it shall remain in force.

John George

Filed august 1st 1840
Jn Ruland clk

In the St Louis Circuit
Court March Term
1841.

And the said plaintiff as to the first
plea of said defendant and whereof he
hath put himself upon the county
doth the like -

and as to the second plea of said
defendant the said plaintiff says that
he by any thing therein contained
ought not to be barred from having
and maintaining his said action
thereof against him because he says
that at the time of the committing
of the said trespasses in the said declaration
mentioned, plaintiff was
and still is a free person and not
the slave of the defendant as in the
said plea is alleged and this the
said plaintiff prays may be enquired
of by the County.

Thos T. Gantt
atty for plff

Archibald Barnes (by
next friend)
vs
John B . Meachum

Replication to pleas

Thos . Gantt
atty for plffFiled March 9th 1841 Jn Ruland clerk

St. Louis Circuit Court .

Take notice that on the tenth day of may in the
year of our Lord one thousand eight hundred and thirtyforty one, between the hours of
eight, in the forenoon and six in the afternoon, of that day, at
the office of John QuinlandEsq. at Bethel
Clermont County in the State of Ohio
depositions will be taken by the undersigned, to be read on the trial of the above entitled case, on
behalf of the plaintiff-; 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,
until completed.

To the above defendant Thos . Gantt
atty for plff

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 Ohio
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 Archibald Barnes 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 said Archibald Barnes is
plaintiff and John B . Meachum is
defendant on the part of the Plff. 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 26th
day of March in the year of our Lord, one
thousand eight hundred and thirtyforty one. Jn. Ruland Clerk C.C.

Deposi

Archibald Barnes
vs
John B Meachum
Dedimus for plff.

of his family and with that understanding they
all left the house of deponant- Leah appeared
to be from twenty to twenty five years of age- She
had a Mulatto male child with her from two to
three years old and was said to be in an advanced
state of pregnancy- deponant thinks that Leah
was of light complexion but does not distinvtly
Remember- deponant heared that Arthur Mitchel
afterwords moved to the state of Missouri and took Leah
and her children with him- but has no personal
knowledged of the fact and further this deponant
saith not

Jesse R . Grant

I John Quinlan a Justice of the peace in and for
the township of Tate in the County of Clermont Ohio
do hereby certify that the above named Jesse R. Grant
were by me first duly sworn to testify the whole
truth and nothing but the truth, and that the foregoing
deposition by him subscribed wore Reduced to
writing by me and were taken at the time and place
Specified in the inclosed notice —

In testimony whereof I have hereunto set my hand
this tenth day of May in the year 1841

John Quinlan J.P.

The State of Ohio
Clermont County

S. S . I. Morris Clerk of the Court
of Common pleas in and for the County
and State aforesaid do hereby Certify that
John Quinlan Esquire before whom
the foregoing deposition of Jesse R. Grant
appears to have been sworn to & Subscribed
was at the time of taking and certifying said deposition and
now is an acting justice of the peace in and for said
County of Clermont duly commissioned and qualified
and full faith and credit are due and ought to be
given to all his official acts as such in all Courts of
record as well as elsewhere and that his signature
thereto written is genuine In Testimony whereof I
have hereunto set my hand and affixed the seal of
said Court of Common pleas at Batavia in
County this 12th day of May A.D. 1841.

Morris clk Fee for County seal 50 cts

Depositions of
Jesse R . Grant

Opened & filed May 20 1841
Jn Ruland Clerk

Archibald Barnes
vs
John B Meachum
Dep for plff