State of Missouri
County of Saint Louis ssIn Saint Louis Circuit Court
November Term 1840
Brunetta Barnes , an infant of colour under the age of
twenty one years to wit of the age of fourteen years, admitted
to the here as a poor person by Peter Charleville her next friend
of Saint Louis and State of Missouri , complains of Berry Meach-
um of the state and county aforesaid of a plea of trespass and
false imprisonment for that the said defendant heretofore
to wit on the first day of January in the year Eighteen hun-
dred and forty, at the county aforesaid, in and upon the
said plaintiff did make an assault: and her the said plaintiff
did then and there beat and evilly treat, and then
and there did imprison, keep, detain confine and hold
the said plaintiff in confinement and slavery: and still
continues to imprison the said plaintiff and to keep detain
and hold her in confinement, and has ever since then im
prisoned the said plaintiff and kept detained and
held her in confinement and slavery to wit at the
county aforesaid, contrary to the laws of the state
and against the will of said plaintiff. And the
aid plaintiff avers that she was, at the time of the
committing of the grievances aforesaid, and before
that time, and has ever since then continued to be
and still is a free person and that the defendant
then and there held, and has ever since continued
to hold, and still holds her the said
plaintiff in slavery to wit at the county afore-
said - and then and there did other wrongs to the
said plaintiff against the peace government &
dignity of the state and contrary to the form of
the statute in such case made & provided. To the
damage of the said plaintiff in the sum of
one thousand dollars and therefore she brings
suit& so forth
Gantt & Strother
for plaintiff
In St. Louis Circuit Court
November Term 1840-
Brunetta Barnes , by
Peter Charleville her next
friend
Trespass and false
imprisonment -
vs
Berry Meachum
Damages $1000
Let a summons issue
Strother
p. q.
County of St. Louis , ss.
The State Of Missouri ,To the Sheriff of St. Louis CountyGreeting:
We command you to Summon Berry Meachum 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 November next, then and there to answer unto Brunetta
Barnes who sues by Peter Charliville her next friend
of a plea of trespass& false imprisonment
to the damage of said plaintiff of one thousand
dollars: And have you then there this writ.
Witness, John Ruland . Clerk of our said Court,
with the seal thereof hereto affixed at office,
City of St. Louis , this Thirty first day of
August 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 12 - Sub & Judgt for plff damages & Judgt of of liberation BK 13
p 326
No. 121
St. Louis Circuit Court
November Term 1840
Brunetta Barnes by Peter
Charleville her next friend
vs
Berry Meachum
Summons
Trespass & false imprisonment
Damages - 1000
Gantt & Strother pqFiled August 31, 1840 John Ruland Clerk Free
Executed this writ in the County of
St Louis by offering to read it and the
declaration to Berry Meachum
the 1st day of September 1840. which
he refused to hear
Service 1.00
Marshall Brotherton Sheriff
By W. S. McKnight Depty
Know all were by there presents that we
John Berry Meachum as principle and Geroge
- as security are indebted unto
the State of Missouri in the sum of seven
hundred fifty dollars for the payment whereof
we bind ourselves our executors andad-
ministrators by these presents. Sealed
with our seals and dated this first day of
August eighteen
hundred forty.
The condition of this recognizance is such
that whereas Brunetta Barnes has filed her
petition in the St Louis Circuit Court &
procured an order to sue said Meachum for
freedom: Now if the said Brunetta
the petitioner, shall during the pendency of the
suit have resonable liberty of attending her
counsel and the Court and shall not be
removed out of the judiction ofsaid court,
and shall not be subjected to any seventy on
account of her application for freedom; then
this obligation shall be else it shall
remain in force.
John geroge
Filed august 1st 1840
Jn Ruland Clk
vs.
J.B . Meachum
St. Louis Circuit Court Nov. T. 1840
And the defendant
by his attorney comes and defends the
wrong & injury when &c. and says he
is not guilty of said supposedtrespas-
ses wherewith he is charged in man-
ner and form as in the declara
tion set forth , and of this be
puts himself upon the country &c.
And for further plea he says that
the said plaintiff was at the times when ,
the slave of him the defendant & this he is
ready to verify wherefore he prays
&c.
Spalding &
attys for dft
St. Louis Circuit Court
Brunetta Barnes
vs.
Meachum
pleas
Spalding &
Filed November 17th 1840 Jn Ruland Clerk
(by her next friend)
vs
John Berry Meachum
In the St Louis Circuit Court
March Term 1841
Replication
And the said plaintiff as to
the first plea of the said de
fendant by him in this behalf pleaded & whereof he
hath put himself upon the Country doth the like
And as to the second plea of said defendant
the plaintiff says that the by reason of any
thing in the said plea contained ought not to he
barred from having and maintaining her said
action thereof against said defendant, because
She says that at the time of the commit
ting of the trespass in the said declaration men
tioned, plaintiff was and still is a free person
and not the slave of defendant as in the said
plea is alleged, and this the said plaintiff
prays may be enquired of by the country.
Thomas
Atty for plff
Brunetta Barnes (by
next friend)
vs
John B . Meachum
Replication to pleas
Thos .
atty for plttFiled March 9th 1861 Jn Ruland Clerk