No 123
St. Louis Circuit Court
July Term 1840.
friend)
vs
Barry
Petition
Filed in open court Sept: 1 1840.
Jn. Ruland Clerk
of petitioner granted - and she to the case of Bk 11 225
State of Missouri
County of St Louis
ss.
In St Louis Circuit Court , Nov Term 1840
her next friend false imprisonment action of
vs
Beny Meachum
Petition to
Meachum , as prayed.
To the honourable Luke E Lawless
Judge of the Saint Louis Circuit Court
The humble petition of Brunetta
Barnes by Peter Charleville her next friend, resepectfully showeth to your honour. That the
applied for and obtained purmission from
your honour heretofore to bring an action of
and false imprisonment against
Beny Meachum who unlawfully detains
her in slavery. and that the has in
of that permission instituted said against
said Meachum , That she is a female of the age
of fifteen year as nearly as she can state. That
said Meachum is in the of sending her to
sell and deliver milk on board the several
lying at St Louis . That she
is daily sent there her with milk, and that
the hour at which she is sent is at daybreak
in the morning. long before it is fully light
That she is exposed on these occasions to insults
of the character from various members of
the of different . That said Meachum
holds in his service other persons (among them her
) who areis more fit than herself for such .
That she has to said Meachum
through Peter Charleville , a written request
in the most respectful language,
the she suffers from the employment
aforesaid, and the discontinance
of such employment in future and that
said Meachum has continued to send
her as before to said steamboats, and her declared
his determination to pay no regard to her request
Your petitioner respectfully shows to your
honour that the hardship of which she complains
is of a nature to her, and that this application
to your honour for relief is not made in a
of or through the wish to
give annoyance or occasion in convenience to said
Meachum because she is at present exposed to
insult, which the said Meachum
space her without any to himself-
In consideration whereof she your petitioner
humbly that your honour may make
an order to the effect that the said Meachum
shall discontinue sending her on board the
steamboats aforesaid for the aforesaid
or upon any other protect whatsoever and that
your honour will grant to her & further
relief as the case may
in your honours action seem to require
and in duty bound your petitioner
shall ever pray
Thos J for
of
Barner, by
Peter Charleville her next
friend
vs
Beny Meachum
& false
imprisonment
County of St Louis SsThe State of Missouri To the Sheriff of the County of St Louis
greeting.
Whereas it having represented to our Honorable
Circuit Court now in Session in the City of St Louis by the petition
of Barnes a female of about the age of fifteen years
who has been heretofore permitted to bring suit (by her next friend,
Peter ) against Berry that she
is subjected by the said to gross insults, as in
her petition stated. You are therefore commanded
to bring the said Barness into our said court
and also to summon the said Berry that
he be and appear before our said court on Wednesday the
second day of September instant at ten o'clock A.M.
and there to answer the Petition ofsaid Brunrtta
Barnes hereto - and have you then and there
this writ your return how you shall
execute the same.
Witness John Ruland , Clerk of
our said Court at office in the City
of St Louis this first day of September
in the year four Lord
one thousand eight hundred and
forty.
Jn. Ruland Clerk
Excuted this writ and have
the body of the within
Barnes in court at the time and placeed
by this writ I am commanded
and for the by reasing this writ and
petition to the within named Berry
= St Louis September
2nd 1840
Sheriff $ 2.00