To the Honorable Bryan Mullanply Judge, of the
Circuit Court of St. Louis County.
The petition of
Brown a man of color respectfully represents
That he is deserving of
instituting, a suit against-one William C Anderson ,
in order to establish, the right, of your petitioner to
freedom that, his Claim that, is founded, upon the
following grounds to wit. That, Henry Brown who had
formerly owned, your petitioner for some, six or eight years
prior, to the first of May last & during the time, he so
owned your petitioner hired, out your, petitioner to
work in the County , of St . Claire , State of Illinois that, under virtue, of such hiring petitioner, petitioner
did, work in said St . Claire , County State of Illinois , at
various times between the years 1839. & 1841. for several,
months at a time: Your petitioner further represents,
that somewhere, about the first, of May last, he,
was purchased from, Henry Brown his siad former master, by the said William & that he
is now by the said held in slavery,
Your petitioner therefore prays, that
he may have, leave to sue, as a poor person, in order,
to establish, his right to freedom.
Squire his X mark Brown
State of Missouri
County & St. Louis
p: Squire, Brown the above,,
named being duly, sworn deposes,
says, that the facts, set forth, in the above petition,
are true, to the knowledge of this
Squire his Xmark Brown
Sworn to this 26th day of
June, 1841 before me,
. ,
Justice, of the peace
State of Missouri , County of St. Louis
Be, it remembered that the within
named Squire, Brown is hereby allowed
to sue, as a poor, person and John
Davis & Benjamin B Dayten Esqres, are
assigned as his counsel and it is hereby
ordered, that said Brown , have reasonable
liberty to attend, his counsel
& the Court as occasion may require that he be not, not removed out, of the,
Juisdiction of the court St. Louis
Circuit Court , and that he, be not
subjected to any severity, on account of
his application for freedom. In
whereof witness, my hand this 28 June 1841
By, an honorable judge, of
the 8th of
St. Louis Circuit Court
July Term 1841
St. Louis County ss:
Squire, Brown plaintiff in this
suit by his attorneys, complains of William defendant of a plea of tresspass,.
For that the said defendant heretofore, to to wit on, the
first-day of June on the year of our Lord, one thousand
eight hundred forty one In, the City of St. Louis
at said county, with force and arms, made an assault,
on said, plaintiff & then others beat
bruised and ill treated, him then and there, imprisoned
him kept, him in prison without any reasonable or,
probable cause whatever for a long, space of time,
to wit for the space, of ten days then following
contrary, to the laws of, the State of Missouri
against the will of the said, plaintiff and other
to the said, plaintiff then there, did
against, the peace of the State of Missouri to,
the damage of the said plaintiff of five hundred
dollars.
And, the said plaintiff that
before at, the time of the of the greivances, aforesaid by the said defendant he the,
said plaintiff was and still, is a free person &
that the said defendant, held and still, holds him,
in slavery. Therefore he
Dayten , & Davis
Plff attys,
St. Louis Circuit Court
Squire, Brownvs
William C Andersen
in tresspass for false,
imprisonment
Damages $ 500,
Issue, Summons
Dayten , & Davis
Plff attys,
County of St. Louis , ss.The State Of Missouri ,To the Sheriff of St. Louis County-Greeting:
We command you to summon William C Andersen
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, then and there to answer unto Squire
Brown 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 first day of
July in the year of our Lord eighteen
hundred and forty one John Ruland Clerk.
State of Missouri
County of St. Louis
at Chambers
Be it remembered that the
within named Squire Brown is hereby allowed to sue, as
a poor, person, and John Davis & Benamin B Dayton , are assigned as his Counsel, and it is hereby
ordered that said Brown have reasonable liberty to attend,
his counsel & the court as occasion may require: that he
be not removed out of the jurisdiction of the Court in, the
St. Louis Circuit Court , and that he be not
subjected to any severity on account of his application
for freedom. In testimony whereof witness my hand
this 28 June 1841.
Bryan Judge of
the 8th Cir. of Ms.
Bk 13 p 261 Dismissed (no body's costs) Bk 14 p 338. Squire says he
will pay the cost.
No. 119,
St. Louis Circuit Court
July Term 1841
vs
Summons
William C Anderson
Suit, for freedom
Damages : 500
Dayton & Davis , for plff
Filed 1st July 1841
John Ruland Clk
Executed this writ in the county of St. Louis on
the 3rd day of July 1841 by offering to read it and
the declaration to, William C Anderson the defendant
all of which he refused to hear
Marshall Brotherton Sheriff by Benjamin Lacy ,Dpt. Service $ 1.00
man of color
vs
Wm C Anderson ,
In the St Louis Circuit Court
July Term AD 1841
and, the said defendant, by
his attorney and signing
when says, that he is not guilty, of the said supposed, greivances aforesaid to his, charge, or any, or either
of them,, or any part, thereof, in manner form the
said plaintiff with, alon thereof complained against
him. And of this, the said defendant puts, himself
upon the county,
for
No. 119
St Louis Circuit Court
July Term 1841
of colour
vs
Wm C, Anderson
Plea not guilty,
m. P.D .
Filed July 20 1841
Jn Ruland Clerk
County of St. Louis , ss.The State Of Missouri ,To William Moore Patrick Quinn ,, Thomas Glenn , John
Sterling William Wiggins ,
Greeting:
You are hereby commanded, that setting aside all manner of excuse and delay, you appear
before the Judge of our Circuit Court , on the twenty first day of July instant
at the City of St. Louis , then and there to
testify, and the truth to say in a certain matter of controversy now pending in our said Court,
wherein Squire, Brown is
plaintiff and William C Anderson is
defendant on the part of the plaintiff
and herein you are in no, wise to fail.
Witness, John Ruland , Clerk of our said Court, with the seal thereof hereto affixed, at office, in the City of St. Louis ,
this Sixteenth day of July in
the year of our Lord one thousand eight hundred and forty two Jn. Ruland Clerk, C.C.
Circuit Court ,
Squire, Brownvs
Wm, C Anderson ,
Sub for plff.
William Moore ,
Patrick Quinn
Thos Thos Glenn ,
John Sternley
William Wiggins ,
July 21st
Executed
M.Brotherton
Shff
Fee #1.37
County of St. Louis , ss.The State Of Missouri ,To Thomas Bamber
Greeting:
You are hereby commanded, that setting aside all of manner excuse and delay, you appear
before the Judge of our Circuit Court , on the thirty first inst
at the City of St. Louis , then and there to
testify, and the truth to say in a certain matter of controversy now pending in our said Court, wherein Squire, Brown is
plaintiff and Wm, C Anderson is
defendant on the part of the defendant
and herein you are in no wise to fail.
Witness, John Ruland , Clerk of our said Court, with
the seal thereof hereto affixed, at office, in the City of St .
Louis , this 23rd day of October
in the year of our Lord one thousand eight hundred and forty three
Jn. Ruland Clerk, C.C.
find him at
of &
vs
Wm, C. Anderson ,
Wis, for Deft,
Thomas Bamber
for 3.
Executer
William
fee $0.50
County of St. Louis , ss.The State Of Missouri ,To Wm, C Anderson Jr ,
Greeting:
You are hereby commanded, that setting aside all manner of excuse and delay, you appear
before the Judge of our Circuit Court , on the Thirty day of November
1843 at the City of St. Louis , then and there to
testify, and the truth to say in a certain matter of controversy now pending in our said Court,
wherein Squire Brown
plaintiff and William C. Anderson Sen, is
defendant on the part of the Defendant
and herein you are in no wise to fail.
Witness, John Ruland , Clerk of our said Court, with
the seal thereof hereto affixed, at office, in the City of St .
Louis , this 30th day of October
in the year of our Lord one thousand eight hundred and
forty-three.
Jn. Ruland Clerk C. C.
vs
Wm, C. Anderson Sen,
Subp,
writ
C. Anderson Jr ,
To appear 1843
30 Nov.
This writ not exec in,
consequence of the adjournment
of Courts
Milburn Shff
By Dave Murphy Dpty,
County of St. Louis , ss.The State Of Missouri ,To Eli , Anderson
Greeting:
You are hereby commanded, that setting aside all manner of excuse and delay you appear
before the Judge of our Circuit Court , on the Eleventh day of January instant,
at the City of St. Louis , then and there to
testify, and the truth to say in a certain matter of controversy now pending in our said Court,
wherein Squire Brown is
plaintiff and William C. Anderson is
defendant on the part of the defendant
and herein you are in no wise to fail.
Witnes, John Ruland , Clerk of our said Court, with
the seal thereof hereto affixed, at office, in the City of St .
Louis , this ninth day of January
in the year of our Lord one thousand eight hundred and
forty-four
John Ruland Clerk C. C.
Executed the 11th January
1844.
Wm. Milburn Shff
By & Dave Murphy ,
Fees $ 50 cents
In Circuit Court
Squire Brownvs
Wm. C. Anderson
Subpoena,
Eli Anderson ,, near,
the corner, of Cars and main, ets. for
Jany . 11. for
deft,
County of St. Louis , ss.The State Of Missouri ,To J. J. Wolfock Shaw John Sternley , William
Wiggins ,. Peter abirt. William Denny , Patick Quinn ,
Greeting:
You are hereby commanded, that setting aide all manner of excuse and delay, you appear
before the Judge of our Cicuit Court , on the eleventh day of January instant,
at the City of St. Louis , then and there to
testify, and the truth to say in a certain matter of controversy now pending in our said Court,
wherein Squire Brown is
plaintiff and William C Anderson is
defendant on the part of the plaintiff,
and herein you are in no wise to fail.
Witness, John Ruland , Clerk of our said Court, with
the seal thereof hereto affixed, at office, in the City of St .
Louis , this ninth day of January
in the year of our Lord one thousand eight hundred and
forty-four
Jn. Ruland Clerk C.C.
St. Louis Circuit Court
Squire Brownvs
William C Anderson
JJ Wolfock ,. Shaw ,
John Sternley
William Wiggins ,
on Jerry
Peter Writ.
at St. Louis Brewery
William Denny at
Rooms
Patrick Quinn ,
for plff.
Jan. 11. 1844
Executed the 11th January
1844 John Sternley , not found,
By C. W.
fees$ 3.00non est.13$ 3.13
County of St. Louis , ss.The State Of Missouri ,To JJ Wolfock , Shaw John Sternley William Wiggins ,. Peter . William , Denny
Patrick Quinn ,
Greeting:
You are hereby commanded, that setting aide all manner of excuse and delay, you appear
before the Judge of our Cicuit Court , on the Sixteenth day of January
at the City of St. Louis , then and there to
testify, and the truth to say in a certain matter of controversy now pending in our said Court,
wherein Squire Brown , is
plaintiff and William C Anderson , is
defendant on the part of plaintiff,
and herein you are in no wise to fail.
Witness, John Ruland , Clerk of our said Court, with
the seal thereof hereto affixed, at office, in the City of St .
Louis , this eleventh day of January,
in the year of our Lord one thousand eight hundred and
forty-four
John Ruland Clerk C.C.
Executed the 11th January
1844 John Strong not found, in my County
Wm . Milburn , Shff
By Dave Murphy Dpty,
fees$ 2.50.25$ 2.75
vs
William C Anderson ,
JJ Wolfock ,
Shaw
John Sternly,
William Wiggins ,
William Denny
Patrick Quinn ,
Jan 16
County of St. Louis , ss.The State Of Missouri ,To William C Anderson for Joseph ,. C Conn ,
Greeting:
You are hereby commanded, that setting aside all manner of excuse and delay, you appear
before the Judge of our Circuit Court , on the sixteenth day of January
instant, at the City of St. Louis , then and there to
testtify, and the truth to say in a certain matter of controversy now pending in our said Court,
wherein Squire Brown , is
plaintiff and William , C Anderson is
defendant on the part of the plaintiff,
and herein you are in no wise to fail.
Witness, John Ruland , Clerk of our said Court, with
the seal thereof hereto affixed, at office, in the City of St .
Louis , this fifteenth day of January
in the year of our Lord one thousand eight hundred and
forty-four
John Ruland Clerk C.C.
Executed on J. H .
Milburn Shff
by
fees$ .50.13$ .63
vs
William C Anderson ,
Sub, for
plff.
Wlm, C Anderson Jr ,
Joseph C Conn ,
Jan 16
County of St. Louis , ss.The State Of Missouri ,To Joseph H
Greeting:
You are hereby commanded, that setting aside all manner of excuse and delay, you appear
before the Judge of our Circuit Court , forthwith,
at the City of St. Louis , then and there to
testify, and the truth to say in a certain matter of controversy now pending in our said Court, wherein Squire Brown is
plaintiff and Wm, C Anderson is
defendant on the part of the
and herein you are in no wise to fail.
Witness, John Ruland , Clerk of our said Court, with
the seal thereof hereto affixed, at office, in the City of St .
Louis , this day of Jan
in the year of our Lord one thousand eight hundred and forty four
John Ruland Clerk, C.C.
Exd the,16th January 1841
Wm Milburn Shff,
By
fees 50
vs
Anderson ,
Joseph H . Conn , in -
at &