of Color
otherwise called

Plff
vs
.
Deft.

In St. Louis Circuit
Court
April Term
1855 St Louis County SS.

The plaintiff
states that her name is Mary
though she is also called &
by the name of Mary Davis -
that she was formerly owned
& claimed by John T . Moore in
the County of St Louis - that said
Moore by his deed in writing
duly executed & proved &
date January 14 1852manumitted
& set free the plaintiff & by that
deed of manumission she became
& is entitled to her freedom - A
duly certified copy of said deed
is filed herewith marked

the plaintiff says that she is held
in slavery & deprived of her
freedom by the Defendant Samuel
B. Bellis in the Court of St Louis

The plaintiff says that she is poor
& wholly destitute of money or property
& she asks that she may be allowed
to sue as a poor personto Establish
her right to freedom

Jeremiah F . Young Mary X her mark

Mary of Color the plaintiff in
the above Entitled cause being
duly Sworn says that the foregoing
petition & the matters therein as stated
are true

Subscribed & sworn
to before the this
2nd day of March 1855 Mary X her mark

In witness whereof I have hereto
set my hand & notarial seal
the day & year above written.

Jeremiah F . Young
Notary Public

On the of the foregoing
petition & in considering the
same it is ordered by the
Court -

First that the said Mary is allowed
to sue for her freedom

Second that she have reasonable
liberty to attend her Counsel
& the Court as occasionmay
require & that she be not
removed out of the Jurisdiction
of this Court & that she be
not subjected to any severity
on account of her applica
tion for freedom aforesaid

Wm . J. Hammond Clk

In St. Louis Circuit
Court

Mary of color other
wise called Meary Davis
vs
Samuel B. Bellis

Petition for freedom

Filed Mch 3rd 1855 Wm. J.Hammond Clk

Know all men by these presents that where as John
T. Moore purchased at Constables Sale of Samuel
Morrawell a Negro woman slave for life and now
owns said slave by Bill of Sale dated the 3d
day of September in the Year one thousand eight
hundred and fifty, which said Slave is described
as being about thirty six years of age, and about five
feet five inches in height of very dark complexion and
known by the name of and called Mary . Now
therefore I John T. Moore of the City of St Louis and
State of Missouri does hereby emanacipate and set
free said Negro woman slave and declare her
now and hereafter discharged from all servitude and
as free as if she had been so born

In witness whereof I have hereunto set my hand and seal
this 14th day of January in the Year one thousand
Eight hudred and fifty two. John J.Morre Executed in the presence of James McMartin
L.C.Parsons

In the matter of the emancipation of Mary a colored person
State of Missouri SS.
County of St Louis

Be it remembered that on this
26th day of February 1855. In Open Court it was pro
ved by the testimony of Logan Steeper, John B .
& John M Constable witnesses to the satisfaction
of the Court that the within and foregoing deed
of Emancipation was signed and duly executed
by John T. Moore whose name appears subscri
bed to said deed as a party thereto and it was also
proved to the satisfaction of the Court that
James McMartin and L.C.Parsons whose names
appear on said deed as subscribing witnesses

to the occasion thereof are not within the
Jurisdiction of this Court

In Testimony whereof I hereto set
my hand and affix the seal of said Court
at office in the City of St Louis the day and
year last aforesaid Wm J. Hammond Clk

State of Missouri
County of St. Louis
ss

I William J .
Hammond Clerk of said Court the said Circuit
Court within and for the County aforesaid certify
the foregoing to be a true and correct copy
of the deed of Emancipation from John T Moore
to Mary as fully as the same remains
of Record in my Office

In Testimony whereof I hereto set
my hand and affix the seal of
said Court, at Office in the
City of St Louis this TwentyEighth
day of February Eighteen hundred
and fifty five Wm. J. Hammond Clk

(A)

John T Moore
To.
Mary (Negro)

Cert. Copy deedEman
for Jno M . Atty $ 2.00

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

We command you to summon Samuel B Bellis
to appear
before the Judge of our Circuit Court , on the first day of the
next term thereof, to be held in the City of St. Louis , within and
for the County of St. Louis , on the Third Monday of
April next then and there to answer the complaint of
Mary of color otherwise Called Mary Davis
as set forth in the annexed petition:
and have you then and there this writ.

Witness, William J. Hammond , Clerk of said
Court, with the seal hereto affixed, at office,
in the City of St Louis , this 3rd
day of March in the year of our
Lord eighteen hundred and fifty five Wm J. Hammond Clerk.

I acknowledge myself bound for all Costs that may accrue in the case of
against

Witness, my hand and seal at St. Louis , this day of day of
185.

April T 1855 filed 24 p 562 Oct T. 55CntdbyConsent23 p 283
Mch T '56 Contd 25 p 379 Oct T. 56 Nov 12 Jurywaived,sub & Judges of freedom under
stipulationcosts of plff 2 p 52

No 96 St. Louis Circuit Court .
April Term, 1855

of color Otherwisecal
led Marry
vs

Summons

Pet for freedom

on of the foregoing petition & in consid
ering the sameit is ordered by the Court
First that the said Mary is allowed to sue for
her freedom, Second that she have reason
able liberty to attend her Counsel & the
court as occasion may required & that she
be not removed out of the Jurisdiction
of this Court & that she be not subjected
to any severity on account of her ap
plication for freedom aforesaid
a true copy attest Wm . J. Hammond clk

& attos.Issued 3rd of March 1855 Wm J. Hammond Clerk. v Security for Costs
3 1/2 by Plff
Copies due 50 cents

Executed this writ in the County of St Louis on the 3d day
of March 1855 by delivering a copy of the same & petiti
on as furnished by the clerk to Samuel B. Bellis
the within named defendant.

Turner Maddox . Sheriff
By J.S .Wilkinsdepty fee $ 1.00

State of Missouri
Saint Louis County
In the St Louis Circuit Court To April Term 1855

of Color
otherwise

vs

Defendant answers
and denies that
Plaintiff was
formerly owned
and claimed by
John T Moore in the County of St Louis
as alleged in the Petition. Defendant
further denies that said Moore ever
executed a Deed manumitting and
setting free the Plaintiff as set forth in
said Petition and Defendant believes the
Deed a copy of which is filed with the
Petition marked exhibit A to be a person
Defendant admits that he claims the
Plaintiff to be his slave and avows that
she is his slave by virtue of a purchase
from William H. Heath made some time in
the year 1854. Defendant further saith
that he hath not at the time of filing
his answer hereto the Bill of Sale from
said Heath to him of said Plaintiff
nor is the same recorded but he can
procure the original - Defendant
prays Judgement and for
his costs and charges

J.B. Thompson Defts atty

State of Missouri
Saint Louis County

Personally appeared Ruuben Bartlett
who being duly sworn makes oath and
says that he believes the above answer
and the matters there in as stated are true
sworn to 21st
April 1855

R . Bartlett C. W Kicks Clk Court Common Pleas

In Circuit Court

of color
vs

answer of Deft
Thompson

Filed April 21st 1855 Wm J. Hammond Clk

This deed made this 18th day
of October A.D. 1855 by Samuel
B. Bellis of St. Louis Missouri
, that in consideration
of eighty Dollars agreed to be
paid by Mary a woman
of color of large size &
aged about thirty six years,
I do hereby manumit &
set free said Mary . &
do hereby release her
forever fromservitude

This deed however is upon
condition that said Mary is
to pay the said sum of Eighty
dollars in sums of three
dollars per week until
the whole sum is paid &
in case she neglects or refuses
to pay said three in due man
ner aforesaid this deed shall
be void- It is further agreed
that the suit of said Mary for
freedom against me now
pending in the St. Louis Circuit
Court shall stand continued
from term to term until
the said sum of Eighty dollars
shall be paid & when that
is done judgement may
be Entered in said suit
for said Mary , but she
shall pay all the costs
of said suit-

In witness whereof I have
hereto set my hand & seal
this 18th day of October 1855
In presence of

Samuel B Bellis Witnesses Jeremiah F . Young John M .

Samuel B. Bellis
To
Mary of color

Deed & agreement

Filed Nov 30. 1855 Wm J. Hammond Clk