State of Missouri
St. Louis County

Sarah the mother of the
within named petilioner being
Sworn says thats she has heard the within
Petition read & She that the facts in
the Said Petition stated are true as regards
the birth & residence of said Matilda &
She knows thats said Charles holds
said Matilda in servitude & beleives that
said Matilda is entitled to her freedom
Sworn & Subscribed

1830

Sarah x Mark

I William C Carr Judge of the Circuits Court
for the third Judicial district and state of
Missouri do order that the above named
petitioner Matilda be permitted to sue as a
poor person to Establish her freedom & I do asign
Gustavus a Bird as her counsel to commence
& prosecute her said suit for freedom
and I do moreover order that the said
Matilda shall have reasonable liberty of
attending the court and her counsel when
occasion may require, and that Said
Matilda shall not be taken or removed out of the
Jurisdiction of the court nor be subject to
any severity because of her application
for freedom November 4th 1830

Will : C. Carr
judge of 3 Circuits -

In the Honorable William C Carr Judge
of the Circuits Courts third Judicial Circuits
& State of Missouri

Your Petitioner Matilda an
Infant under twenty one years represents that
She is a person of colour & entitled to her
freedom but She is held in Slavery by Mr
Charles in the County of St louis
your Petitioner was born of a fine woman
by the name of Sarah on the 16th day of
March AD 1810- about four miles from
Edwardsville in the State of Illinois
in which State of Illinois your petitioner has
resideduntillabout Ten months past
when she was brought to the State of Missouri
by Said who now holds your
Petitioner in Slavery and in
St Louis County your Petitioner prays
that she may be permitted to sue as a
poor person to Establish her freedom
that counsels may be asigned to
her that her mother Sarah may
be appointed her focussed to commence
& prosecute her suit & that such
order may be made for her personal
Security as her case requires & the
Law provides

Matilda x Mark

No 58 March term 1821

vs
.

Petition

County of St Louis
The State of Missouri
To the Sheriff of StLouis County Greeting-

We command you to summon Charles that he be and
appear before the Judge of our Circuit Court at the next-
term thereof to be here at the city of StLouis within and
for the county of StLouis on the fourth monday of March
instant- then and there to answer unto Matilda a woman
of color ( who sues by Sarah a free woman, her next friend.)
of a plea of trespapapault& Battery & false impprisonment
to the damage of said plaintiff of three hundred dollars. and
have you then there this writ--

archibald clerk of our
said court at office the 9th day of march 1831 Archibald Gambler

I William C. Carr Judge of the Circuit Court for the third Judi
-cialCircuit district and State of Missouri do order that the above
named petitioner Matilda be permitted to sue as a poor person to
establish her freedom & I do asign Gustavus A Bird as her counsel
to commence and prosecute her said Suit for freedom and I do
moreover order that the said Matilda shall have reasonable liberty
of attending the Court and her counsel when occasion may require
and that said Matilda shall not be taken or removed out of the Juris
-diction of the court nor be subject to any severity because of her appli
-cation for freedom November 4th 1830

Signed - Will .C. Carr
Judge of 3rd. Circuit

not executed for want of time
13th March 1831

No. 58. March Term 1831-
StLouis Circuit Court

woman of
Color by

vs

This is an action of
asault & Battery & false
Imprisonment for
freedom to Damages
$300 The Clerk of
St. Louis Circuit court

summons to

filed9th. March 1831-

State of Missouri Circuit Court third Judicial
March Term 1831

St Louis County fo- Matilda a woman of color who by Sarah
her mother & next friend a free woman of color
complains of Charles St of a plea of
trespap asault & Battery & false imprisonment for
thatwhereashere to on the first day
of October in the year of eighteen hundred &
Thirty at St. Louis said County the said Defendant
the force & arms made an asault upon the
said plaintiff & then & there beat bruised wounded
& ill-treated the said plaintiff & then & there falsely
imprisoned the said plaintiff & kept & detained
the said plaintiff in prison there for a long
space of time to from the day last aforesaid
to the time of the commencement of this said
and the said plaintiff that before & at the
time of the committing the said grievances She
was & still is a free person & the said
Defendant kept & detained & still keeps
& detains her in slavery wherefrom she says
She is greatly injured & hath sustained Damages
to to Three hundred Dollars therefore she sues to

GA Bird for