State of Missouri
County of St. Louis
In the Circuit Court
July Term 1825
Marguirite a free woman of Color, who is
permitted by the Court to sue by her next
friend Peirre Barribeau, as a poor person
for her freedom, by her Attornies Harris Gamble and
M Girk assigned as counsel by the court, com
plains of Peirre of a plea
of said Peirre ,
for to wit, on the first day of January, in the
year of our Lord Eighteen hundred and twenty
five, with force and , at the county of
St. Louis , unlawfully an assault did make in &
upon the body of the said Marguirite , and
then and there heat and ill treated
her the said Marguirite , and then and there im
prisoned him the said Marguirite , and Rept &
detained her in prison without any reasonable
or probable cause whatsoever, against her will
and her Rept and detained
prison, and still & detain her in prison
against the will of the said Marguirite , and
contrary to the laws of their state, and other wrongs
to the said Marguirite then and there did -
against the peace of the state, Wherefore the said
Marguirite says she is greatly injured, and hath
sustained damage to the amount of five hund
red dollars, and therefore she brings her
.
Harris, Gamble and M Girk
for plff
County of Saint Louis
of Missouri To the Sheriff of said county Greetings
command you to summon Peirre that he be and appear
before the Judge of our circuit court at the next term thereof to be held at the City of
St. Louis within and for the county of St. Louis on the fourth monday in July next
then and there to answer unto Marguirite a free woman of color who is permitted
by the court to sue by Peirre her next friend as a poor person of a plea
of trespass to the damage of said plaintiff of five hundred dollars, and have you
then this writ.
Witness Archibald Gamble clerk of our
said court at office this second day of June
1825 Archibald Gamble Clerk
No 26
In the Circt Court
July Term 1825
vs
Peirre Chouteau Sr .
To the Clerk
This is an action of Tres
pass Apaut & Battery &
false imprisonment.
a
for Peirre Sr
Farris ,
Gamble & M Girk
P. Q.Filed 2nd June 1825 Archibald Gamble Clerk
Executed this writ on Peirre June 14th 1825 in the
of St. Louis , by giving the writ & declaration to him to read and his
acknowledging the service thereof.
John K . Walker Sheriff
By Simonds
Service $1.00
ads
a
by her fined
July term 1825
and said attorny
and depends the and when
and day as to the heading
and the may with as in said
declaration mentioned that the
set to have a mention her action they
against him he says that and at
the when see in said declaration mentioned to
at a Louis the was a
in the and of send
the send they and there and
doth save may in his and
which and and the
heating
the said may in said declaration
and this the same is to verify
wherefore he if the said
any to have a maintain her action
again him
ads
filed August 4 1823 A Gamble Clk
friend
vs
Chouteau Leus
And the
said plaintiff that the filed of the
said defendant and the matter and
thing, therein contained, in manner
and form as the same therein
mated and set forth, are not good and
sufficient in land to or
the plaintiff from having and
maintaining her aforesaid action
thereof against the said defendant,
and that the said plaintiff is not
bound by the law of the land to
the some and this the said plaintiff
is ready to verify, wherefore for the
want of a sufficient plea in this
half the said plaintiff judgement
M Girk & Ganis for pltff
vs
Choulean
to plea
filed august 22nd 1825 A Gamble Clk
adsm Marguerele
And the said defendants come
and defend the force and when
and say that they are not guilty of the said
suffered his any of them
in and form as the said
hath above there of complained against
them &c.
And the said Marguerete doth
the like .
Gamble, McGirk
& Harris Atty's
for plff
for defts
Marguerite
Filed August 31st
1825
A Gamble clk
vs
Chantham Sr .
B . In the Circuit Court
of St Louis County, In
vacation, before the
November Term 1825.
And the said Marguerite , by her attornees, as to
the said Plea of the paid Chantham or
by him first above pleaded, as to the said several
trespases in the introductory part of that plea
mentioned, and therein attempted to the
paid, Saith , that she the said Mar
guerite, by reason of any thing by the said
in that plea alledged, ought not to be barred
from having and maintaining her aforesaid
action thereof against him the said , because she saith, that she the said Margui
rite was not, at the time of the committing of
the said several trespases by him the said
Pierre , in her said declaration set forth, nor is she
now a slave, as the said Pierre in his said
Plea hath above alledged, but that she the
said Marguirete was at the time of the com
mitting of the said Several trespases, by the
said Pirre , in her said declaration above
set forth, and is now a free person by and
according to the usages, and laws of the
land, and ought not to be held and detained
as a slave in the and of
the said , nor of any other person by or under
whom the said claim, and this
she the said Marguerite prays may be enqui
red of by the County .
Gamble, M &
Harris , Attys for plff
vs
Repli
cation
Harris Gamble &
, Attys for
plff
filed Oct 31st 1825 A Gamble
clk
vs.
Hortes a witness in
this case, claims 13 days attendance, $ 6.50
miles travel, at five cents per mile,
The above named Margarett being sworn, says, that he was summoned in the
above case, on the part of the Defendent, and attended 13 days at the March term, 1827; and that he has to travel the number of miles above charged, in attending Court; and that he has not claimd attendance as
witness in any other case during the same time.
Sworn to and subscribed, before me, 11th
day of April 1827. Archibald Gamble Clerk.
March Term 1827
Margarettvs.
Chouteace
Margartt Hortez $6.50
Purse
for
following
1
2 Agareement Law
3 That in the matter
of law to the informed in by
the
4 That there upon
the of the
plaintiff and not upon any
to as from other
her
5 The in giving the instructions
prayed for by the plaintiff to this
- Bates
for
vs.
Reasons filed for
new treal Dec.
11th 1826
A G Clk