No 13 St Louis Circuit Court
July Term 1831

Mariguette
vs
Sam T M Kinney

Petition filed
April 7th 1831A gamble clk

petition to sueas
personto
establishtofree
dom

To the honorable the circuit court of the
county of St Louis

Your petitioner Mary
to honorable court, that
she was born in the town of Nashashia in
what is now the state of Illinois about thirty
years since that she was purchased
an infant by our Marshall and taken to St
in what is now the state of Missouri
And she has continued to reside in this state
for that time until now held as a slave, that
about six or seven months since she was
purchased by one Samuel Kinney as your
petitioner who now holds her as a
slave your petitioner is advised that
in the north
she has a claim to and is entitled to the
freedom your petitioner therfore prays that she
may be permitted to institute suit to establish
her right to freedom and the such orders may be
had in the as the law and

Sworn to   subscribed
before me this 17th of April
1831 A gamble Clerk Mariguette her mark

St Louis Circuit Court March Term 1831Thursday 7th April 1831

George T Strother presents the petition of
Mariguette a woman of color praying that she may be permitted
to institute suit against Samuel W Kinney for Establishing
her right to freedom and that she may be permitted to institute
suit against Samuel W Kinney for Establishing her right to
freedom and that she may be permitted to sue as a poor person
thereupon the court permit the said Mariguette to sue as aforesaid
and direct that an action of assault and Battery and false imprisonment
be brought in the name of the said Marguette and assign
George F Strother as her counsel and it is ordered by the court that
the said Samuel W Kinney permit the said Mariguette to have
a reasonable liberty of attending her counsel and the court when
occasion may require it and that the said petitioner shall not
be taken or removed out of the Jurisdiction of this Court or be
subject to any severity of treatment on account of her said
application for freedom

A True copy of the order Archibald Gamble Clerk

No 13 Saint Louis Circuit Court
July Term 1831

This is an action of assault  
battery and false imprisonment
for freedom The Clerk will please
issue a Summons

Filed 12th April 1831 Archibald Gamble Clerk

Served this writ by reading the declaration
  writ to Samuel F M Kinney on the 14th
day of April 1831. served the
the order at of the Circuit Court
a copy of which is endorsed on the declaration, my reading it to the said M . Kinney

John K . Walker Service of $ 1.00 of order .50 $1.50

St Louis Circuit Court July Term 1831
St Louis County of Wit;

Mariguette who sues by permission of the Court
Complains of Samuel W Kinney of a plea of trespass. For and
that the said Samuel W Kinney on the first day of February
in the year 1831 with force and arms made an assault upon the
said Mariguette to wit at the County of St Louis and then and
there struck and gave the said Mariguette a great many violent
blows and strokes and then and there imprisoned the said
Mariguette and kept and detained her in prison there without
any reasonable or probable cause whatsoever for a long space
of time to wit for the space of ten weeks then next following
contrary to law and against the will of the said Mariguette
whereby she the said Mariguette was then and there not only
greatly hurt and wounded but was also thereby then and there greatly
injured in her circumstances to wit at St Louis aforesaid and the said
Mariguette avers that before and at the time of committing the
grievences aforesaid to wit at the county of St Louis aforesaid
then was and still is a free person and the defendants Samuel
W Kinney   Charles Wahrensdorff
then held and detained her and still hold (and detain)
her in slavery and other wrongs to the said Mariguette then
and there did against the peace of the State and to the damage
of the plaintiff Five Hundred dollars and therefore the brings
her suit

Shother V.2..

I have copied the original declaration as well as I could make it out the same not being made
out as required by Rule of court and being also very badly written

The State of Missouri
County of St Louis ssTo the Sheriff of the County of Saint Louis
Greetings

We command you to Summon Samuel W Kinney that he be
and appear before the Judge of our Circuit Court at the next July
Term thereof to be held at the City of St Louis within and for the county
of Saint Louis on the Fourth Monday of July next then and there to answer
unto Mariguette of a plea of trespass to the damage of the plaintiff
Five Hundred dollars and have you then there this writ

Witness Archiblad Gamble Clerk of our said
Court at Office this twelfth day of April in
the year of Our Lord One thousand Eight
Hundred and thirty one Archibald Gamble Clerk

No 13 July Term 1831

This is an action of
assault and battery
and false imprisonment for freedom on the
clerk will issue a
summons

p.q.

St Louis Circuit Court July
term 1831

St Louis county to wit Mary guette
who sues by of the court complains of Samuel L McKinney of
a plea of trespass for that the said Samuel
M Kinney on the first day of February
in the year 1831 with force and orders made
an assaultupon the said Mary guette
to wit at the county of St Louis and
then and there and gave the said
Mary guette a great many violentblows
and strokes and then and there imprisoned
the said Mary guette and left and detained
her in prison there without
any reasonableorprobable cause whatsover
for a long space of time to wit for the space
of ten weeks then next following contrary
to law and against the will of
the said Mary guettewhereby she the
said Mary guette was then and there not only
greatlybeatand wounded but was also
then and theregreatlyinjured in her circumstances
to wit at St Louis aforesaid and the
said Mary guetteavers that beforeand at the time
of concluding the grievances aforesaid to wit at the
county of St Louis aforesaid she was and still
is a free person and the defendant Samuel
L W Kinney then held and detained her
and still holds and detains her in slavery and
after ways to the said Mary guette then
and there did against of
and to the damage of the plaintiff
$ 500 and therefore she brings her suit

July Term A.D.1831

And the said M Kinney comes
and defends the force and injury when   c. and says
that said plaintiff ought not to have or maintain her
aforesaid action thereof against him because he says
that at the time when this suit was commenced he had
not nor claimed to have nor hath he nor doth he now
claim to have but disavoweth   disclaimeth to have
any title or interset in said Mariguette as a slave nor
did he then hold nor hath he since had nor doth he now, hold
her as a slave: and this he is ready to verify, where
fore he prays proficient   c.

for deft

and the said Charles Wahrendorff by his attorney
comes and defends the force   injury when
  c.   says that he is not guilty of the said supposed
trespasses   wrongs in manner and form as in said
declaration alleged: and of this he puts himself
upon the country   c.

and for further plea in this behalf he
says that said plaintiff ought not to have or maintain
her aforesaid action thereof against him because
he says, that said plaintiff at   before the time mentioned
in said declaration for the committing said supposed
trespasses   grievances, said plaintiff was   now
is his slave, without there that she was or is a
free person:   this he is ready to verify. Wherefore he
prays   c.

for Wahrendorff filed August 12th
1831A gamble Clerk

Page 92

Non suit of page 157

No 13 July Term 1831

Mariguette
vs
Samuel T . McKinney

Disclaimer

Filed July 28th 1831 A Gamble Clk

by Wahrendorff

filed August 12th 1831 A Gamble Clk

County Of St. Louis , Sct.
State Of Missouri ,To the Sheriff of St. Louis County---Greeting.

You are hereby commanded to summon Clayton Tiffin
that setting aside all manner of excuse and delay, he be and appear in proper person before the
Judge of our Circuit Court , 3rd day of Aprilnext 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 Mariguette is
plaintiff, and Samuel T McKinney   Charles Wahrendorff are defendants,
on the part of the plaintiff; and have you then there this writ.

Witness: Archibald Gamble , Clerk of our said
Circuit Court , at the City of St. Louis , this 20
day of February in the year of our Lord one
thousand eight hundred and thirty two Archibald Gamble Clerk C.C.

March Term 1832

Mariguette
vs
F.T. McKinney   W Wahrendorff

for plff
Clayton Tiffin 6on 3d April

Executed on this
writ on Clayton Tiffin in the
city of St Louis on the 6th day of March 1832

Jno K Walker Sheriff by J . Brotherton $ 1.00

County Of St. Louis , Sct.
The State Of Missouri ,To The Sheriff Of St. Louis County,
Greeting.

We command you to attach Clayton Tiffin
by his body, and him safely keep, so that you have his
body before the Judge of our Circuit Court , now in session at the City of St. Louis , within and for the
county of St. Louis , forthwith 18,
then and there to testify and the truth to say in a certain matter of controversy, now pending in our said
Circuit Court , between Mariguette plaintiff and Mariguette S T M. Kinney
is defendant, wherein the said Tiffin
has heretofore been summoned on the part of the said plaintiff

Witness, Archibald Gamble , Clerk of our said Court, at the
City of St. Louis , this 24th april - 1832 A Gamble Clerk

Executed & have the body of
Clayton Tiffin in Court 24th
April 1832

Jno K
Walker Sum $

Mariguette
vs
S T McKinney

for Clayton Tiffin

County Of St. Louis Sct.
State Of Missouri ,To the Sheriff of St. Louis CountyGreeting.

You Are Hereby Commanded To Summon Alexis Amelin
that setting aside all manner of excuse and delay, he be and appear in proper person
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 Mariguette
is plaintiff, and S. T. McKinney
is defendant, on the part of the plaintiff
and have you then there this writ.

Witness: Archibald Gamble , Clerk of our said Circuit Court ,
at the City of St. Louis , this 25th day of
April in the year of our Lord one thousand
eight hundred and thirty two A Gamble Clerk C.C.

Served this
writ on Alexis
Amelin on the 25h April
1832

K Walker Sheriffsum. 50

Marguritte
vs
S.T. McKinney

for
Alexis Amelin
forthwith
for plff

County Of St. Louis Sct.
State Of Missouri ,To the Sheriff of St. Louis CountyGreeting.

You Are Hereby Commanded To Summon Clayton Tiffin and Alexis
Amelin
that setting aside all manner of excuse and delay, he be and appear in proper person
before the Judge of our Circuit Court , on the 30h day of Julynext
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 Mariguette
is plaintiff, and Samuel T M. Kinney  
W Wahrendorff are
defendants, on the part of the plaintiff
and have you then there this writ.

Witness: Archibald Gamble , Clerk of our said Circuit Court ,
at the City of St. Louis , this 29th day of
June in the year of our Lord one thousand
eight hundred and thirty two Archibald Gamble Clerk C.C.

July Term 1832

Mariguette
vs
S.T . W Kinney   W Wahrendorff

for plff
Clayton Tiffin Alexis Amelin on 30th July

Executed this writ on Clayton Tiffin
  Alexis Amelin in the city of St Louis
on the 3rd day of July 1832

John K Walker Sheffby Brotherton service 1.00

County Of St. Louis , Sct.
State of Missouri , To the Sheriff of St. Louis County,
--Greeting.

We command you to attach Clayton Tiffin   and Alexis Amelin
by by their bodies, and them safely keep, so that you have their bod ies before
the Judge of our Circuit Court , now in session at the City of St. Louis , within and for the County of St. Louis , on the8th
day of August 1832, then and there to testify and the truth to say in a
certain matter of controversy, now pending in our said Circuit Court , between Mariguette
plaintiff and Sam T M Kinney
defendant, wherein the said Tiffin and   Amelin have
heretofore been summoned on the part of the said plaintiff

Witness, Archibald Gamble , Clerk of our said Circuit Court , at the City of St .
Louis , this Third day of August in the year
of our Lord, one thousand eight hundred and thirty-two A Gamble Clerk C.C.

Mariguette
vs
M Kinney

for
Clayton Tiffen Alexis Amelin attachment
to 8th august

Executed   havethebody
of Tiffin ߖ Amelin in
of 7 Augst 1832

Jno K Walker
SheriffService $ 2.00

County Of St. Louis Sct.
State Of Missouri ,To the Sheriff of St. Louis CountyGreeting.

You Are Hereby Commanded To Summon Clayton Tiffin and Alexis Amelin
that setting aside all manner of excuse and delay, they be and appear in proper person
before the Judge of our Circuit Court , Fifth day of Decembernext
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 Mariguette
is plaintiff, and Samuel T . M Kinney and
defendant, on the part of the plaintiff-
and have you then there this writ.

Witness: Archibald Gamble , Clerk of our said
Circuit Court , at the City of St. Louis , this 2nd day of
November in the year of our Lord one thousand
eight hundred and thirty two Archibald Gamble Clerk C.C.

November Term 1832

Mariguette
vs
S.T. McKinney   CW Wahrendorff

for the plaintiff
Clayton Tiffin 12 Alexis Amelin 14on 5th Dec

Executed this writ on Clayton Tiffin on
the 12th Nov 1832 and A . Amelin on
the 14tNov 1832 by reading the same
to them in the County of St Louis

John K Walker Sheriffby S . Brotherton shff $ 1.00

County Of St. Louis --Sct.
State Of Missouri ,To the Sheriff of St. Louis County--Greeting.

You are hereby commanded to summon Clayton Tiffin   Alexis Amelin
that setting aside all manner of excuse and delay, they be and appear in proper person before the
Judge of our Circuit Court , on the Twenty ninth day of Marchnext
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 Mariguette is plaintiff, and Samuel T M Kinney and Charles
Wahrendorff are defendants, on the part of the plaintiff
and have you then there this writ.

Witness: Archibald Gamble , Clerk of our said Circuit Court , at the City of
St. Louis , this Twenty third day of February
in the year of our Lord one thousand eight hundred and thirty three Archibald Gamble Clerk C.C.

Executed this writ by reading it to Clayton
Tiffin and Alexis Amelin in the County of St
Louis March 1st 1833

John K Walker Sheriffby J . Brotherton service $ 1.00

March Term 1833

Mariguette
vs
S.T.McKinney   W Wahrendorff

for plff
Clayton Tiffin 1st Alexis Amelin 1ston 29th March

County Of St. Louis --Sct.
State Of Missouri ,To the Sheriff of St. Louis County--Greeting.

You are hereby commanded to summon Clayton Tiffin   Alexis Amelin ,
that setting aside all manner of excuse and delay, they be and appear in proper person before the
Judge of our Circuit Court , on the 25th day of Julynext
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 Mariguette is
plaintiff, and Samuel T M Kinney and Cha. Wahrendorff
are defendants, on the part of the plaintiff
and have you then there this writ.

Witness: Archibald Gamble , Clerk of our said Circuit Court , at the City of
St. Louis , this 14th day of June
in the year of our Lord one thousand eight hundred and thirty three A Gamble Clerk C.C.

July Term 1833

Mariguette
vs
S.T . M Kinney   Chas Wahrendorff

for plaintiff
Clayton Tiffin 18 Alexis Amelin 19on 25th July

Executed this writ on Clayton Tiffin 18th on Alexis Amelin
the 19th July 1833 in the County of St Louis

John K Walker Sheriff $ 1.00

County Of St. Louis --Sct.
State Of Missouri ,To the Sheriff of St. Louis County--Greeting.

You are hereby commanded to summon Clayton Tiffin   Alexis Amelin ,
that setting aside all manner of excuse and delay, they be and appear in proper person before the
Judge of our Circuit Court , on the 2nd day of Decembernext
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 Mariguette is
plaintiff, and Samuel T M Kinney and Charles
Wahrendorff are defendants, on the part of the plaintiff
and have you then there this writ.

Witness: Archibald Gamble , Clerk of our said Circuit Court , at the City of
St. Louis , this 28th day of October
in the year of our Lord one thousand eight hundred and thirty three Archibald Gamble Clerk C.C.

November Term 1833

Mariguette
vs
M Kimmey   Wahrendorff

for plff
Clayton Tiffin 18 Alexis Amelin 11on 2d Decr

Executed this writ on Alexis Amelin
11th Clayton Tiffin 18th days of November 1833

John K Walker by Brotherton Service $ 1.00

County Of St. Louis , Sct.
State of Missouri ,To the Sheriff of St. Louis County,
--Greeting.

We command you to attach Clayton Tiffin   Alexis Amelin
by their bod ies, and them safely keep, so that you have their bod ies before
the Judge of our Circuit Court , now in session at the City of St. Louis , within and for the County of St. Louis ,
forthwith 183, then and there to testify and the truth to say in a
certain matter of controversy, now pending in our said Circuit Court , between Marguette
is plaintiff and S. T . M Kinney   C Wahrendorff
defendant, wherein the said Tiffin   Amelin have
heretofore been summoned on the part of the said plaintiff

Witness, Archibald Gamble , Clerk of our said Circuit Court , at the City of St .
Louis , this 10th day of December in the year
of our Lord, one thousand eight hundred and thirty-Three A Gamble Clerk C.C.

Marguette
vs
Wm Kenney  
Wahrendorff A

for
Clayton Tiffin Alexis Amelin attachment

Executed this writ   the body
of C Tiffin   A in Court
14th December 1833

by
Service of 200