To the Hon.l Judge of the
St. Louis Circuit Court
The petition of
Susan a girl of Colour about fourteen
years of age represents to your honor
that she was born at in
the State of Illinois sometime in the
year Eighteen Hundred and Eighteen, that
her mother as she is informed
and believes is a native African and
was at the time of your petitioners birth
held in bondage by one William
Monnesou of Illinois , - that said Monnesou
several years since on the marriage
of his daughter to our Andrew Hay
gave your petitioner to said Hay who
sometime after sent her to Galena
in Illinois and sold her as she
is informed and believes to our Lemon
Parker who brought your petitioner
to thisplace ( St. Louis ) where he holds
and restrains her as a slave well kn
owing her to be free; therefore your
petitioner prays that your honor may
permit her to sue as a poor person, to esta
blish her right to freedom, and that such
other and further orders may from time
to time be made in the premises as to your
honor may seem proper
Susan
her mark
State of Missouri
St. Louis County
This day personally
appeared before me Patrick Walsh a
justice of the peace where and for the
County of St. Louis , Susan the above
petitioner who being duly sworn says
that the facts contained in the foregoing
petition are true to the best of her
knowledge
Sworn to and subscribed before
me this 3rd day of July AD. 1832 Patrick Walsh
Justice of the Peace
St. Louis County Susan her Mark
State of Missouri
Third Judicial Court
The above named
petitioner Susan is permitted to sue as a
poor person upon the foregoing petition to
establish her freedom, and the Clerk of
Circuit Court of St. Louis County is hereby
directed to issue the necessary process for that
purpose; - Has further ordered that the petitioner
have reasonable liberty to attend her counsel
and the Court; and that said petitioner shall
not be taken or removed out of the jurisdict
ion of the Court nor be subject to any
severity because of her application for
freedom- is assigned
as her counsel
State of Missouri
County of St. Louis
July Term 1832
Susan by her Attorney
complains of Parker of a plea
of Trespass;- For that the said Parker on the
second day of July 1832 with force and
made an assault upon said Susan
to wit; at the County of St. Louis and State
of Missouri , and then and there beatbruised
and ill treated her the said Susan and kept
and detained her in prison there without
any reasonable or probable cause for long
time to wit. For the space of twelve hours
then next following, and the said Susan
in jail avers that before and at the time of
the committing the said grievances she was
and still is a free person, and that the def
endant held and detained her and still
holds and detains her in slavery against
her will; and otherwrongs and injuries
then and there did to the said Susan where
fore she says she is injured and hath
Sustained damage in the amount of
hundred dollars & therefore she sues &c
G.W . Foreman
atty
Saint Louis Circuit Court July term 1832
Tuesday July 24th 1832
vs
Lemon Parker
Stephen W Foreman presents the petition of Susan a girl of
color praying that she may be permitted to institute a suit against Lemon
Parker for Establishing her right to freedom and that she may be permitted
to sue as a poor person, thereupon the Court permit the said Susan to sue as
aforesaid and direct an action of assault and battery and false imprisonment to be brought in the name of the said Susan and assign Stephen W . Foreman
Esq. as her counsel, and it is ordered by the Court that the said Lemon Parker permit
the said petitioner 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 Saint Louis Circuit Court
November Term 1832
Susan
vs
L Parker &
Filed July 22nd 1832 A Gamble Clk
Susan a girl of color
vs
Lemon Parker
The said defendant Lemon Parker moves the
Court to quash the alias writ in this case and the
sheriffs return for the following reasons
1st Because the aliaswrit in this cause was issued
before the return of the orginal
2nd Because the alias writ is irregular
HR Gamble atty
for deft
No 5 March Term 1833
Susan a girl of
color
vs
Lemon Parker
Motion to quash&reasons
filed March 28th
1833A gamble clk