To the Honbl the judge of the circuit court
of St Louis County the petition of Hetty
a woman of color respectfully represents
That she was born a slave in the state of Vir
ginia and became the property of John Rolf
in that state who died in Virginia , and your
petitioner then became the property of his widow
Mrs James Rolf , who removed your petitioner
to St Geneveive County in the territory of
Missouri on or about the third day of December in the year 1816, in which last
mentioned County and territory your petition
er was kept by her said mistress about one
month, when the said Mrs Rolf your petition ers mistress removed to the territory of
Illinois about eight miles from the
town of Kaskaskia where she took up
her residence in the family of
Dr James H Rolf her son, where she resided
more than a year that when she went over
to the territory of Illinois she removed your
petitioner with her to that territory, where she
kept your petitioner employed in the ordinary duties of a slave, in working for her and the
family of her son for about the period of
two months, and then about the tenth of March
in the year eighteen hundred and seventeen
your petitioner was sent to St Geneveive in
the territory of Missouri and hired there until
some time in September of the last mentioned
year, at which last mentioned time your petitioner was
again removed to her said mistresses residence
in Illinois , and remained there employed in
in her service as a slave until the month of
July following, when she was sent by her said mistress again to the St Geneveive in Missouri with
Mrs Elisabeth the daughter of the said Mrs. Relf. Your petitioner states that she is now
held in slavery by Arthur L Maganis Esqr of
St Louis and claims her freedom on the foregoing
state of facts
Hetty X her markwitness HR Gamble
State of Missouri
County of St Louis
This day the above named
petitioner Hetty being by me duly sworn upon
her oath says that the facts in the foregoing
petition are true
Hetty mark xherSworn to & subscribed
before me January 16th 1835 D Hough
State of Missouri Sct
On the foregoing petition it is ordered that
the petitioner Hetty have leave to sue as a poor person
to establish her right to freedom and HR Gamble is
assigned as her counsel And it is moreover ordered
that that petitioner have reasonable liberty to attend
her counsel and the court when occasion may require
and that the petitions 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
Given at my chambers at St Louis February 19. 1835
No 43
St Louis circuit court
March term 1835
color vs
Arthur L Magenis
Filed 20th Febuary 1835
Archibald Gamble clerk
In the Circuit Court
March term 1835 St Louis circuit court
Hetty a woman of color by
H R Gamble her attorney complains of Arthur
L Magennis of a plea of trespass. For that
the said defendant on the first day of January
in the year eighteen hundred and thirty five at
the county aforesaid made an assault in and
upon the said plaintiff and then and there did
beat bruise and wound the said plaintiff
and did then and there imprison the said
plaintiff and hath ever since kept and de
tained the said plaintiff in imprisonment
and slavery And the said plaintiff avers
that before and at the time of the committing
the said grievances by the said defendant she the
said plaintiff was and still is a free person
and that the defendant held and detained
her and still holds and detains her in sla
very
against the peace and dignity of the state
wherefore the said plaintiff says she is injured
and hath sustained damage to the amount
of five hundred dollars therefore she sues &c
HR Gamble attr for plff
County of Saint Louis Ss. The state of Missouri To the sheriff of the county of Saint Louis Greeting:
We command you to summon Arthur L Magenis 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 Saint Louis on the fourth Monday of March next then and there to answer unto Hetty a
woman of color of plea of trespass wherefore the said plaintiff says she is injured and hath sus-
tained damages to the amount of five hundred dollars and have you then there this writ.
Witness. Archibald Gamble clerk of our said circuit court at office
this Twentieth day of Febuary in the year of our Lord one thousand
eight Hundred and thirty five Archibald Gamble clerk
(copy of the order of the judge permitting suit to be brought) State of Missouri sct
on the foregoing petition it is ordered that the petitioner Hetty have leave to sue as a poor person to
establish her right to freedom and H R Gamble is assigned as the counsel, and it is moreover ordered that the petitioner
have reasonable liberty to attend her counsel and the court when occasion may require and that the petitioner 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 - Given at my chamber at St Louis Febuary 19. 1835 L. E. Lawless - Judge 3d Judc Ct
A true copy of the order of the judge permitting Hetty to sue A L Margeris as endorsed on her petition)
Archibald Gamble clerk
Executed this writ by offering to read it together with
the petition Declaration and order of the judge
to Arthur L Magenis on the 26th day of February
1834 in the County of St Louis and his refusing to hear the same read
and acknowledging the service thereof
J Brotherton shff by G Hammond Dept Service ' 1.00
No43 Saint Louis Circuit court March term 1835
Hetty a woman ofcolor
vs
Arthur L Magenis
This an action of tres
pass Dam ' 500
Let a summons issue
Gamble Filed 20th Febuary 1835 Archibald Gamble Clerk
St Louis Circuit Court
Hetty suing for freedomvs
A.L. Magenis
The defendant moves to
quash the order permitting the petitioner to sue in
this case & also to dismiss this suit for
the following reasons.
That said order was improvidently made
, on a statement of facts not warranting it, &
not sufficiently proved.
A.L . Magenis
Motion to quash order permitting plff to sue overruled Book 7 - page 346 -
No. 43
Saint Louis circuit court
March term 1835
vs
A.L . Maseny
Reasons for quash-
ing order to sue &c.
filed March 23rd 1835
A Gamble clerk
State of Missouri
County of St Louis In the Circuit Court March Term 1835
And the said defendant
by his attorney comes and defends the wrong
and injury when &.c, and says that he is
not guilty in manner & force as the said
plaintiff hath above thereof complained
against him and this he prays may be
inquired of by the County
Atty for Dfts
No.43 March Term 1835
Arthur L . Magennis ads Hetty a woman of colorplea N.G. Magennis atty for Dfts
filed March 28'1835 A Gamble clk
change of venue to County of St Geneveive Book 7 page 346