To the honorable the judge of the third
Circuit for the state of Missouri
Your petitioner Josephine
an infant of color under the age of 21
years by Julia sa Course her mother and next
friend respectfully presents that she was hour in
the state of Illinois as she has been informed in
or about the year 1826 at the house of one
Baptiste La Course at the French Village in
the County of St Clair in the state of Illinois
that said La Cause claimed petitioner as a slave
that as such be sold her to one Charles Bond
who also lived in the state of Illinois that said
Bono afterwards sold and disposed of her as a
slave for life to M. Edward H . Mitchel who
brought her from the state of Illinois to the City
of St Louis in this state where she now lives
in his family and is used and held to color
and involuntaryservice by said Mitchel and
ownership claimed by him over as his slave
whereas your petitioner claims to be a free person
and prays that your Honor will order
and permit that he may bring suit as a
four person to establish her right to feedom
Josephini Sa
an infantby
her next friend
say
Marie P Ledue
State of Missouri County of St Louis
Before me a justice of the County Court within a justice of the County Court within and for said County
personally appeared alias a White
man of lawful age and made oath that
the statements contained in the above petition of Josephline Sa an infantly
her next fiend Julia Sa are just
and here
Sworn to and subscribed before me
this first day of August A. D . 1835
M . P Ledue Justice County Court
St. Louis CountyM. S. alexis her
mark
histhat the above
petition of be
permitted to her freedom
as a poor person to the
of in
made and provided and that a C.
as
g.
State of Missouiri
County of St Louis
SctIn the circuit court
november Term 1835
Josephine La an
infant of color under the age of 21 years who
then if Julia La her nextfriend
complains of eround of Mitchell of a
plea of trespass for that the said defend
and court on the first day or
June in the year 1835 at the county
aforesaid did then & there feat stike
and illtreat the said Plaintiff and then
and there did confined and imprison. the
said Plaintiff for a long spaces of time
towit hitherto and other wrongs
to the said plaintiff then and there did
to the great damages of the said Plaintiff
and the said Plaintiff that she is inquired and sustained damage
to the amount of one dollar. Again the
said Plaintiff in faen Saith that before
and all the time of this communipions of
the said grievances by the said defendant
the the said Plaintiff was and stilte
is a free person. and that the said
defendant at the paid have above mention-
ed held and detained and still doth
hold and delaing her in slavery when
fore she brings her suit
josephineBy hernextfriendjulia La
It is hereby ordered that the above patitioner josephine La
course be permitted to sue for her freedom as a poor person according
to the form of the statute in such case made and provided and that
A L Magenis be assigned as her counsel
L & Loawlejo J Judct
County of Saint Louis to
the State of Missouri To the Sheriff of the County of St Louis
Greeting
We command you to summon Edward & Mitchell 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 Seened monday of November next then and there
to answer into Josephine La Course an infant of color under the age of
21 years who sues> by Julia La Course her next friend of a plea of
trespass to the damage of the said Plaintiff of one dollar and have you then there this writ
Witness Archibald Gamble Clerk of
said circuit court at office this 5th, day of august year 1835 Archibald Gamble Clerk.
No 22 Saint Louis Circuit Court
November Term 1835
Josephine La Course
an infant of color
by her next friend
vs
mitchell>
This is a suit for freedom according
to the statute
Set a summons issue ally for filed 5th august 1835 Archibald Gamble Clerk
Executed this writ by receiving it and the declaration petition
and order of the judge to edward P. Mitchell on the 8th day
of august 1835 in the county of St Louis
J Brotherton by of Liberation & enq of damages 7-464
clerk Gambles
$1-93/2
226
continued Book 10 page 1- Rule 10 /, 440, Bk 12 / 2
State of Missouri
County of St. Louis
Josep line a Course
SctIn the Circuit Court
Nov. Term 1835
vs
Edward Mitchel
Personally appeared in open
Court arthur S. magrins and made oath that
he i Counel for the plaintiff in this Cause
that very soon after the commencement of the
same he was informed and verily believes that
the said plaintiff was removed out of the juridiction
of this Court into the State of Illinois by the
consent or convinience of said defendant that
this affiant has lately been informed that the right
of property to said plaintiff is claimed by
james mitchel father of said defendant who
resides at in the state of Illinois
that said defendant give information to
hi father the aid James Mitchel
of the institution of said and by aid plain
and that therefore said plaintiff was forth
with removed from the State of Missouri by
the said defendant or his said father or by both
of them and this affiant father saith that
he verilybelieves said plaintiff was so removed for
the purpose of depriving her of the benefit
of a trial of her right to freedom in this court
arthur & maginis
Maginis Sworn to Dec 1st 1835 A Gamble Clk
22
Nov. Term 35.
josephineLa Course
vs
Edward Mitchele
affidavit filed
Decr 1st 1835A G Clk
> Saint Louis Circuit Court July Term 1836.
Tuesday 23d August 1836
vs
Edward Mitchell
On motion of A. L. Magenis attorney for the plaintiff, it is ordered that the
rule upon the defendant made at the last November term of this court
be removed therefore it is ordered by the court that the said Edward Mitchell
show cause on Saturday next why an attachment should not issue against him for a contempt
of court in removing the plaintiff out of the jurisdiction of this court, in violation of the order herein before
made."
A true copy of the rule.
John Ruland Clerk.
By
J. D. Johnston D.C.
Served the foregoing Rule of court on
Edward Mitchell on the 27th day of August
1836 by Reading it to him in the city of St
Louis .
James Brotherton SheriffBy M. Brotherton D Shff Service 50 cts
Josephine Lecourse
vs
Edward Mitchelllb/> Rule
Book 8 - page 119 Rule discharged
renewed as to mitchelle
on a with to shew cause
Josephine Lecourse
vs
Edward Mitchelle
Filed 27th august 1836 John Ruland Clerk
Saint Louis Circuit Court July Term 1836
josephine becausevs
Edward Mitchell
on a to shew cause
why an should
not against him
Edward P Mitchell the defendant
in the above suit for cause why are attactment should not five against him
for content of court for removing the plaintiff
of the jurisdiction of this court, is
of an order in the said suit before
says. that he the said Edward did
not remove the said plaintiff of
the jurisdiction of this court
This respondant further says that the said
josephine before the commencement
of the
said suit was to him the
by James the father of this
defendants who
held and claimedsaid
josephine unit="chars"
rend="written" for the
of
wating on the of the respondant
for a start period that while said
josephine was in the of said
respondents under said
warn suit was brought by said
against this the said josephine
claiming her freedom - Immediatly
after the
service of the in said
action where
this defendant he employed Edward
Bates to defendant suit as
for him the respondant and suffered
that he would attend to it accordingly
and
this respondant soon after left the
state of Missouri and went to the
state
of Kentucky or and returned
to St Louis after or of
about
there weeks and upon his
action found
that the plaintiff had
been taken away
during his absence and in inquiry learned
that said plaintiff had been taken by
said James the Mitchell his father to his
residence in the state of Illinois This
respondent further says that when he left
St Louis to go to he left the plaintiff
at st louis in the family of the respondant
and that she was taken away during
his absence without the knowledge
priority or consent of this respondant
This respondant further says that he had
not at the of the commencement of
the said suit any ir claim to
the succes of said plaintiff except for such
time as said James Mitchelle should James
he said James a right to take
away the plaintiff at any time
Sworn to & subscribed in open
court this 27 august 1836 John Ruland Clerk