State of Misouri
St. Louis Countyss Saint Louis circuit
November Term A D 1836

a free woman of color otherwise
called Susan complains of
of a plea of trespass &
Battery & false imprisonment for that
on the first day of
October in the year of our Lord eighteen
hundred & twenty four at St. Louis in said
county the said defendant with force
& arms an assault did make upon
the same plaintiff and did then & there
any on probable cause
find her hands & her
, and did then & there any
lawful or probable cause bind her hands
said plaintiff to slavery & false imprisonment
he the said said defendant then
and there knowing the said plaintiff
to be a free person and the plaintiff
ours that afterwards on the first
day of December in the year aforesaid
at Balan range in the State of at St. Louis aforesaid and
the said defendant said said plaintiff
as a slave and the plaintiff ours that
from the day first aforesaid untill the
first day of December in the year last
of own land hundred &thirty
five she has been held and detained as a slave
by said defendant and other claiming her as such said Defendant
touch at the place last aforesaid.
And said plaintiff ours that for from
the first day of October eighteen hundred &
twenty four until the first day of December
eighteen hundred & thirty five by reason of
the aforesaid she has been presented from Labouring for himself and
carring and securing larger sum of
many touch the sum of eleven hundred
dollars which sum she said plaintiff and
& & earned and secured herself By means of which said
several grievances said plaintiff says she
is greatly , and hath sustained
damage to five thousand Dollars

G A Bird attorney for
plaintiff

State of Missouri
St. Louis County ss.

otherwise Susan the
plaintiff in the aforesaid Declaration
mentioned on her oath says that she has
a and unsatisfied cause of action
against Reddin and the same as
stated in the Declaration she
further says that said as
as she can recall in the fall of the
year 1823 on 1824 at the City of St. Louis
in the right time sayed this affiant put a
rape around her neckso as to choke
her of -he then in

took affiant to near
in Illionis where he
the hands & of with irons
he these affiant bound as
aforesaid for about 10 or 12 days
then put affiant in a said
then put an a flat Boat had
her taken to Baton Rouge & there said
as a slave and said
all this time that affiant
This affiant has been held as a slave
taken by as aforesaid untill
the 19th day
of march 1836 where she was by
the Judgement of the supreme court of the
state of Louisiana This affiant
is healthy and has always been
a good servant while her suit was pending
for freedom in new orleans the hired 12 dollar per month. This affiant
belives that she could have earned
at the rate of one hundred Dollars a
year during the period she has been as aforesaid change of all
said Defendant is a resident of
the state of is now him
and about to remove from this state
This affiant fears that she
be in danger of the damages
she may recover in sand sent
said Defendant shall he held to court

Phillis X her mark sworn to & subscribed before me their 17 Sep: 1836 John Ruland ClerkC. C.

on the foregoing affidavit a copies is allowed and the defendant orderd to be held to bail
in the sum of fifteen hundred dollars.

John Ruland clerk of the circuit court.

County of St. Louis , ss.
The State of Missouri ,To the sheriff of the County of Saint Louis greeting:

we ommand you to take Ridden B. Herring if he be found in your County, so that
you have his body before our Honorable Circuit court, on the first day of the next term
thereof, to begun and held at the City of Saint Louis , within and for the County aforesaid
on the second Monday of November next, then and there to answer unto Philis alias
susan of a plea of trespass, assault and battery and false imprisonment wherefore
the said plaintiff saith she has sustained damage to the amount of five thousand
dollars and have you then there this writ.

Witness, John Ruland , Clerk of our said Court, at
office in the city of Saint Louis with the seal thereof here
to affixed, this seventeenth day of September in
the year of our Lord eighteen hundred and thirty-six.

No 51
November Term 1836

of

Filed 17th September 1836 John Ruland Clerk
on the wit the sheriff will require bail of the defendant in the
of $ 1500.
John Ruland Clerk

Executed this writ on the 17th day of
1836 in the county of St. Louis by Reading
it and the declaration to the within named
Reddin B Herring and arresting his body
which was on the same day discharged
from my custody by his giving bond
and security as Required by law which herewith Returned

James Brotherton Sheriff
By M Brotherton Deputy
Sheriff

Service$ 1.00Bond50$ 1.50

[Common Capias Bond.]
Know All Men By The Presents, That we Reddin B Herring
as principal, and
David Coons as security are held and firmly bound unto
Philis alias Susan
in the sum of fifteen hundred dollars, to
the payment of which sum well and truly to be made, we do hereby bind ourselves, our
heirs and our representatives, jointly and severally, firmly by these presents, sealed with
our seals and dated this Seventeenth day of September 1836

The condition of the above obligation is such, that whereas
said Reddin B Herring
hath been arrested by the Sheriff of St. Louis County, upon a writ of capias, returnable
to the term of the Circuit Court to be holden on the second Monday of November
next, in the city of St. Louis , within and for the County of St. Louis ,
to answer unto the said Philis alias Susan
in a plea of Trespass assault & battery
and false imprisonment
to the damage of said plaintifffour thousand
Now if no judgment shall be given against Reddin B Herring
in said suit, or if judgment be given against said
Reddin B Herring
in said suit, and he shall pay the amount of the recovery, or surrender in
execution thereof, or the said David Coons the
security will do it for him then this obligation shall be void;
otherwise it shall remain in force.

Signed, sealed and delivered
in presence of
Redding B Herring
D. Coons

In Circuit Court

And the said Ridder by
has and defends the and and says that he is not guilty of the
of the premises in mannered form as the
plaintiff above thereof in her declaration
alleged and of this the defendants
feets himself upon the county

for

and for further plea on this behalf the said Defendant
says that the plaintiff ought not to have maintain her aforesaid thereof because
he says that the said several causes
of written in the declaration mentioned did
not nor did of then accrue written
two-years next before the commencement of
this next and this the defendant is ready
to verify - wherefore he prays judgment
of the plaintiff ought to have a
her aforesaid as

for defts.

No 51
Nov Term 1836

Pleas

Filed 28th Nov: 1836
John. Ruland Clerk

And said plaintiff for
replication the second plea
of said defendant says she ought not
to or mantaining
her said by reason of any thing
by him in that plea alleged because the
says that immedately after the said
defendant took and imprisoned her as
in her declaration is he took her
to the state of Louisiana and there sold
her as a slave, where she was held in slavery
untill the than two years previous to the
commencement of her said suit and that
during the time she was held in slavery as
aforesaid the defendant was not at
any time a resident of the state of
Louisiana but his place of was
unknown to said plaintiff and so
the plaintiff that said defendantly
the means aforesaid did obstruct the
or maintaining her said action
against him during all the time she was
held in slavery as aforesaid & this she as
ready to wherefore the prays
judgement

G A Bird for

No 51
November Term 1836

replication to
plea that
she was obstructed by
in bringing her her
untill

for
Replication
Filed 5th January 1837
John Ruland Clerk

County of St. Louis , sct.
State Of Missouri ,
To the Sheriff of St. Louis County Greeting:

You are hereby commanded, to summon David Coons Mary Coons , James &
Christian F
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 5th day of April next
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 Phillis is plantiff, is and Reddin B Herrin is defendant on the part of the plaintiff
and have you then and there this writ.

Witness, John Ruland , Clerk of our said Circuit court, at the
City of St. Louis , this4th day of March
in the year of our Lord one thousand, eigh hundred and thirty seven.
John Ruland Clerk, C. C.

Served this writ by Reading it
Christian F on the 7th James
on the 8th David Coons and
Mary Coons on the 13th days of
March 1837 in the county of
St. Louis

James Brotherton Shff
By M Brotherton
Service $ 2.00

March Term 1837

For plaintiff

David Coons 13
Mary 13

James
Christians
for 5th April 1837

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

You are hereby commanded to summon David Coons , Mary Coons ,
James Loper & Christian F Keinlien
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 27th July next
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 Phillis is
plantiff and Reddin B Herring is
defendant on the part of the plaintiff
and have you then and there this writ.

Witness, John Ruland , Clerk of our said Circuit court, at
the City of St. Louis , this23 day of June
in the year of our Lord, eighteen hundred and thirty 7.
John Ruland Clerk, C. C.

July Term 1837

David Coons 26
Mary Coons
James Loper
C. F . Keinlein 26
27th July

Served this writ on David Coons
Mary Coons & C F Keinlein on
26th day of June 1837 in the county
of St. Louis James Loper not found
in my county

James Brotherton
By

Service$ 1.50$ 1.62%

County of St. Louis , sct.
State Of Missouri ,
To the sheriff of St. Louis County---Greeting:

You are hereby commanded, to summon David Coons , Mary Coons , James Loper
C. F . Keinlein
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 Sixteenth day of august next
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 Phillis alias Susan is
plaintiff and Reddin B Herrin
defendant on the part of Plaintiff
and have you then and there this writ.

Witness, John Ruland , Clerk of our said Circuit court, at
the City of St. Louis , thisThird day of August
in the year of our Lord, eighteen hundred and thirty seven.
Jn. Ruland Clerk, C. C.

July Term 1837

David Coons 5
Mary Coons 5
James
C F 4
10th aug 1836

Served this writ by reading it to Keinlein
on the 4th and on David and mary Coons by leaving
a true Copy Thereof at their dwelling house,
with a white member of their family over
the age of fifteen years, on 5th day of August,
1837 in the county of St. Louis James Loper not
found in my county

James Brotherton Sheriff
By Joseph

Service$ 1.5012 1/2$ 1.62 1/2

In St. Louis Circuit Court

And the said defendant
as to the said replication of the said plaintiff
to the record plea of the defendant says
that by reason of anything is that after
alleged the plaintiff ought not to
have or maintain her a aforesaid
because he says that he did not
any time years next
before the of the suit
hold the said plaintiff is slavery nor
did the said defendant obstructed the
or maintaining the said active by
any of the means in the
replication in manner and form as the
hall in her said replication alleged
and this the defendant prays may
he enquired of by the county

No 51
November Term 1836

Filed 16th August 1837
John Ruland Clerk

continued Book 10 page 410p 44412 p 2

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

You are hereby commanded, to summon David Coons Mary Coons
, C.F. Reinlein that setting aside all manner of excuse and delay, they be and appear in proper person
before the Judge of our Circuit Court , on the28th November next 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 Phillis alias Susan is plantiff and Reddin B . Herring is defendant on the part of
and have you then and there this writ.

Witness, John Ruland , Clerk of our said Circuit court, at
the City of St. Louis , this 17th day of
in the year of our Lord, eighteen hundred and thirty seven.
John Ruland Clerk, C. C.

not executed, the docket being

James Brotherton Sheriff
50

November Term 1837

David Coons
Mary Coons

C FKeilien
28th November1837

County of St. Louis , sct.
State Of Missouri ,
To the sheriff of St. Louis County---Greeting:

You are hereby commanded, to summon David Coons , Mary Coons
Jas. Loper , C F Keinlein 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 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 Phillis alias Susan plaintiff and Reddin B Herring is defendant on the part of and have you then and there this writ.

Witness, John Ruland , Clerk of our said Circuit court, at
the City of St. Louis , this 29th day of November
in the year of our Lord, eighteen hundred and thirty seven.
John Ruland Clerk, C. C.

of the named
found

J Brotherton Sheriff
$=50

November Term 1839

plff.

D. Coons
Mary Coons

C.F.
24th November 1839

County of St. Louis , sct.
The State Of Missouri ,
To the sheriff of St. Louis County---Greeting:

You are hereby commanded, to summon David Coons , Mary Coons ,
James Loper & Christian F Keinlein 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 27th March 1838 next 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 Phillis alias Susan is
plantiff and Reddin B.Herring is defendant on the part of the Plaintiff and have you then and there this writ.

Witness, John Ruland , Clerk of our said Circuit court,
at the City of St. Louis , this 10th day of February
in the year of our Lord, eighteen hundred and thirty 8.
John Ruland Clerk, C. C.

Not executed on account of the adjoinment
of Court

James Brotherton Sheriff

March Term 1838

27th March plff.

David Coons
mary Coons

C. F . Keinlein

County of Saint Louis , Sct,
The State of Missouri ,
To The Sheriff of St. Louis County---Greeting.

You are hereby commanded to summon David Coons , Mary Coons
Jas Loper , Christian F Keinley that setting aside all manner of excuse and delay, they be appear in proper person
before the Judge of our Circuit court, on the 13th day of April next at the City of St.Louis , then and there to Testifiy,
and the truth to say, in a certain matter of controversy now pending in our said Court,
wherein Philis alias Susan
plaintiff and Reddin B Herring is defendant on the part of Plaintiff and have you then and there this writ.

Witness, John Ruland , Clerk of our said Circuit Court ,
at the City of St. Louis , this 19th day of March
in the year of our Lord, eighteen hundred and thirty eight.
John. Ruland Clerk, C.C. by
Geo. Deply

Executed this writ by offering to read The same to C F
Keinlen on The 23, and to David Coons on The 26th days
of March, 1838 which they refused to hear read and
acknowledged the service Thereof. and by leaving an
true copy thereof at the dwelling house Mrs. Mary
Coons , with a white member of her family over
The age of fifteen years, in the 29th dy of March,
1838- all done in The County of St. Louis - dead

James Brothrton Sheriff
Joseph

Service# 1.5012 1/2$ 1.62 1/2

March Term 1838

David Coons 26
Mary Coons 29
James Saper -
C F Keinlen 23
13th April

County of Saint Louis ,Sct,
The State of Missouri ,
To The Sheriff of St. Louis County---Greeting:

You are hereby commanded to summon David Coons , Mary Coons , James
Loper , Christian F Keinley that setting aside all manner of excuse and delay, they be appear in proper person
before the Judge of our Circuit court, on the 23rd July at the City of St.Louis , then and there to Testifiy,
and the truth to say, in a certain matter of controversy now pending in our said Court,
wherein Phillis alias Susan plaintiff and Reddin B Herring is defendant on the part of Plaintiff
and have you then and there this writ.

Witness, John Ruland , Clerk of our said Circuit Court ,
at the City of St. Louis , this 2 day of July
in the year of our Lord, eighteen hundred and thirty eight.
Jn. Ruland Clerk, C.C. by Geo . A

Executed this writ in the County of St .
Louis on the 21st day of July 1838 by
leaving a true copy, thereof at the rsidence
of David & Mary Coons with a free white
person over the age of fifteen years- and by
reading it to C F Kienlan- James Loper
not found in my County

James Brotherton Sheriff
By F.W . Dpty

Service1.50.12$ 1.62 1/2

July Term 1838

David Coons 21
Mary Coons 21
(Copy)
Jas. Loper
Christian F Keinlien 21
23rd July

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

You are hereby commanded to summon David Coons , Mary Coons ,
James , Christian F Keinley
that setting aside all manner of excuse and delay, they be appear in proper person
before the Judge of our Circuit court, on the 21st August at the City of St.Louis , then and there to Testifiy,
and the truth to say, in a certain matter of controversy now pending in our said Court,
wherein Philis alias Susan
plaintiff and Reddin B Herring is defendant on the part of Plff
and have you then and there this writ.

Witness, John Ruland , Clerk of our said Circuit Court ,
at the City of St. Louis , this 2 day of August
in the year of our Lord, eighteen hundred and thirty eight.
Jno Ruland Clerk, C.C. by
Geo . A

Executed this writ by

July Term 1838

David Coons 16 Mary Coons 16 James. Loper Christian F Keinlen 21st August

this writ by reading it
to Christian F Kienlen on the 15th
and by leaving a true copy, thereof
at the rsidence of David Coons
& Mary Coons on 16th days
of August 1838 in the County of
St. Louis James Loper not found

Brotherton Sheriff Fees # 1.62 1/2

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

You are hereby commanded to summon David Coons , Mary Coons ,
James Loper , Christian F Keinley
that setting aside all manner of excuse and delay, they be appear in proper person
before the Judge of our Circuit court, on the 29th augustat the City of St.Louis , then and there to Testifiy,
and the truth to say, in a certain matter of controversy now pending in our said Court,
wherein Philis alias Susan is
plaintiff and Reddin B Herring is
defendant on the part of Plff and have you then and there this writ.

Witness, John Ruland , Clerk of our said Circuit Court ,
at the City of St. Louis , this 1st day of august
in the year of our Lord, eighteen hundred and thirty eight. Jn. Ruland Clerk,C.C.by Geo.A

Executed this writ on all the written
named witnesses exception Loper who is
dead

M Brotherton Sheriff

Service.5012 1/2# 1.62 1/2

Nov Term 1838

David Coons Mary Coons copy James.Loper Christian F Keinlen 29th

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

You are hereby commanded to summon David Coons , Mary Coons ,
Christian F Keinlen , that setting aside all manner of excuse and delay, they be appear in proper person
before the Judge of our Circuit court, on the 29th March 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 Philis alias Susan is plaintiff and Reddin B Herring is
defendant on the part of Plaintiff and have you then and there this writ.

Witness, John Ruland , Clerk of our said Circuit Court , at
the City of St. Louis , this6 day of March
in the year of our Lord, eighteen hundred and thirty nine Jno Ruland Clerk, C.C.

Executed this writ in St. Louis County by reading it
to the witnhin named witnesses March 25th 1839

Marshall Brotherton Shf By Service 1.50

March T 1839

David Coons Mary Coons C F Keinlen 29th March

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

You are hereby commanded to summon David Coons , Mary Coons ,
Christian F Keinlen , that setting aside all manner of excuse and delay, they be appear in proper person
before the Judge of our Circuit court, on the 29th Marchat 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 Philis alias Susan is
plaintiff and Reddin B Herring is defendant on the part of Plf. and have you then and there this writ.

Witness, John Ruland , Clerk of our said Circuit
Court , at the City of St. Louis , this 5th
day of April in the year of our Lord, eighteen
hundred and thirty nine Jno Ruland Clerk, C.C.

March T 1839

David Coons Mary Coons Chirstian F Keinlen 16th April

County of Saint Louis ,Sct, State Of Missouri , To The Sheriff of St. Louis County,-Greeting:

You are hereby commanded to summon David Coons , Mary
Coons & Christian F Keinlen , that setting aside all manner of excuse and delay, they be appear in proper person
before the Judge of our Circuit court, on the 10th day of Dec; next 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 Philis alias Susan , is
plaintiff and Reddin B Herring , is
defendant on the part of the Plaintiff and have you then and there this writ.

Witness, John Ruland , Clerk of our said Circuit
Court , at the City of St. Louis , this twenty fourth
day of October in the year of our Lord, eighteen
hundred and thirty nine Jn. Ruland Clerk, C.C.

Executed this writ in the County of St. Louis
on the 5th day of December 1839 by reading it to
Christian Keinlen , David Coons & Mary Coons

Marshall Brotherton Sheriff Service # 1.50

Nov; Term 1839

David Coons Mary Coons C F Keinlen 10th Dec 5.

County of Saint Louis ,Sct, State Of Missouri , To The Sheriff of St. Louis County,---Greeting:

You are hereby commanded to summon Christian F Keinlen
& David Coons
that setting aside all manner of excuse and delay, he be appear in proper person
before the Judge of our Circuit court, on the 10th dayDec; next
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 Philis otherwise Susan , is
plaintiff and Reddin B Herring , is
defendant on the part of Plaintiff and have you then and there this writ.

Witness, John Ruland , Clerk of our said Circuit
Court , at the City of St. Louis , this fifth
day of May
in the year of our Lord, eighteen
hundred and forty Jn. Ruland Clerk, C.C.

March Term 1840.

D Coons for Christian F Keintin

for the with Coons