To the To the Hon the Judge of the st Louis circuit
court. The petition of Mary a Negro woman
aged about 32 years Respectfully Requests to your
honor that she was born in the state Maryland -
that she was owned & held as a slave by one Mr Gardner
who about the year 1819 him the said Mary & defendant
by a will then made & recorded in the county of Baltimore
to Miss Sarah Lurk to have- to hold as a servant
until she arrived at the age of twenty one years
or thereabout at which time she was to be free by
virture of said will & according to the Laws of Maryland of the will
your petitioner further requests that after the making no
aforesaid & after she came into possession of the said
Sarah Lorsh according to its provisions she was by the
said Sarah Lorsh summoned out of the state of
Maryland to the state of Kentucky & from
Kentucky she was removed to the State of Missouri
When the said Sarah Lorsh was married to
one & by virture of said
your petitioner came into the possession of the
said who mortgaged your petitioner
to for & who got possession
of your petitioner about the year1834 or 1840
and has continued to hold your petitioner since that
as a slave & still holds & acquires ownership
her as such although your petitioner
by virture of the will above mentioned is a free
woman of color therefore your petitioner pleas
that your honor allow her sue as a poor person
to establish her right to freedom according to the
Law in such case made & provided Mary

J F Ris

Mary a negro Woman of color being sworn petitioner
says that the matters & things set forth in the forgiving
and there

Mary Xher mark

Sworn to and Subscribed
Before Me this 29th day of October
A.D.1844, Whetman
Justice of the peace

I allow the foregoing and order First
That the said Mary be allowed to sue as a poor
person to establish her rightto fredom
& assign J.F Risk eqr as her counsel
Second that said Mary have reasonable
Liberty to attend her counsel & the court
as a season may require that she be not
removed out of the jurisdiction of the court
& that she be not subjectto any severity on
account of her application for freedom.

John M Krum Judge

State of

a negro womanv

St Louis Circuit Court
NovTerm 1844
for

Mary a Negro Woman
complains of James Jr in a plea
of Trespass for false imprisonment For that
theretofore towit on the tenth day of October Eighthundred
and forty five A.D. 1843 the said James Jr with
force & arms then & there made an assault on
the said Mary to wit at the city of St Louis County
of St Louis & State aforesaid & then & there beat
bruised & illtreated her the said Mary & then &
there imprisoned her the said Mary kept & delivered
her the said Mary in prison there without any reason
able or probable cause whatsoever for
a long time towit for the space of one year
past contrary to Law & against the will of the
said plaintiff and the said plaintiff further
owns that before the government above
mentioned the was
& still is a free person of color
and that the defendent did then & still holds
her in slavery & therefore she sues

Byof F
Atty

And the said trespass the force & in-
jury when he is assigned of the
said supposed trespass own land to his days
in manner &form another law pltff law &arm
thereof complains against him
himself when the county

Plea Filed Nov 19th 1844 D. Allen Jno Ruland Clerk Att for Deft

State of Missouri

Couty of

a Negro woman
v
Action of Trespass
for flase imprison
ment

The Clerk will issue
a summons in the a:
bove returnable
to the Nov Term 1844

T H Rich
Att for Dfns

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

We command you to summon James Clemens Jr
if he be found in your County that he be and
appear before the Judge of our Circuit Court , on the first day of the next term thereof, to be
held at the City of St. Louis , within and for the county of St. Louis , on the third Mon-
day of November next then and there to answer unto Mary
a negro woman of a plea of trespass and false
imprisonmentto the damage of said plaintiff dollars: And have you then there this writ.

Witness, John Ruland , Clerk of our said Court, with the seal thereof hereto affixed, at office, in the
city of St. Louis , thisSecondday of
November in the year of our Lord eighteen
hundred and forty four. John Ruland Clerk.

I acknowledge myself bound for all costs that may accrue in the above cause.
Witness my hand and seal, at St. Louis , this day of 184

plea filed 29 suit dismissed November 26th. 1844 15 330 at nobodys CostsNo.346 St. Louis Circuit Court
November 1844

a negrowomanv
SummonsTrespass & False Imprisonment

False T. F . Risk p.q

Filed November 2 1844 John Ruland Clerk

I allow the foregoing and order
First that the said Mary be allowed
to sue as a free person to establish her
right to freedom to assign T. F . Risk Esq
as her Counsel second that said Mary
have reasonable liberty to attend her
Counsel & the Court as occasion may
require that she be not removed and of the
jurisdiction of the Court that she be not
subject to any severity on account of her application for
her freedom Jno McKrum Judge 8 Jud Cir (153)

Executed this writ in the
County of St. Louis on the 2nd day of Novem-
ber 1844 by offering to read it and the
decleration to James Clemens Jr which
he refused to hear - Also by reading to the
said James Clemens Jr . the of the
Judge endorse upon this writ.

William Milburn Shff ByN. C Osburn ShffFee $ 1.50