nd a citizen of the State of New York, in the plea of trespass for that the defendant heretofore, to wit: on the 1st day of January, A. D. 1853, at St. Louis in the County of St. Louis and State of Missouri, with force and arms assaulted the plaintiff, and without law or right held him as a slave, and imprisoned him for the space of six hours and more, and then and there did threaten to beat the plaintiff and to hold him in prison, and restrained of his liberty, so that by means of such threats the plaintiff was put in fear and could not attend to his business, and thereby lost great gains and profits which he might have made and otherwise would have made in the prosecution of his business, to wit: $2,500, and other wrongs to the plaintiff then and there did, against the peace and to the damage of the plaintiff $3,000. And also for that the defendant heretofore on the 1st day of January A. D. 1853, with force and arms at St. Louis aforesaid, an assault did make on Harriet Scott, then and still the wife of the plaintiff, and then and there did imprison Harriet, and hold her as a slave, without law or right, for the space of six hours, and then and there did threaten to beat said Harriet and hold her as a slave, so that by means of the premises said Harriet was put in great fear and pain and could not and did not attend to the plaintiff's business, and the plaintiff lost and was deprived of the society, comfort and assistance of said wife, and thereby lost great gains and profits, of the value, Belonos 8to wit: of $2,500, and other wrongs to the plaintiff, the defendant then and there did, against the peace and to the plaintiff's damage, $3,000. And also for that the defended heretofore, to wit: on the 1st day of January, A. D. 1853, with force and arms at St. Louis aforesaid made an assault on Eliza Scott and Lizzie Scott, then and still infant daughters and servants of the plaintiff, and then and there imprisoned and held as slaves said...
