Rachel Graham v. Frances Swann. Transcript from Alexandria County
Be it remembered that heretofore to wit: at the rules held in the Clerk's office of the said Court for the month of May 1842, came the plaintiff by Thomas Semmes Esq her attorney and filed there a certain bill against the said defendant, which is in the words following:
District of Columbia
Alexandria County to wit
Rachel Graham complains of Frances Swann in custody &c of a plea of trespass and false imprisonment for this to wit: that the said defendant on the day of 1840 in the County aforesaid with force and arms made an assault upon the said plaintiff and then and there did beat wound and ill treat her the said plaintiff, and her the said plaintiff did then and there falsely and unlawfully imprison, and of her the said plaintiff's freedom and lawful liberty did then and there falsely and unlawfully deprive the said plaintiff, and other injuries to her the said plaintiff then and there did, against the peace of the United States and to the damage of the plaintiff one hundred dollars, and therefore
she brings suit.
Jones & Semmes pq
J. Doe
R. Roe pledges &c
And the defendant being arrested, and not appearing, on the motion of the plaintiff by her attorney, it is ordered that judgment be entered for the plaintiff against the defendant, for whose damages the plaintiff hath sustained by reason of the trespass & false imprisonment in the declaration mentioned, unless the said defendant shall appear and plead to issue at the next rules.
And at the rules held in the Clerk's office of the said Court for the month of August 1841, came the plaintiff by her said Attorney, and the deft still failing to appear, on the motion of the plaintiff, by her attorney, it is ordered that the last order made against the defendant in this case be confirmed, and that the plaintiff’s damages be ascertained by a Jury at the next term.
And now at this day, to wit: At a Court continued & held for the District and County aforesaid the 9th day of June 1842, came the plaintiff by her said attorney, and the defendant by Edward Swann Esq her attorney comes & defends the wrong & injury when &c, and says that she is not guilty of the trespass & false imprisonment as the plaintiff hath alledged against her, and of this she putteth herself upon the County and the Plaintiff likewise:
And by consent of parties the venue is changed to the County of Washington. And the Clerk of this Court is directed to transmit the record of the proceedings in this suit, together with the original papers to the Clerk of the Circuit Court for the County of Washington.
I, Cassius F. Lee, Clerk of the United States' Circuit Court of the District of Columbia for the County of Alexandria hereby certify, that the foregoing is a true transcript of the proceedings in a certain action for freedom depending in said Court in which Rachel Graham is plaintiff and Frances Swann is defendant. In testimony whereof, I hereto Subscribe my name & affix the seal of the said Court this 24' day of June 1842.
Cassius F. Lee. CC
Rachel Graham
v
Frances Swann
Record
Filed 12 July 1842