"Plaintiff states she was born in the empire of Russia on the 26th day of February, 1879, of poor Hebrew parents; that her father died about one month after her birth, and that her mother remarried a short time thereafter; that in the month of September, 1889, plaintiff arrived in the city of St. Louis, Mo., in a state of penury, illiteracy, ignorance, without a guardian, and emancipated, and for three years thereafter, and without any educational opportunities, and without a guardian, provided for herself by securing employment from others for wages in the several successive capacities of nurse girl, apprentice and domestic, while her scant earnings were appropriated by a relative for procuring transportation to America for plaintiff's elder sister, and which sister was, at the times hereinafter stated, defendant's wife.
"That on or about the 1st day of August, 1892, and at all times hereinafter stated, plaintiff was able-bodied, but illiterate and ignorant of her personal rights, and was without a guardian, but was able to and did perform the duties of nurse girl, domestic and scrub girl, and that the services in said city at the times hereinafter stated of a domestic and scrub girl, of the nature as hereinafter shown to have been performed by plaintiff for defendant, were reasonably worth $18.00 per month, plus board and lodging.
"That, at all times hereinafter stated, defendant was a thrifty retail merchant and householder of the Hebrew race, with full knowledge of plaintiff's status, ability as a domestic, and of her illiteracy and ignorance.
"That on or about the 1st day of August, 1892, in said city of St. Louis, defendant took possession and control over plaintiff's person and mind and placed plaintiff in his household as his domestic, and as scrub
woman of his store, and thereafter for a period of six years, ending August 1, 1898, and again during the period from June 1, 1899, to August 1, 1902, and again during the period from August 17, 1904, to March 17, 1905, defendant at all times so employed plaintiff to the full limit of plaintiff's physical capacity, and at all times denied plaintiff all opportunities for securing the rudiments of or any education, and defendant moulded plaintiff's mind and character to his own exclusive use and benefit as his domestic, and denied plaintiff the right to receive and enjoy or invest the said value of her said servitude; that during the said first period of six years, ending August 1, 1898, under the facts stated, defendant acted as plaintiff's guardian and curator de son tort, and as such defendant converted plaintiff's said earnings to his own personal use, and invested the same in his business and converted the accrued profits from his said investment to his own use, and at all times kept plaintiff in ignorance of her personal rights to demand and secure from defendant at the end of six years an accounting and settlement for her said earnings invested as aforesaid; and defendant at all times herein stated falsely represented to plaintiff that he had a right to withhold from plaintiff said earnings until defendant and his wife in due time had selected for plaintiff a proper husband, and that when the time arrived plaintiff and plaintiff's husband would receive said earnings and profits thereon; that plaintiff, being ignorant of her rights at all times, believed and relied upon defendant's said false representations, failed to assert and exercise her said rights to such final accounting and settlement.
"That thereafter, on or about the 1st day of August, 1898, and while smarting under the physical abuses and mental neglect suffered by her during her said six years of servitude, plaintiff made her escape from defendant's home in a state of abject mental ignorance, penniless and without decent attire, and proceeded to Staunton, Ill., where for 10 months, ending June 1, 1899, plaintiff was in the employ of an uncle, at whose house plaintiff first acquired her then first knowledge of the English alphabet and of figures; that on said last-named date plaintiff was persuaded by defendant to resume, and plaintiff did resume, her former station and duties as domestic in defendant's said household and store, under the representation then and there made by defendant, and at all times believed and relied upon by plaintiff; that defendant would soon provide plaintiff with a husband, and defendant would then duly turn over to plaintiff the earnings and profits both accrued and thereafter to accrue on account of plaintiff's services; and plaintiff, for the period from June 1, 1899, to August 1, 1902, continued under defendant's said domination and employment, and on said last-named date plaintiff again made her escape from defendant's said home and went to Staunton, Ill., for the same reasons and under the same state and condition which caused her to leave defendant on the 1st day of August, 1898, as aforesaid, and plaintiff remained at Staunton, Ill., in the employ of her aforesaid uncle, until the 17th day of August, 1904, and during her second period with her uncle at Staunton, Ill., plaintiff received further instruction in the rudiments of knowledge, but continued in ignorance of her rights and of defendant's duties for an accounting.
"That on said last-mentioned date defendant again prevailed upon plaintiff to return to his home at St. Louis, under representations then and there made to plaintiff that plaintiff's said invested earnings and profits, and plaintiff's future earnings as domestic for defendant, would be duly invested by defendant and would be paid to plaintiff or to plaintiff's husband, as soon as such a suitable husband could be found, and that defendant and defendant's wife would at once address themselves to the task of securing such a suitable young man for plaintiff.
"That plaintiff, while still relying upon defendant's said representations and promises then made, and as previously made as aforesaid, and while still believing them to be true, did, from the period from the 17th day of August, 1904, to the 17th day of March, 1905, continue to perform for defendant the services of domestic at his house, and as scrub woman at his store, under conditions identical with those which had obtained during said two preceding terms of servitude under defendant, as aforesaid.
"That, a few days prior to the 17th day of March, 1905, plaintiff and defendant had together agreed upon a suitable young man as plaintiff's husband, and defendant was, on and prior to said date last mentioned, requested by plaintiff to render a full, true and correct account and make a complete settlement to plaintiff for plaintiff's said accrued and accumulated earnings, together with the accrued interest thereon, which request defendant has failed, and still fails and refuses, to do. Plaintiff states that, the premises...
