Malinda and Nelly, people of color, by and through their next friend, Beriah Cleland v. Robert Wilburn
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To the Honarable the Circuit court of the county
of st Louis

The petition of MalindaMalinda & NellyNelly free person of
colour represents

That - they have been permitted by this honorable
court to sue as poor persons, a certain RobertRobert Wilburn
WilburnRobert Wilburn to establish their freedom and that
this honorable courtâhave made an order
that your petetioners the said WilburnWilburn permit
your petitioner to have reasonable liberty of
attendending her council, said the court where occassion
may require it and that your petitioners
shall not be taken or removed out of
the jurisdiction of this court nor be subjected
to any severity because of their applications
for freedom that the said WilburnWilburn is
about to remove your petitioners out of the
jurisdictions of this court - wherefore they
pray that a writ of habeas corpus may
to bring your petitioners before this
honorable court that such proceedings
may be taken in the permissions as shall
be agreeable to law

by their next friend
BeriahBeriah Cleland ClelandBeriah Cleland