Malinda and Nelly, Free Persons of Colour, by and through Their Next Friend, Beriah Cleland v. Robert Wilburn
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To the Honorable the Circuit Court of the County ofCounty of St Louis
St LouisCounty of St Louis

The petition of MalindaMalinda and NellyNelly free persons
of Colour, held in Slavery, humbly represents.
that your petitioners were held as slaves
by a certain Robert WilburnRobert Wilburn that some time
in the year eighteen hundred & twenty and while
your petitioners were so held in slavery, taking
your petitioners with them, removed to and arrived in
the State of IllinoisIllinois, where he immediately com
menced residing and has ever since continued to
reside that the said WilburnWilburn kept and held
your petitioners as slaves, in the said StateIllinois
of IllinoisIllinois for the period of about five months
when your petitioners being about to apply
to the courts of that state to establish their freedom he the said
WilburnWilburn with a view to defeat and hinder
that application removed your petitioners
to the State ofMissouri MissouriMissouri and there holds your
petitioners in slavery - Wherefore your petitioners
pray that they may be permitted to sue in
your honorable court as a poor person to
establish their right of freedom as aforesaid
upon the facts of aforesaid

by their next friend

Beriah ClelandBeriah Cleland