Jane, a woman of color v. William Dallum
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To the Circuit CourtCircuit Court for the CountyCounty of St Louis ofCounty of St Louis St. LouisCounty of St Louis.

This petition of JaneJane , a woman of colour, re
-presents to this honorable count, that she, as she believes,
is entitled to her freedom on the following grounds: she
was formerly the slave of Col.Dallam, of MarylandMaryland, and
by him taken to the State ofKentucky KentuckyKentucky, where she resided within a few years since; that before her said
master removed her he informed her that he had man-
her, such manumission to take effect at a
future nine, and she believes that said manumission
was by deed and that the deed is now of record in the
proper office in MarylandMaryland, where it can be obtained. She
also states that some time after her in KentuckyKentucky.
She was by her said master actually freed and discharged
from all service and obedience, he giving her complete
and perfect personal liberty and power to do with her-
self what she pleased and requiring from her neither
services nor wages for her time. That from that time
until the time of her master's death, a period of from
ten to fifteen years, the She lived as a free person, with
the consent of her master as aforesaid and in the same
town or neighborhood with him. That she was brought
to St. louis byWilliamWilliam DallamDallam a son of her said master, who afterwards went to KentuckyKentucky, and that she is now claimed by
him as his slave, and restrained of her liberty and at
this time confined in jail by the order of a certain
Munday, who she believes acts asthe agent

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of the said WilliamWilliam DallamDallam . The said JaneJane also states
that she is confident that if she shall be allowed to
institute suit for her freedom as a poor person that
she will be able to establish her right thereto by
legal evidence, and she therefore prays that she may
be allowed to sue as a a poor person and that their
honorable Court will assign her counsel to
prosecute her suit for her. And she will ever pray &c
Jane