Andrew Dutton, a boy of color, by and through his next friend, Grace Dutton v. John Paca
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BetheHonorable the Judge of the Circuit CourtCircuit Court of St Louis
County

The petition of AndrewAndrew DuttonDutton a free boy of color
an infant under the age of twenty one years by Trace
DuttonDutton his mother and next friend respectfully repre-
sents that his grand mother who was named HannahHannah
was a slave the property of one JosiasJosias Dallam WilliamWilliam DallamJosias Dallam
in the state of MarylandMaryland and that the said DallamDallam
while he so owned the said HannahHannah on the thirteenth day of March in the year seventeen hundred and eighty seven excuted a deed of manumission by which
he emancipated the said HannahHannah at the expiration
of thirteen years from the date of said deed with
the provision in said deed that all the children or
childrens children that might descendfrom said
HannahHannah and be born inslavery after the date of
said deed should be free at twenty three years of age
Your petitionerrepresents that his mother named Grace
was the daughter of said HannahHannah and was born
about the year seventeen hundred and ninety two
and that your petitioner was born about the month of June year eight
teen hundred and eighteen and after his mother the
said Grace had passed the age of twenty three years
your petitioner further states that his mother the said
Grace is in the enjoyment of her liberty but that your petitioner
is held as a slave by John PacaJohn Paca of the county
of StSt Louis LouisSt Louis who claims your petitioner as his property by
reason of his marriage with a daughter of said JosiasJosias Dallam
WilliamWilliam DallamJosias Dallam wherefore your petitioner prays
that he may be permitted to institute a suitagainst
the said John PacaJohn Paca to recover his freedom and that
he may be permitted to sue as a poor person and that
counsel may be assigned to him according to law her

Grace her

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mark
next friend

Gest
H R GambleH R Gamble