Mary, a colored woman vs. James Dougherty, Richmond J. Curle
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To the Honorable Bryan MullanphyBryan Mullanphy Judge
of the Circuit CourtCircuit Court within and for the CountyCounty of St Louis
of St LouisCounty of St Louis and State of MissouriMissouri

Respectfully and humbly represents
your petitioner, MaryMary a colored girl, that
about seven years ago the was taken from
the State of KentuckyKentucky, where she had been the
servant and slave of GeorgeGeorge WilsonWilson , by him
the said WilsonWilson and carried to Du

a place in the Territory of Wisconsin;
That the said MaryMary was so taken to the Territory
of Wisconsin by him the said GeorgeGeorge WilsonWilson
claiming to be her master and owner, for
the purpose of introducing her into the said
Territory as a slave, and was then and
there sued and held by him as a slave
and made to labor and serve as such for a
long space of time to wit for the space of
five years, he the said WilsonWilson during that
time being a resident of the Territory of
Wisconsin; That subsequently, be the said
WilsonWilson took your petitioner to DubuqueDubuque a
place in the Territory of IowaIowa, where your
petitioner resided with said WilsonWilson and labored
and served in his family as a slave, for the
space of one year; that subsequently she
left the said WilsonWilson and resided with one
DavisDavis in DubuqueDubuque aforesaid who paid her
wages for her labor; that subsequently she resided
with Judge WilsonWilson of DubuqueDubuque who is repu

ted to be a brother of the said GeorgeGeorge WilsonWilson
and that said Judge WilsonWilson paid your petitioner

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wages for her labor while in his family;
that on the evening of the 8th day of April 1842. your petitioner was taken from the house of
the said Judge WilsonWilson after right fall by force
and arms, by one JamesJames DoughertyDougherty , and being
placed on board the steam boat New Brazil, was
taken to the City and County of St. LouisCounty of St Louis
when she has since been under the control
and management,, and subjected to the
orders of the said DoughertyDougherty and one RichmondRichmond
J. CurleJ Curle of the City and County of St. LouisCounty of St Louis.


Your petitioner further states that the
said PrairiePrairie Du and the said DubuqueDubuque
are in places in the United StatesUnited States where
slavery is not allowed by the laws of the
United StatesUnited States and therefore your petitioner is
free and not a slave, and not subject by the
laws of the State of MissouriMissouri or of the UnitedUnited States
StatesUnited States to the Control of the said DoughertyDougherty or
the said CurleCurle or subject to the owner

ship of said DoughertyDougherty or said CurleCurle or any
other persons, in any manner or form.


And further your petitioner respect

fully prays that she may have leave by
an order of this Honorable court to sue
the said DoughertyDougherty and the said CurleCurle , one or both
of them, or any other person or persons
claiming to exercise ownership over her, to
establish her right to freedom, as a poor
person, and that counsel may be assigned
her. And further that the aforesaid