Squire Brown, a man of color v. Charles Anderson
View original image: Page  001
[missing figure]

To the Honorable BryanBryan Mullanphy MullanphyBryan Mullanphy Judge
of the Circuit CourtCircuit Court of St Louis County

The petition of Squire
BrownBrown a man of color respectfully
. That at the July Term of the
St LouisSt Louis Cricut Court for the year eighteen hundred forty one. Your petitioner
institutes a suit for freedom in order
to establish his right to freedomand
one WilliamWilliam who then claimed
to be owner of your petitioner, that previous
to the instituion of said your had
made an order grantingleave to your
petitioner to sue as a poor person for an
above purpose. also an order that your
petitioner have reasonable
liberty to leture his Counsel & the Court as
occassion might require that he be
notremoved out of the jurisdiction
of said Court- & be not subject to any
severity on account of his application for
freedom. That the same term your
assigned Davis Dayton
as counsel for your petitioner in the above
mentionedsuit.

Your petitioner final his repre
sents that. the institution of said
suit the said WilliamWilliam anderson has
as your petitioner his been informed &
believessold your petitioner to one CharlesCharles
anderson who now claims to be the owner
of or is exercising acts of ownershipover your
petitioner. That the said CharlesCharles anderson
has threatened to sell your petitioner & have
himremovedfrom the Statebeyond the

View original image: Page  002
[missing figure]
jurisdiction of said Court & your petitioner
verilybelieves that prevented by
the interference of your the said
AndersonAnderson will of your petitioner
& have him removedbeyond the juris
diction of this Court. Your petitioner
further represents that said AndersonAnderson
has for some time past up to the
thirty-first day of July instant hired out
your petitioner & received the whole of his
wages. refused to furnish your petition
er with a singlearticle of clothing al
though your petitioner has frequently re
quested& stands in great needclothing
& the said AndersonAnderson has repeatedlytold
your petitiioner that he would not
furnish him with any clothing un
less. Your petitioner would con
sent to a dismissalof said suit.
and your petitioner represents
that the said AndersonAnderson he is now
confined in the jail of St Louis County
by the said AndersonAnderson without any
good cause whatever that your petitioner
is aware of, but your petitioner believes
that he is thus confined for the purpose
of being to dismiss the said suit
your petitioner therefore prays that your
Honor will grant such relief as the
motion of the Courtrequires.

Squire his BrownBrown
mark