Jesse, a man of color v. George W. Coons
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To the Honorable John M. KrumJohn M Krum , Judge of the
Circuit Court of the Eighth Judicial Circuit:

Your petitioner, JesseJesse , a man of color, would
humbly represent to your Honor that he was
purchased and held as a slave by one MiltonMilton
Duty, in his lifetime, sincedeceased, that
the said Duty, being there a resident of the
State of MississippiMississippi, by his last will and
testament, dated the twenty-sixth day of October A.D. 1836, directed that, at his decease
your petitioner among other slaves which
he then owned, should be manumitted
and set free. Your petitioner further
represents that the said Duty removed your
petitioner, amongst other his said slaves,
to the State of MissouriMissouri in the month of
March A.D. 1837, and in the month of
August A.D. 1838, departed this life in
the city and county of St. LouisSt Louis and StateMissouri
of MissouriMissouri, having made no other will
than the one above mentioned; that the
said will was, as your petitioner is informed
and believes, established and admitted
to Probate, in the Probate court of
WarrenWarren County CountyWarren County in the State of MississippiMississippi
on the twenty-sixth day of November A.D. 1838, and, on the twenty second of June A.D. 1839, was recorded, as the last will and testament
of the said Duty, in the CountyCounty St Louis Court
of , and letters of administration
thereof granted to one George WGeorge W .|Coon, of the said city and county of StSt Louis.
LouisSt Louis, who now, as your petitioner verily

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believes, wrongfully and unjustly holds your
petitioner in slavery. Your petitioner therefore
humbly prays your Honor that he
may be allowed to prosecute this his suit
for freedom, as a poor person, that counsel
be assigned him, and that the usual
orders in such cases be made on his behalf,
and as is duty bound he will
ever prays âC.