Jim Brown, by and through his next friend, Jenny Brown vs. William Head
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State of MissouriMissouri
as
St. Louis County
To the Hon. Judge of the Circut CourtCircuit Court of St. Louis County

ss

Your petitioner respectfully states to the
Court Your Honor that the honor mentioned in the Declaration above is
held in slavery by WilliamWilliam Read in this County and that
he the said Louis is entitled to his freedom. In Consequence of a action proceeding him in the state of Wrynim County to the laws of the
state of VirginiaVirginia to wit Jenny BrownJenny Brown the mother of said Jim
was brought into the state of VirginiaVirginia for the purpose of sale
by him the MartinMartin of which slaves then and is now a free person and was afterwards brought to
the state of MissouriMissouri and in said state of MissiouriMissouri she has
been held in slavery for more than twenty years against
her will during which time the said Lein was born
and now of the age of. fourteen years (14 years)

Your petitioner therefore prays your
Honor to allow him to sue as a free person
to establish his right to freedom and duly

Sworn to and submitted before me the 14th day Oct.1844
James JJames J Purely a Justice of the CountyCircuit Court
CourtCircuit Court and for St. Louis County JennyJenny her

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