Mary Brown, by and through her next friend, Jenny Brown vs. William Head
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State ofMissouri MissouriMissouri
St Louis County

In the St LouisSt Louis Court
Nov Term 1844

MaryMary BrownBrown who sues by her next friend
JennyJenny Brown BrownJenny Brown complains of WilliamWilliam Head
of pleas of Trespass and False imprisonment
For that whereas the said defendant on the
day of September in the year Eighteen hundred and forty fourmade an assault upon the said plaintiff
and then and there imprisoned had bruised and ill
-treated the said Plantiff and kept and detained
in prison then and there without any reasonable
or probable cause whatever for a long span of
time for the span of Twelve hours then
next following contrary to the laws of the said
state and against the will of the said plaintiff

And the said plaintiff further
owns that the said plaintiff before and at the commit
-ting of the grievances was and still is free
person. And that the defendant then and there
hold and still holds the said plaintiff in slavery
And other wrongs that the said plaintiff
said defendant then and there did Contrary to
the laws and dignity of the said State And hath
damaged the said plaintiff of Five Hundred
dollars Therefore the said plaintiff sues

EliasElias B. SmithB Smith


p.q.