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

To the Hon Judge of the Circuit CourtCircuit Court of
St Louis County

Your petition respectfully states to the said
your Honor Court,that the person mentioned in the Declaration above
is sold in slavery by WilliamWilliam Head in this county
said that she the said MaryMary BrownBrown is entitled to him freedom
in consequence of a certain proceeding had in
the State of VirginiaState of Virginia to wit JennyJenny Brown BrownJenny Brown the mother of said MaryMary was brought
into the said State of VirginiaState of Virginia By her then Master for the purpose of sale
Contrary to the laws of the state of VirginiaVirginia by reason of which she was then and is now a free person and was
afterwards brought to the State of MissouriMissouri and in
said State of MissouriMissouri has been kept in slavery against her will
for more than twenty years during which time the said MaryMary
was born and is now of the age of fifteen years.

Your petition prays
this court to permit and allow her to sue as a free person
to establish her right to freedom and as unduly found the
pray -
Sworn to and subscribed before on the 14th day of October 1844

JamesJames J JJames J Purely a Justice of the CountyCircuit Court
CourtCircuit Court & for St Louis County JennyJenny her