Samuel, an infant, by and through his next friend, Marcy T. Andrews v. Barnard Lynch
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To the Hon.Alexander HamiltonAlexander Hamilton Judge
of the Circuit CourtCircuit Court of St. Louis
County State of MissouriMissouri

.

Your petitioner
SamuelSamuel an infant by his next friend
[ Marcy T AndrewsMarcy ]T AndrewsMarcy T Andrews states that he is
a free person of colour and as
such is entitled to his freedom
for the following reasons to wit
That many years since the time to
your petitioner unknown but previous
to his your petitioners birth that his
mother MaryMary was the slave of and
owned by an Bowde in the StateKentucky
of KentuckyKentucky and that her said master
and owner removed and took with
him to the State of OhioOhio your petitioners
mother the said [ Marcy ] and there
continued as a permanent resident
and resided in said State of OhioOhio for
more than one year and as by the residence
aforesaid of petitioners mother
in OhioOhio she became and is a free person
Your petitioner claims that he is also
a free person and entitled to his freedom
But is now held as a slave by
one Barnard M LynchBarnard M Lynch .
Your petitioner
further that he is a poor person without
any estate & prays the Court for leave to sue
as a poor person according to the statute
in said cases provided.

EdwardEdward

by
his next friend

M T Andrews.