Samuel, an infant, by and through his next friend, Marcy T. Andrews v. Barnard Lynch
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[missing figure]
SamuelSamuel By next friend
MaryMary T Andrews
Barnard M LynchBarnard M Lynch

In the Circuit CourtCircuit Court of
St. Louis County, StateMissouri
of MissouriMissouri, November Term 1851

Plaintiff amends his original petition filed in this cause and states that at the
time his mother MaryMary mentioned in his
original petition resided in the State of OhioOhio as is
stated in said petition that slavery and involuntary
servitude was prohibited in said
State of OhioOhio and she the said MaryMary became
free and is a free person because of her residence
in the aforesaid State of OhioOhio and as plaintiffs
mother was at the time of his birth a free person, he
also is free.
Plaintiff states that before and at the
time this suit was commenced that defendant
held and still holds him in slavery and he
therefore asks Judgement for his freedom.

SamuelSamuel By next friend

[ Marcy T AndrewsMarcy ]T AndrewsMarcy T Andrews

By att.

RichmondRichmond Joel