next friend [ Marcy T AndrewsMarcy ]T AndrewsMarcy T Andrews
Barnard M LynchBarnard M Lynch defendant
In the CircuitCircuit Court
CourtCircuit Court of St. Louis
County StateMissouri of
Plaintiff by his next friend
states that he is a free person of color
and that he is entitled to his freedom for the
reasons following to wit.
years since his (plaintiff's) mother was
taken by her then owner and master
Bowde from the State of KentuckyKentucky to
the State of OhioOhio to which latter named
State he Bowde removed and resided permanently
as a citizen for more than
twelve (12) months having plaintiff's
mother in possession and thereby
(her residence in the State of OhioOhio) she became
and is free.
Plaintiff states also that since
the time at which his said mother was
taken to and remained in the State ofOhio
OhioOhio that he has been born and then
that his mother being a free person
he is also free and entitled to his
freedom. And therefore plaintiff
prays judgement for his freedom
against the defendant Barnard MBarnard M Lynch
LynchBarnard M Lynch who claims
owner to be plaintiff's owner.
M. T. Andrews.