To the Honourable WilliamWilliam C CarrCarr Judge of the Circuit CourtCircuit Court
for the 3rd - Judicial Circuit in the State of MissouriMissouri now sitting
for the County of St. LouisCounty of St Louis, your petitioner DollyDolly a colored woman
about 40 year of age resident of St. LouisSt LouisHumblyHumbly to yourHonour
that the is now held in slavery by a certain John Young &
your petitioner humbly conceiving that she is entitled to her
right to freedom prays that she may be permitted to
institute a suit (as a poor person / for purpose of obtaining the same and that
counsel may be assigned her, your petitioner states, that
the ground upon which she claims her freedom is that
the said John Young conveyed her to the Fever River
mines in the north western Territory, & / kept and detained
her there six months contrary tothe, usages & customs
of that County and your petitioner as is duty bound
will pray &c

George FGeorge F Strother StrotherGeorge F Strother and James Evans present the petition of DollyDolly a woman of
Color praying that she may be permitted to institute suit againt John Young to
Establish her right to freedom and that she may be permitted to sue as a poor person
therefore the Court permits the said DollyDolly to sue as aforesaid and direct that an action
of assault and battery and false imprisonment be commenced against the said John
Young in the name of the said DollyDolly and assign James Evans and GeorgeGeorge F Strother FGeorge F Strother StrotherGeorge F Strother
Esquires as her Counel and it is ordered by the Court that the said defendant permit
the said DollyDolly to have a reasonable liberty of attending her counsel and the Court
when the occasion may require it and that the said DollyDolly the plaintiff shall
not be taken or removed out of the juridiction of this court and that she shall
not be subject to any severity of treatment on account of her said application
for freedom -

DollyDolly
vs
Jn. Young
petition filedmarch 26th 1828

DollyDolly a coloured woman by her attorneys
complain of John young of a plea of Trespass
assault Battery & False imprisonment. For that
the said John Young on the day of in
the year A.D 1827, with force & arms & made an
assault upon the said DollyDolly , towit, at the County ofCounty of St Louis
StCounty of St Louis. LouisCounty of St Louis aforesaid & there & there seized & laid hold
of the said DollyDolly & with great force & violence took
& conveyed the said DollyDolly to Fever river in the North
Western Territory & then & there imprisoned the said
DollyDolly & kept & detained her in prison without
justifiablecausewhatsoever for a long space
of time, towit for the space of sixmonths then
next following contrary to the laws of the
said North Western Territory and the said DollyDolly
aver, that before and at the time of the committing
of the grievances she was & still is a free person
& that the Deft held & detained her still holds &
detainsherinslavery against the will of the said
DollyDolly , whereby she the said DollyDolly was then & there
greatly exposed injured & restrained of her liberty
towit at the County aforesaid & other wrong to
the said DollyDolly there & there did against the peace
& diginity of the state aforesaid & other damages of the
said DollyDolly five hundred dollers therefore

Executed this writ on John young April 12th 1828 in the
City of S LouisS Louis by reading the same to him

DollyDolly
vs
John Young

This is an action of Trespass
assault & Battery & False imprisonment

StrotherStrother Evans & EvansStrother Evans PQ

We command you to summon John Young
that he be and appear before the Judge of our CircuitCircuit Court
CourtCircuit Court at the next term thereof to be held at the
city of S LouisS Louis within and for the County of S LouisCounty of S Louis
on the fourth monday of July next then and there
to answer unto DollyDolly a woman of color of a plea
of Trespassassault&Battery & false imprisonment
to the damage of said plaintiff of five hundred
dollars and how you then there this writ

Your petitioner DollyDolly a free woman
of color, now held in slavery by John Young represents
to your Honor, that by an order of the Circuit
Court of the said County of St LouisCounty of St Louis made at the
last March Term of said Court, obtained an order
permitting of the said DollyDolly to institute suit against
the said John Young to establish her right to freedom
that to declaration of this petitioner was
filed against the said John Young for the threats and
declaration of the said John Young your petitioner
has reason to believe and does beleive, that because
of her application for freedom, the said John Young
will treat her with great severity and that he will remove
her out of the jurisdiction of this court before
the trial of the said cause instituted to establish her
right to freedom your petitioner therefore prays

that your Honor may issue a writ of HabeasCorpus
and have your petitioner brought before you and
cause the said John young to enter into a recognizance
with security agreeable to CarrCarr & your petitioner

Be it remembered that on
this 12th day of May 1828. personally appeared before me
the subscribed judge of the Circuit aforesaid
John Young and DougalOFerguston Jr.
of the county of St LouisSt Louis and acknowledge them
to owe to the state of missouri the sum of
four hundred dollars each, to be levied of their
respective goods & chattles lands & tenaments
on condition following whereas one DollyDolly
a coloured woman has instituted suit
against said John Young to by her right
to freedom agreeably to the statute in such
cases made & provided & has petitioned
the undersigned to cause the said John
Young to enter into recognizance eith securety
that she the said DollyDolly shall not be removed
out of the jurisdiction of the Circuit CourtCircuit Court
for the County of St LouisCounty of St Louis now therefore if the
petitioner DollyDolly shall at all times during the
pendency of the suit aforesaid have reasonable
liberty of attending her counsel and shall not
be removed out of the jurisdiction of the court
aforesaid & that she shall not be subjected to
any severity because of her application for
freedom, then this recognizance to be void
otherwise to be in full force & effect

You are hereby commanded that the
body of a certain woman of colour named DollyDolly in your
custodypossession or power (who has been permitted
to institute suit against you to establish her right
to freedom and who has petitioned me to issue a
writ of habeas corpus to cause you to give security
that you will not remove her the said
DollyDolly out of the jurisdiction of the court agreeably to
the provisions of the statute in such cases made
& provided) you have before me at my house
at the hour of twoO Clock to day then & there to
do subject to & receive what of right ought
to be done in the premises

"By the HabeasCorpus
Act."

State missouri
vs
John Young

The within named John appeared before
me aspursuant of the within writ
& having entered into recognizance
agreeably to the statute in such cases
made & provided with
FergusonFerguson as security the said DollyDolly
is remanded into his possession.

at chambers may 12th 1828.

Wll. C. CarrCarr

and the said John Young by his attorney, comes and defends the force and
injury when & and says that he is not guilty of the said supposed trespass above
laid to his charge, or any part thereof, in manner and form as the said DollyDolly hath
above thereof complained against him. And of this he the said John Young puts himself
upon the county

John Young
ats
DollyDolly

pleas
issue or
not guilty

You are hereby commanded to summon William SkinnerWilliam Skinner Herman L HoffmanHerman L Hoffman
Otis ReynoldsOtis Reynolds . Thomas CohenThomas Cohen -
that setting aside all manner of excuse and delay, they be and appear in proper person before the Judge
of our Circuit CourtCircuit Court ,on theforthwithday of, at the City of StCity of St Louis.
LouisCity of St Louis, then and there to testify and the truth to say in a certain matter of controversy now pending
in our said Court, wherein DollyDolly is plaintiff,
and John Young is defendant,
on the part of the plaintiff; and have you then there this writ.

DollyDolly
vs John Young

William SkinnerWilliam Skinner .

Herman LHerman L Hoffman .HoffmanHerman L Hoffman

OtisOtis Reynolds ReynoldsOtis Reynolds

ThomasThomas Cohen CohenThomas Cohen .

Executed the writ on WSkinner H.L Hoffman. OtisOtis Reynolds
ReynoldsOtis Reynolds & Thomas CohenThomas Cohen April 6. 1829 by reading
to them the same

Execute

You are hereby commanded to summon WilliamWilliam Skinner SkinnerWilliam Skinner HermanHerman L Hoffman L HoffmanHerman L Hoffman
OtisOtis Reynolds ReynoldsOtis Reynolds and Thomas CohenThomas Cohen
that setting aside all manner of excuse and delay, They be and appear in proper person before the Judge
of our Circuit CourtCircuit Court , on the Fifth day of August, at the city of StSt Louis.
LouisSt Louis, then and there to testify and the truth to say in a certain matter of controversy now pending in
our said Court, wherein DollyDolly is plantiff
and JohnYoung is defendant,
on the part of the plantiff; and have you then and there this writ.

Executed this writ on WilliamWilliam Skinner SkinnerWilliam Skinner . HermanHerman L Hoffman LHerman L Hoffman
HoffmanHerman L Hoffman &ThomasThomas Cohen CohenThomas Cohen June 5th 1828OReynolds
not found

DollyDolly

John young
for the plaintiff

WilliamWilliam Skiner

Herman L HoffmanHerman L Hoffman
OtisOtis Reynolds ReynoldsOtis Reynolds

ThomasThomas Cohen CohenThomas Cohen

You are hereby commanded to summon WilliamWilliam Skinner SkinnerWilliam Skinner Herman LHerman L Hoffman HoffmanHerman L Hoffman
OtisOtis Reynolds ReynoldsOtis Reynolds Thomas CohenThomas Cohen
that setting aside all manner of excuse and delay, they be and appear in proper person before the
Judge
of our Circuit CourtCircuit Court , on the First day of December, at the city of
St. LouisSt Louis, then and there to testify and the truth to say in a certain matter of controversy now pending
in our said Court, wherein DollyDolly is plantiff
and JohnYoung is defendant,
on the part of the plantiff-; and have you then and there this writ.

Executed this writ on ThomasThomas Cohen CohenThomas Cohen Nov 2nd on
WilliamWilliam Skinner SkinnerWilliam Skinner & Herman L Haffman Nov 3rd on Otis ReynoldsOtis Reynolds Novr 4th 1829 by Reading
the server to them

DollyDolly
vs
John Young
for plaintiff

WilliamWilliam Skinner SkinnerWilliam Skinner 3

Herman L HoffmanHerman L Hoffman 3
OtisOtis Reynolds ReynoldsOtis Reynolds 4

ThomasThomas Cohen CohenThomas Cohen 2