Your Petitioner JackJack represents
that he was born in AfricaAfrica, was
brought from AfricaAfrica to South CarolinaCarolina , was
brought from South CarolinaCarolina to the City of
Saint LouisSt Louis in the County of SaintCounty of Saint Louis LouisCounty of Saint Louis and
StateMissouri ofMissouri MissouriMissouri by David Williamson and
sold by him to Charles CollinsCharles Collins , who sold him to JamesJames English and the said
English took him to Carolton in the State of IllinoisIllinois
in the year One thousand eight hundred Twenty nine
where he said JackJack resided
Twelve Months and that he was brought from
IllinoisIllinois to Saint Louis & Saint louis County & StateMissouri
ofMissouri MissouriMissouri by the said Charles CollinsCharles Collins , that he
now resides in the City, within the County of SaintCounty of Saint Louis
LouisCounty of Saint Louis & StateMissouri ofMissouri MissouriMissouri

Your petitioner states that he
is still held in slavery by the said Charles CollinsCharles Collins
in the County of SaintCounty of Saint Louis LouisCounty of Saint Louis and State ofMissouri MissouriMissouri
when he is advised and believes that he is entitled
to his freedom and therefore your petitioner prays
that he may be permitted to sue in forma pauperis to
estabish his right thereto and that other and further
orders may be made in the premises as the law directs,
and as may seem & proper to this Hon Court

This day came before me JackJack

the above named petitioner & on his
oath says that the facts in the above petition
stated are true

The within named JackJack is hereby permitted
to sue as a poor person to establish his right to free
-dom and George FGeorge F Strother . StrotherGeorge F Strother Esquire is assigned as his counsel. It is moreover order that the said
JackJack have reasonable liberty to attend his his counsel
& the court when occasion may require: and that
he shall not be taken out of the jurisdiction of the
Circuit CourtCircuit Court for the County ofCounty of St Louis St LouisCounty of St Louis,
> nor be subject to any severity because of his application
for freedom

Petition to sue in
forma pauperis

Served this writ on Charles CollinsCharles Collins
on the 17th March 1831 by offering to read
it & the declaration to him which he re-
fused to hear read & acknowledged service the order endorsed on said writ by
reading it to him on the same day at
at the same place

The other defendantWilliamWilliam not
found in my County
9July 1831

Trespass assault & battery &
false imprisonment
The Clerk will issue sum

Dismissed at defendants costsBook 6 page 285
Archibald GambleArchibald Gamble Clerk

Saint LouisSt Louis County Jack a man of colour who by
permission of the Court sues in forma pauperis complains of
WilliamWilliam Sewel SewelWilliam Sewel Charles CollinsCharles Collins For that on the first day of September in the Year of our Lord 1830the said
Charles CollinsCharles Collins made an assault on the said JackJack
to wit at the City of SaintSt Louis LouisSt Louis
StateMissouri of MissouriMissouri and then and there seized and laid
hold of the said JackJack and with great force and violence
pulled, and draged about him the said JackJack and
then & there struck the said JackJack a great many violent
blows and strokes and then and there imprisoned the
said JackJack and kept and detained him the said JackJack ,
in prison there without any reasonable or probable cause
whatsoever for a long space of time to wit for the space of
six Months then next following contrary to law and against
the will of the said JackJack whereby the said JackJack was then and
there not only greatly bruised and wounded and was thereby greatly
exposed and his life endangered to wit within the County
aforesaid And the said JackJack avers that before and
at the time of committing the said grievances he was &
still is a free person and that the defendant CharlesCharles Collins
CollinsCharles Collins held and detained him and still holds and
detains him in slavery to wit within the County ofCounty of Saint Louis SaintCounty of Saint Louis
LouisCounty of Saint Louis aforesaid and other wrongs to the said JackJack ,
then and there did against the peace of the State and
to the damage of the said JackJack of Five hundred
dollars and therefore he brings suit

We command you to summonWilliamWilliam Sewel SewelWilliam Sewel and Charles CollinsCharles Collins
that they be and appear before the Judge of our Circuit CourtCircuit Court at
the next term thereof to be held at the City of S LouisS Louis within and
for the County ofCounty of S Louis S LouisCounty of S Louis on the fourth monday of March next
then and there to answer unto JackJack a man of Color of a Plea of
assault & battery and false imprisonment to the damage of said
plaintiff of five hundred dollars and have you then there this writ

The within named JackJack is hereby permitted to sue as a poor person
to establish his right to freedom and GeorgeGeorge F Strother F StrotherGeorge F Strother Esquire is
assigned as his counsel- It is moreover ordered that the said JackJack
have reasonable liberty to attend his counsel & the court when occasion
may require, and that he shall not be taken out of the Jurisdiction
of the CircuitCircuit Court CourtCircuit Court for the county of S LouisS Louis nor be subject to any sever-
ity because of his application for freedom