Margaret vs. George Brown, William Dallam
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To the Honourable the Judge of the St Louis CircuitCircuit Court
CourtCircuit Court . This petition of MargaretMargaret , HenryHenry â SallySally ,
persons of colour, represents to your Honour, that
they, as they belive are entitled to their freedom on
the following grounds: theirmotherJaneJane was formerly
the slave of Col.Dallam of MarylandMaryland and by
him taken to the State ofKentucky KentuckyKentuckyâ where
she resided untill a fewyears since, and where your
your petitioners were born, that her
master removed her from MarylandMaryland he informed
her that he had manummitted her, such
manummissions to take effect at a future
time, and that said time had elapsed before your
petitioners were born; your petitioners say
that they are informed â believe that said
manummission of their matter was by deed
and that the deed is now of record in the proper
office in the state of MarylandMaryland, which can be
obtained. They also state that some time after
the arrival of their mother in KentuckyKentucky she
was by her said master actually freed â discharged
from all service â obedience, he giving her
complete â perfect personal liberty and power
to do with her self what she pleased, and requiring
from her neither service or wages for her time.
That from that time until the time of her masters
death a period from ten to fifteen years she
lived as a free person with the consent of her
master as aforesaid in the same town or neighborhood
with him. That they your petitioners
were with their mother, brought to St LouisSt Louis by
a son of their old master Cal Dallam namely
WilliamWilliam DallamDallam , who afterwards went to KentuckyKentucky

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and that they are now claimed by him as his slaves
and that said DallamDallam by his agents have been and
now are making preparations to carry off your
petitioners to the South beyond the reach of
assistance â where it will be impossible for
them to assert their right to freedom your petitioner
say that they are all imfants under twenty
one years- they therefore pray that they may
severally be permitted to sue as poor persons
by their next friend George BrownGeorge Brown , and that
your honour will assign them counsel for
to prosecute their suits for freedom- And as
your honour has already authorized their
said mother to sue for her freedom, your petitioners pray your honour to grant them
the same privilege in which case they believe
they will be able to establish their right to
freedom â your petitioners will pray etc

HenryHenry
Sally
Margaret
by
their next
friend

George BrownGeorge Brown

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State of MissouriMissouri

Third Judicial Circuit CourtCircuit Court : It is hereby ordered
that an the foregoing petition that the subscribers thereto
HenryHenry , SallySally and MargaretMargaret be permitted to sue as
poor persons by GeorgeGeorge Brown BrownGeorge Brown their next friend
to establish their right to freedom and JohnJohn Newman NewmanJohn Newman
Esq is assigned on their counsel - It is also ordered
moreover that said HenryHenry SallySally and MargaretMargaret shall have reasonable
liberty to attend their counsel and the Court when other occasion may require
â that said HenryHenry , SallySally and MargaretMargaret not be removed out of the jurisdiction
of the Circuit CourtCircuit Court of St Louis County nor be Subjected to any
severity because of their application for freedom given under
my hand their 22 day of July A.D 1831.

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Margaret
Sally â
HenryHenry
Petition

Filed July 22nd 1831

A gamble Clk

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The defendants not found in my
County 12th Novr 1831

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No 4

St Louis Circuit CourtCircuit Court
November Term 1831

MargaretMargaret by next friend
vs
WilliamWilliam
Declaration

Dallow

Filed 23rd July 1831

Archibald GambleArchibald Gamble Clerk

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This is an action of trespass
assault â battery â false
imprisonment
$ 500 summons

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In the St Louis Circuit CourtCircuit Court
County of St LouisCounty of St Louis, to wit, November Term 1831

MargaretMargaret a girl of colour
an infant under the
age of twenty one years by GeorgeGeorge Brown BrownGeorge Brown her
next friend complains of WilliamWilliam Dallow in
custody â of a plea of trespass of assault â battery
â false imprisonment for that heretofore
to wit, on the twentieth day of july in the year Eighteen hundred â thirty one at the county aforesaid
the said Defendant with force â arms made
an assault upon the said plaintiff â then
â there beat wounded â ill treated her and then
â there with force and arms falsely â unlawfully
imprisoned the said plaintiff â kept her and
detained her in prison there without any
lawful authority or cause for a long space of
time to wit for the space of twodays there next
ensuing - and said plaintiff further says that
before and at the time of the committing of the
said several grievances she was â still is a
freeperson â that said Defendant held â detained
â still holds â detains her in slavery wherefore
the said plaintiff says she is greatly injured
and hath sustained damage to fivehundred
dollars â therefore she sues â etc

JohnJohn Newman NewmanJohn Newman esq

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The State of MissouriMissouri
County of Saint LouisCounty of Saint Louis. ss

To the Sheriff of the county of Saint LouisSt Louis
Greeting

We Command you to summon WilliamWilliam DallamDallam that he be and appear
before the Judge of our Circuit CourtCircuit Court at the next November term thereof
to be held at the city of St LouisSt Louis within and for the County of Saint LouisCounty of Saint Louis
on the fourth monday of November next then and there to answer unto
MargaretMargaret a Girl of color an infant under the age of twenty one years by George BrownGeorge Brown her next friend of a plea of trespass assault and Battery and false imprisonment wherefore the said plaintiff says she is greatly injured
and hath sustained damage to five hundred dollars and have you then there
this writ

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Witness Archibald GambleArchibald Gamble Clerk of our sid CircuitCircuit Court
CourtCircuit Court at Office this Twenty Second day of July One thousand Eight Hundred and thirty one

Archibald GambleArchibald Gamble Clerk

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copy of the order of the Judge on endorsed on the petition of plaintiff â

State of MissouriMissouri- Third Judicial Circuit to wit; It is hereby ordered that on
the foregoing petition that the subscribers thereto HenryHenry SallySally and MargaretMargaret be
permitted to sue as poor persons by George BrownGeorge Brown their next friend to establish
their right to freedom and JohnJohn Newman NewmanJohn Newman Esq is assigned as their counsel it
is also ordered moreover that said HenryHenry SallySally and MargaretMargaret shall have
reasonable liberty to attend their counsel and the court when occasion may
require and that said HenryHenry SallySally â MargaretMargaret shall not be removed out
of the Jurisdiction of the Circuit CourtCircuit Court of St Louis County nor be subjected
to any severity because of their application for freedom- given under my
hand this 22 day of July A D 1831

WillWill C CarrCarr