The petition of HarrietHarriet an infant under twentyoneyears of age
by JuliaJulia her mother respectfully that your petitioner
is free but that she is held as a slave in St LouisSt Louis by within
SamuelSamuel TMcKinney or Thomas DThomas D James JamesThomas D James a negro trader.
Your petitioner states that in October 1829LucindaLucinda Carrington CarringtonLucinda Carrington
& her children settled in the state of IllinoisIllinoiswith the
intention of making that state their permanant residence
& that said LucindaLucinda & her family have resided there
ever since your petitioner states that said LucindaLucinda
on her arrival in IllinoisIllinois as aforesaid brought with
her your petitioners & her mother claiming & holding
them as slaves & having owned them as such in the
state of KentuckyKentucky - your petitioner states that said LucindaLucinda
kept her mother & her in the state of IllinoisIllinois in the county
of PikePike which she had selected for her residence from the
27 or 28th day of October 1829 untill the 26th day of December in the same year during all of which
time the said LucindaLucinda required services of your
petitioner & her mother as her slaves & kept your
Petitioners mother at labor as such slave in her family
your petitioner states that after it became a talk that
your petitioner & her mother were free among the neighbors
of MrsCarringtonCarrington she said LucindaLucinda Carrington CarringtonLucinda Carrington caused
your petitioners mother & your petitioner to be taken to
MissouriMissouri & there hired out as her slaves your petitioner
states that after she & her mother had been hired
for about nine months in MissouriMissouri they were
again taken back to IllinoisIllinois where they were again
by said LucindaLucinda Carrington CarringtonLucinda Carrington kept & treated as
slaves for about eightweeks when they were sent
to MissouriMissouri & sold to SamuelSamuel FMcKinney
your petitioner prays that she may be permitted to sue
as a poor person to establish her freedom that
counsel may be assigned to her & that such

further orders may be made in her behalf as her case
requires & the lawprovides & she will this pray

Petition of HarrietHarriet for
leave to sue for freedom
&c

PetitionRevisedBook 6 page 459
& order for leave to sue

HarrietHarriet an infant under twenty one years of age
by GAGA Bird BirdGA Bird her next friend complains of
SamuelSamuel TT M Kinney MT M Kinney KinneyT M Kinney WilliamWilliam Walker WalkerWilliam Walker &
ThomasThomas D James DThomas D James JamesThomas D James of a plea of trespassassault
& Battery & false imprisonment for that heretoforeto wit on the first day of May 1831 at St LouisSt Louis
on said county the said defendants with
force & arms an assault did make upon the
said plaintiff & her the said plaintiff did
then & there beat wound & ill treat & her
the said plaintiff did then imprison there without any reasonable or probable cause whatsoever
& kept & detained her in prison there for a
long space of time to witfrom the day
last aforesaid & other wrongs to the said
plaintiff then & there did against the peace
& dignity of the state and said plaintiff
avers that before & at the time of committing
the said several grievances she was & still
is a free person & the defendants held &
detained & still do hold & detain her in
slaveryby means of which promises said
plaintiff says she is greatly injured & hath
sustained Damage to three hundred Dollars
therefore she sues&c.

I am writing to unto the above suit as
the next friend of said HarrietHarriet

Served this writ onS.T.McKinney
on the 11th April 1833 by reading it and the
declaration to him and on William WalkerWilliam Walker
on the 15th day of same month by reading
thewrit & declaration to him, in the city of
St LouisSt LouisThomas D JamesThomas D James not found in
my County

service	2
	.50
	$2.50

No 17
July Term 1833

HarrietHarriet an infant by
her next friend
GG A Bird AG A Bird BirdG A Bird
vs
SamuelSamuel T Mc Kinney TSamuel T Mc Kinney McSamuel T Mc Kinney KinneySamuel T Mc Kinney
WilliamWilliam Walker WalkerWilliam Walker &
Thomas D JamesThomas D James

This is an action for
freedom in form
a assault & Battery &
false imprisonment
Sum $ 300

The clerk willplease
issueasummons

We command you to summon SamuelSamuel T Mc Kinney
TSamuel T Mc Kinney McSamuel T Mc Kinney KinneySamuel T Mc Kinney Williams Walker and Thomas D JamesThomas D James
that they be and appear before the judge of our
Circuit court at the next term thereof to be held
at the city of St LouisSt Louis within and for the county
of S LouisS Louis on the fourth Monday of July next
Then and there to answer into HarrietHarriet an infant
under twenty one years who sworn by GA BirdGA Bird her
next friend of a plea of trespassassaultbattery
and false imprisonment to the damage of
said plaintiff of three hundred dollars
And have you then there this writ.