James Wilkinson v. Aaron Young
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To the Circuit CourtCircuit Court of St Louis County in the State ofMissouri
MissouriMissouri

Your Petitioner JamesJames Wilkinson WilkinsonJames Wilkinson a man of color represents
to said court that he is justly entitled to his Freedom
but is now held in Slavery by AaronAaron Young in the CountyCounty of St Louis
of St. LouisCounty of St Louis & is claimed by said Young as his Slave -
your Petitioner states that in the fall of the year 1827 at StSt Louis
LouisSt Louis said AaronAaron Young agreed with your Petitioner that
he might pass free as he pleased & laboras he pleased
& that when ever your Petitioner would pay said AaronAaron
Five hundred dollars he said AaronAaron would liberate your
Petitioner from Slavery - your Petitioner says that in the
fall of 1827 & winter of 1828 - he went into the State ofIllinois
IllinoisIllinois & hired himself to labor with one Osborn in said
State of IllinoisIllinois & Laboured with Said Osborn in IllinoisIllinois
about four months & your Petitioner says that he
went into the State of IllinoisIllinois & Laboured with said
Osborn as aforesaid with the permission & consent
of said AaronAaron Young - Your Petitioner Says that
afterward in the year 1828 - your Petitioner went to
GalinaGalena in the State of IllinoisIllinois in Company with Young
the brother of said AaronAaron & Staid & Laboured at
GalinaGalena in that year about four months & your
Petitioner says that he went to GalinaGalena aforesaid &
Staid & Laboured there as aforesaid with the assent
& permission of Said AaronAaron Young - Your Petitioner
further says that after the year 1827 he paid said
AaronAaron Yang Four Hundred Dollars & afterwards as a
consideration for Petitioners freedom & that he completed
the payment of this sum more than four years ago
yet Said AaronAaron Young held your petitioner in
slavery & refuses to emancipate him your Petitioner
Prays to be permitted to sue as a poor person to
Establish his freedom that counsel may be assigned
to him & that such further orders may be made
in his behalf as his case requires & this warrants
& he will
pray &

JamesJames his WilkinsonWilkinson
Mark

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State of MissouriMissouri
St. Louis County ss

This day personally appeared before me
PatrickPatrick Walsh WalshPatrick Walsh a Justice of the Peace in
and for said county JamesJames Wilkinson WilkinsonJames Wilkinson the
within named Petitioner & I read the said
Petition to said JamesJames & he being duly sworn
on his oath says that the facts in the within
petition stated are true

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James WilkinsonJames Wilkinson
Petition for
leave to sue in
form a pauperis

filed April 2nd 1833

A GambleArchibald Gamble
Clk

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order permitting to sue Book 6 - page 446

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State of MissouriMissouriCircuit CourtCircuit Court third Judicial Circuit
July Term AD 1833.

Saint LouisSt Louis County of James WilkinsonJames Wilkinson by BirdBird his attorney
complains of AaronAaron Young of a plea of trespass on
the case for that heretofore towit on the first day
of January on the year of eighteen hundred
& Twenty eight the said defendant withforce & arms an assault
did make upon him said plaintiff & him said
plaintiff did then & there beatbruisewound & ill
treat & him said plaintiff did then & there imprison
& hath kept & detained said plaintiff in prison there
for a long span of time towit from the day last
aforesaid untill this time without any just or legal
cause whatsoever & other wrongs to the said plaintiff
then & there did against the peace & dignity of said
State. And the plaintiff avers that before & at the
time of the committing the said secured grievances he
was & still is a free person & that said defendant
held & detained & still holds & detains him in slavery
wherefore said plaintiff says he is greatly injured
& hath sustained Damages to five hundred dollars
therefore he sues &c.

G A Plffs atty

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

To the Sheriff of the county of Saint LouisSt Louis Greeting

We command you to summon AaronAaron Young that he 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 Saint LouisSt Louis on the
fourth Monday of July instant then and there to answer unto JamesJames Wilkinson
WilkinsonJames Wilkinson of a plea of trespass on the case to the damage of said plaintiff
of five hundred dollars and have you then there this writ

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Witness Archibald GambleArchibald Gamble Clerk of our said
circuit court at office this fifth day of July one thousand eight hundred and thirty three

Archibald GambleArchibald Gamble Clerk

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Gustavus A BirdGustavus A Bird Esquire presents to the court the petition
of James WilkinsonJames Wilkinson a man of color praying that he may be permitted

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to institute suit against AaronAaron Young for Establishing his right to freedom
and that he may be permitted to sue as a poor person thereupon the court permit
the said James WilkinsonJames Wilkinson to sue as foresaid and direct that an action of assault
and Battery and false imprisonment be brought in the name of the said
James WilkinsonJames Wilkinson and Assign the said Gustavus A BirdGustavus A Bird as his counsel and
it is ordered by the court that the said AaronAaron Young permit the said
James WilkinsonJames Wilkinson to have a reasonable liberty of attending his counsel and
the court when occasion may require it and that the said petitioner
shall not be taken or removed out of the Jurisdiction of this court or be
subject to any severity of treatment on account of his said application
for freedom

a true copy of the order

A GambleArchibald Gamble Clerk

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No 102

Saint Louis Circuit CourtCircuit Court
July Term 1833

James WilkinsonJames Wilkinson
vs
AaronAaron Young

This is a suit for freedom
declaration in the form
prescribed by Statute Trespass
& Damages $500 -

An order that made last
Term permitting said
Plff to sue as a poorperson
to Establish his freedom
&c.&c.. The Clerk will
please issue a summons
& copy of said order

G A BirdG A Bird Plffs
atty

Filed 5th July 1833

Archibald GambleArchibald Gamble Clerk

Order permitting plff to sue &c Book 6 page 446
Judgment by default Book 7 page 34
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Served this writ by reading at the defendants usual
place of residence in St. Louis County
a certified copy of the writ and declaration
with a free white member of his
family over the age of fifteen years to
whom I made known the contents
thereof on the 6th July 1833

Service $1.00

Jno. K. WalkerJohn K Walker shff
by Stone
Shff