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St.LouisSt LouisJuly the 10th 1835

To the honorable Luke Lawless one of the Judges of
the Circuit Court of the State of MissouriMissouri- the petition
of Michael Edward, colored sheweth; that he
the said EdwardsEdwards is a free person that he was born in the
State of IllinoisIllinois in the Town of KaskaskiaKaskaskia about eighteen
years ago and since the ordinance of seventeen hundred
and eighty seven, and that he has never done any thing
where by he had forfeited his freedom- And that a certain
J J Birdsong although he is aware of the premises and well knows
that he the said Michael EdwardsMichael Edwards is a free person and has always
been a free person and has never done anything to
forfeit his freedom yet be the said J. J. Birdsong has and
does still actair him the said EdwardsEdwards in custody against
Law â right and against his will in the Common Jail of
the county of St LouisSt Louis and with the interest and purpose
as he the said EdwardsEdwards verily believes of carrying him out
of this State, in order that he may sell him as a slave in
four one of the near Southern States. wherefore your
petitioner humbly prays your honour that an order be
made, that your petitioner be allowed to sue as a poor per-
son, for the purpose of establishing his freedom, and that your
Honour assign the said petitioner counsel and that your
Honour with also order, that the petitioner have reasonable
liberty to attend his counsel and the court, when occasion
may require; and that the petitioner be not taken or re
moved out of the jurisdiction of the Court, nor be subject
to any severity because of his application for freedom.
and your petitioner as in duty found will ever pray &c

EdwardsEdwards his mark

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County of St LouisCounty of St Louis ss

Michael EdwardsMichael Edwards being
duly sworn according to law deposeth â saith that the facts
contained in the within petition are true to the best of his
knowledge & belief

Sworn to and signed before me at St LouisSt Louis this Tenth day of July Eighteen hundred and thirty five

PeterPeter FergusonFerguson justice of the peace County St LouisCounty St Louis

Michael EdwardsMichael Edwards his mark

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County of St LouisCounty of St Louis ss

Daniel BusbyDaniel Busby being duly sworn according to law deposeth and saith that from the
best information which he had gathered he verilybelieves
that it is the pupose and intention of the within named
J. J. Birdsong to carry the within named coloured ladMichaelMichael Edwards
EdwardsMichael Edwards out of the jurisdiction of this court - that is to say to
carry him to one of the Southern States in order to sell him as
a slave - that the said Birdsong is what is commonly called a
negro trader and is in the habit of buying negro for the
purpose of taking them to the south and furthermore that he
is now engaged in making purchases of the kind with this aim
and for this end

Sworm to â signed before me at St LouisSt Louis this Eleventh day of July eighteen hundred thirty five

D. Hough J. P.

D Busby

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In the Circuit CourtCircuit Court November Term
State of MissouriMissouri
County of St. LouisCounty of St Louis
ss

J J. Birdsong the defendant
in this suit was summoned to answer. Michael EdwardsMichael Edwards
the plaintiff in this suit in a plea of trespassassault
battery and false imprisonment, and therefore the said
Michacl EdwardsEdwards , the plaintiff, by JustenPark his
attorney, complained against the said G. G. Birdsong
for that the said defendant on the twentiethday day of June A.D. 1835 with force and arm assaulted the said plaintiff
to wit at St. LouisSt Louis in the County aforesaid and then â
there beat bruised and ill-treated him, and then â there
imprisoned and kept â detained him in prison there without
any reasonable or probable cause whatsoever, for a long
time to wit, for the space of twenty days then next following
contrary to the laws and customs of this State and against
the will of the said plaintiff and the plaintiff avers
that before and at the time of committing the aforesaid
grievances he was and still is a free person and that the
defendant held and detained and still holds and detains
him in slavery against law and right â against the will of
the plaintiff and other wrongs to the said plaintiff then
and there did to the great damage of the said plaintiff
and against the peace and dignity of the State -
Wherefore the said plaintiff saith that he is injured and
hath sustained damage to the amount of five hundred
dollars and therefore he brings this suit.

TrustenPolk

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(copy of the judges order) It is hereby ordered as prayed in said petition according to the act in such case made and provided
11th July 1835LL E Lawless EL E Lawless LawlessL E Lawless judge 3dJud Circuit (as true copy of the order of the judge)

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 J. J. Birdsong that he be and appear before the Judge
of our Circuit CourtCircuit Court at the next November Term thereof it be held at the City of StCity of St Louis.
LouisCity of St Louis within and for the county of Saint Loui on the second monday of November next
then and there to answer unto MichaelMichael Edwads in a plea of Trespass Assault â Battery
and false imprisonment wherefore the said plaintiff saith he is injured and hath sustained
damage to the amount of five Hundred dollars and have you then there this writ.

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Witness Archibald GambleArchibald Gamble Clerk of our said CircuitCircuit Court
CourtCircuit Court at office this Eleventh day of July one thousand eight hundred and thirty five

Archibald GambleArchibald Gamble Clerk

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Executed this writ by reading it and the petition
affidavit and order of the honourable judge to J. J.
Birdsong on the 11th day of July 1835 in the county
of St. LouisSt Louis

J. BrothertonJames Brotherton Shff
by G. Hammond Dept

Service 1.00
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No 11
Saint Louis Circuit CourtCircuit Court
November Term 1835
Saint Louis Circuit CourtCircuit Court
July Term

Michael EdwardsMichael Edwards
vs
J J Birdsong

suit for freedom
action

trespass Assault â Battery â false Imprisonment

filed 11th July 1835

Archibald GambleArchibald Gamble Clerk

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It is herebyordered as prayed in said
petition to the act in such
casemade & privided
L E LawlessL E Lawless

11th July 1835

Judge3 JudCircuit

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The petition of
Michael EdwardsMichael Edwards
a coloured lad