Petition of PeterPeter to
as poor man
It is reduced by the Court that said PeterPeter be allowed
to sue as a poor person to establish his
right to freedom: and JohnJohn Davis DavisJohn Davis require
is assigned him as counsel and it is further
ordered that the said petitioner have reasonable
liberty to attend his counsel, and
the court as occasion may require: that he
be not removed out of the jurisdiction of the court and that he be not subject to
any any severity on account of his application
for freedom

Respectfully presents and complains your
petitioner, PeterPeter , a colored man, that he is held in
slavery unlawfully and against right as he believes, by
John RichardsonJohn Richardson of the County of St. LouisCounty of St Louis under
the following circumstances.

In the spring of the year 1833, he was the lawful slave of said RichardsonRichardson , and was by him
taken to DubuqueDubuque in the Territory of IowaIowa and there
worked for his master in the business of mining at or
about said period. That he has remained in said place
for a space of about eight years, by and with the
consent and direction of the said RichardsonRichardson .
That said Territory is a portion of the United StatesUnited States
in which slavery is not allowed by the laws of the
United StatesUnited States, and therefore your petitioner belives he is
fully entitled to his freedom.

Wherefore he prays the Honorable Court, that
an order may be granted, allowing the petitioner to sue in
the Circuit CourtCircuit Court of St. Louis County, as a poor person, to
establish his right to freedom; that counsel may be assigned
him; that he have reasonable liberty to attend his counsel
and the court, as occassion may require; that he be not removed
out of the jurisdiction of the Court; and that he be not
subjected to any security on account of his application
for freedom.

This day personally appeared before
me Philip.S. Dave Clerk of the District CourtCircuit Court for the said
County of DubuqueDubuque PeterPeter a colored man the petitioner
within named and made oath that the facts set forth
in the within petition are true

trespass for false
imprisonment

PeterPeter , a colored man, plaintiff in this
suit, by his Attorneys, complains of John RichardsonJohn Richardson
defendant of a plea of trespass

For that the defendant heretofore, to wit, on the
first day of June in the year of our Lord one thousand eight hundred and thirty three, in DubuqueDubuque in the
Territory of IowaIowa to wit in the County of St. LouisCounty of St Louis
and State of MissouriMissouri, with face and arms made an
assault on said plaintiff and then and there beat,
bruised and ill treated him, and then and there imprisoned
him and kept him in prison without any reasonable
or probable cause whatever for a long space of time, to
wit for the space of one year these next following, countrary
to the laws of the State of MissouriMissouri and against the
will of the plaintiff, and other wrongs to the said
plaintiff then and there did against the peace
of the State of MissouriMissouri to the damage of the said
plaintiff in the sum of One Thousand Dollars.

And the said plaintiff covers that before
and at the time of the committing of the greivances
aforesaid by the said defendant, the said plaintiff
was and still is a free person, and that the defendant
held and still holds him in slavery

Suit for freedom

We command you to summon JohnJohn Richardson RichardsonJohn Richardson if he be
found in your County, that he be and appear
before the judge of our Circuit CourtCircuit Court , on the first day of the next term thereof, to be
held at the city of St. LouisSt Louis, within and for the county of St. LouisSt Louis on the third Monday
of november next, then and there to answer unto PeterPeter , a
colord man, of a plea of trespass of to the damage of said, plaintiff of one thousand
dollars: And have you then there this writ.

I acknowledge myself bound for all costs that may accure in the above cause.
Witness my hand and seal, at St. LouisSt Louis, this day of
It is ordered by the Court that said person be allowed to
sue as a poor person to establish his right to freedom;
and JohnJohn Davis DavisJohn Davis Esquire is assigned him as counsel
and it is further ordered that the said petition have
resonable liberty to attend his counsel and the

the dependent not formed in my county for freedom

JohnJohn Richardson RichardsonJohn Richardson the defendant
not found in my CountyCircuit Court

CourtCircuit Court on occasion may require ; that he be not removed out of the jurisdiction
of the court and that he be not subject to any severity on account of
his application for freedom.

BK 13 p 370