The petition of
BrownBrown a man of color respectfully represents

That he is deserving of
instituting a suit against-one WilliamWilliam C AndersonAnderson
in order to establish the right of your petitioner to
freedom that his Claim that is founded upon the
following grounds to wit. ThatHenryHenry BrownBrown who had
formerly owned your petitioner for some six or eight years
prior to the first of May last & during the time he so
owned your petitioner hired out your petitioner to
work in the County of St. Claire StateIllinois of IllinoisIllinois that under virtue of such hiring petitioner petitioner
did work in said StSt Claire County. ClaireSt Claire County CountySt Claire County State ofIllinois IllinoisIllinois at
various times between the years 1839. & 1841. for several
months at a time: Your petitioner further represents
that somewhere about the first of May last, he
was purchased fromHenryHenry BrownBrown his siad former master by the said WilliamWilliam & that he
is now by the said held in slavery

Your petitioner therefore prays that
he may have leave to sue as a poor person in order
to establish his right to freedom.

p: SquireBrownBrown the above,
named being duly sworn deposes
says that the facts set forth in the above petition
are true to the knowledge of this

Be it remembered that the within
named SquireBrownBrown is hereby allowed
to sue as a poor person and JohnJohn Davis
DavisJohn Davis & Benjamin B Dayton Esqres are
assigned as his counsel and it is hereby
ordered that said BrownBrown have reasonable
liberty to attend his counsel
& the Court as occasion may require that he be not not removed out of the
Juisdiction of the court St. LouisCircuit Court
Circuit CourtCircuit Court, and that he be not
subjected to any severity on account of
his application for freedom. In
whereof witness my hand this 28 June 1841

SquireBrownBrown plaintiff in this
suit by his attorneys complains of WilliamWilliam Anderson AndersonWilliam Anderson
defendant of a plea of tresspass.

For that the said defendant heretofore to to wit on the
first-day of June on the year of our Lord one thousand eight hundred forty oneIn the City of St. LouisCity of St Louis
at said county with force and arms made an assault
on said plaintiff & then others beat
bruised and ill treated him then and there imprisoned
him kept him in prison without any reasonable or
probable cause whatever for a long space of time
to wit for the space of ten days then next following
contrary to the laws of the State of MissouriMissouri
against the will of the said plaintiff and other
to the said plaintiff then there did
against the peace of the State of MissouriMissourito
the damage of the said plaintiff of five hundred
dollars.

And the said plaintiff that
before at the time of the of the greivances aforesaid by the said defendant he the
said plaintiff was and still is a free person &
that the said defendant held and still holds him
in slavery. Therefore he

Narr in tresspass for false
imprisonment
Damages $ 500

We command you to summon WilliamWilliam C Andersen
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. LouisCity of St Louis, within and for the county of St. LouisSt Louis, on the third Monday of July, then and there to answer unto Squire
BrownBrown of a plea of trespass
to the damage of said plaintiff of five hundred
dollars: And have you then there this writ.

at ChambersChambers
Be it remembered that the
within named Squire BrownBrown is hereby allowed to sue as
a poor person, and John DavisJohn Davis & Benamin B Dayton are assigned as his Counsel, and it is hereby
ordered that said BrownBrown have reasonable liberty to attend

his counsel & the court as occasion may require: that he

be not removed out of the jurisdiction of the Court in the
St. Louis Circuit CourtCircuit Court, and that he be not
subjected to any severity on account of his application

for freedom. In testimony whereof witness my hand
this 28 June 1841.

contdBk 13 p 261 Dismissed (no body's costs) Bk 14 p 338. Squire says he
will pay the costs.

Suit for freedom
Damages : 500

Executed this writ in the county of St. LouisSt Louis on
the 3rd day of July 1841 by offering to read it and
the declaration toWilliamWilliam C AndersonAnderson the defendant
all of which he refused to hear

and the said defendant by
his attorney and signing
when says that he is not guilty of the said supposed greivances aforesaid to his charge, or any, or either
of them, or any part thereof, in manner form the
said plaintiff with alon thereof complained against
him. And of this the said defendant puts himself
upon the county

Plea not guilty

Filed July 20 1841

You are hereby commanded, that setting aside all manner of excuse and delay, you appear
before the Judge of our Circuit CourtCircuit Court , on the twenty first day of July instant
at the City of St. LouisCity of St Louis, then and there to
testify, and the truth to say in a certain matter of controversy now pending in our said Court,
wherein SquireBrownBrown is
plaintiff and WilliamWilliam C AndersonAnderson is
defendant on the part of the plaintiff
and herein you are in no wise to fail.

Sub for plff.

Executed

You are hereby commanded, that setting aside all of manner excuse and delay, you appear
before the Judge of our Circuit CourtCircuit Court , on the thirty first inst
at the City of St. LouisCity of St Louis, then and there to
testify, and the truth to say in a certain matter of controversy now pending in our said Court, wherein SquireBrownBrown is
plaintiff and Wm C AndersonAnderson is
defendant on the part of the defendant
and herein you are in no wise to fail.

Wit for Deft

for 31. Ist

You are hereby commanded, that setting aside all manner of excuse and delay, you appear
before the Judge of our Circuit CourtCircuit Court , on the Thirty day of November 1843 at the City of St. LouisCity of St Louis, then and there to
testify, and the truth to say in a certain matter of controversy now pending in our said Court,
wherein Squire BrownBrown
plaintiff and WilliamWilliam C. AndersonAnderson Sen is
defendant on the part of the Defendant
and herein you are in no wise to fail.

Subp
wit.

This writ not exec in
consequence of the adjournment
of Courts

You are hereby commanded, that setting aside all manner of excuse and delay you appear
before the Judge of our Circuit CourtCircuit Court , on the Eleventh day of Januaryinstant
at the City of St. LouisCity of St Louis, then and there to
testify, and the truth to say in a certain matter of controversy now pending in our said Court,
wherein Squire BrownBrown is
plaintiff and WilliamWilliam C. AndersonAnderson is
defendant on the part of the defendant
and herein you are in no wise to fail.

Executed the 11th January 1844.

Subpoena

You are hereby commanded, that setting aide all manner of excuse and delay, you appear
before the Judge of our Cicuit CourtCircut Court , on the eleventh day of Januaryinstant
at the City of St. LouisCity of St Louis, then and there to
testify, and the truth to say in a certain matter of controversy now pending in our said Court,
wherein Squire BrownBrown is
plaintiff and WilliamWilliam C AndersonAnderson is
defendant on the part of the plaintiff
and herein you are in no wise to fail.

JJ Wolfolk. ShawShaw
tobacconists

Executed the 11th January 1844JohnJohn Sternley SternleyJohn Sternley not found

You are hereby commanded, that setting aide all manner of excuse and delay, you appear
before the Judge of our Cicuit CourtCircut Court , on the Sixteenth day of January
at the City of St. LouisCity of St Louis, then and there to
testify, and the truth to say in a certain matter of controversy now pending in our said Court,
wherein Squire BrownBrown is
plaintiff and WilliamWilliam C AndersonAnderson is
defendant on the part of plaintiff
and herein you are in no wise to fail.

Executed the 11th January 1844John SternleyJohn Sternley PeterPeter Wirt
not found in my County

JJ Wolfock

You are hereby commanded, that setting aside all manner of excuse and delay, you appear
before the Judge of our Circuit CourtCircuit Court , on the sixteenth day of January
instant at the City of St. LouisCity of St Louis, then and there to
testtify, and the truth to say in a certain matter of controversy now pending in our said Court,
wherein Squire BrownBrown is
plaintiff and WilliamWilliam C AndersonAnderson is
defendant on the part of the plaintiff
and herein you are in no wise to fail.

Executed on J. H. Conn

Sub for deft
plff.

You are hereby commanded, that setting aside all manner of excuse and delay, you appear
before the Judge of our Circuit CourtCircuit Court , forthwith
at the City of St. LouisCity of St Louis, then and there to
testify, and the truth to say in a certain matter of controversy now pending in our said Court, wherein Squire BrownBrown is
plaintiff and Wm C AndersonAnderson is
defendant on the part of the
and herein you are in no wise to fail.

Exd the16th January 1841

spa