Squire Brown, a man of color v. Charles Anderson
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To the Honorable BryanBryan Mullanphy MullanphyBryan Mullanphy Judge
of the Circuit CourtCircuit Court of St Louis County

The petition of Squire
BrownBrown a man of color respectfully
. That at the July Term of the
St LouisSt Louis Cricut Court for the year eighteen hundred forty one. Your petitioner
institutes a suit for freedom in order
to establish his right to freedomand
one WilliamWilliam who then claimed
to be owner of your petitioner, that previous
to the instituion of said your had
made an order grantingleave to your
petitioner to sue as a poor person for an
above purpose. also an order that your
petitioner have reasonable
liberty to leture his Counsel & the Court as
occassion might require that he be
notremoved out of the jurisdiction
of said Court- & be not subject to any
severity on account of his application for
freedom. That the same term your
assigned Davis Dayton
as counsel for your petitioner in the above

Your petitioner final his repre
sents that. the institution of said
suit the said WilliamWilliam anderson has
as your petitioner his been informed &
believessold your petitioner to one CharlesCharles
anderson who now claims to be the owner
of or is exercising acts of ownershipover your
petitioner. That the said CharlesCharles anderson
has threatened to sell your petitioner & have
himremovedfrom the Statebeyond the

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jurisdiction of said Court & your petitioner
verilybelieves that prevented by
the interference of your the said
AndersonAnderson will of your petitioner
& have him removedbeyond the juris
diction of this Court. Your petitioner
further represents that said AndersonAnderson
has for some time past up to the
thirty-first day of July instant hired out
your petitioner & received the whole of his
wages. refused to furnish your petition
er with a singlearticle of clothing al
though your petitioner has frequently re
quested& stands in great needclothing
& the said AndersonAnderson has repeatedlytold
your petitiioner that he would not
furnish him with any clothing un
less. Your petitioner would con
sent to a dismissalof said suit.
and your petitioner represents
that the said AndersonAnderson he is now
confined in the jail of St Louis County
by the said AndersonAnderson without any
good cause whatever that your petitioner
is aware of, but your petitioner believes
that he is thus confined for the purpose
of being to dismiss the said suit
your petitioner therefore prays that your
Honor will grant such relief as the
motion of the Courtrequires.

Squire his BrownBrown

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State of MissouriMissouri
County of St LouisCounty of St Louis

SquireBrownBrown this day
sworn deposes
that the facts set forth

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in the petition an as
he verilybelieves

Subscribed & sworn to this
31st day of July 1843

Squire his mark BrownBrown

Jn RulandJohn Ruland Clerk

By Milbourne Depty.

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In the matter

Charles AndersonCharles Anderson
present- Wm Anderson

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State of MissouriMissouri
County of St LouisCounty of St Louis

The State of MissouriMissouri

To the Sheriff of St Louis
County Greeting

It having been alleged to our
Circuit Judge of the Eighth
Jud. Cir.. (in the annexed aff
davit that one Squire BrownBrown
(a man of color to whom hereto-
fore leave hath been granted
to sue for his freedom in the
St Louis County Circuit CourtCircuit Court ),
is about to be removed out
of the jurisdiction of said
Court and is harshly treated
with undue severity on account
of his application for freedom,
therefore you will take the
said BrownBrown & have, his body he-
fore me at the the Sheriff office in the city of
St LouisSt Louis at 3'o clock P. M. this
day and summon CharlesCharles Anderson Anderson
& William AndersonCharles Anderson and any
person in whose possession said
BrownBrown may be forced to appear be-
fore me at the same time & place I have then there this writ
As witness the hand of our said, Judge this 3d Aug 1843

BryanBryan Mccleanffs

Judge 8th JudCir.

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no. 232

St. Louis Circuit CourtCircuit CourtAugust Term 1843


Brand Le

Filed August 3. 1843

J.Ruland Clk

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Executed the within order in the
County of St. LouisCounty of St Louis as the 3d Augt 1843
by Summoning Charles AndersonCharles Anderson &
the jailor of St. LouisSt Louis the County Benjamin to appear at Sheriffs office at 3
O' Clock P. M. this day before the Judge of the
Circuit CourtCircuit Court . William AndersonWilliam Anderson said
and by having the body of the negroe before the judgeasdirected

Service $ 3.00 Mon est ''.13 $ 3.13

William MilburnWilliam Milburn Shff.

By Danl. Murphy Depty.

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The Sheriff is directed to there
papers & annexed receiving and to the
Clerk of the Circuit Count and surrender
negroe to Charles R AndersonCharles R Anderson 3 Aug 1843

Bryan Murphy

Judge 8th Jud. Cir.
of Mo.

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Papers & the annexed recognisazion on -
them to the clerk of the Circuit Count as directed above
this 3 of day august â 1843

William MilburnWilliam Milburn

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State of MissouriMissouri
County of St LouisCounty of St Louis

The writ having been returned as witness
the return here to annexed, & the time limited
having expired & CharlesCharles Anderson AndersonCharles Anderson having
been duly called at the door of the Sheriffs office
appeared and offered to
enter into the recognizance as required by 7th.
Dec. of an act to enable persons held in Slavery to
sue for their freedom approved Jan 27 - 1835.

We the undersigned do in presence of &
before in MullanphyMullanphy Judge of the Eighth
Judicial Circuit of the State of MissouriMissouri
acknowledge ourselves held & firmly bound & in
debted to the State of MissouriMissouri in the sum
of six hundred dollars to be levied of our res-
pective land; & tenements goods & , never-
theless upon the following condition that whereas
Squire BrownBrown hath sued WilliamWilliam C. AndersonAnderson
in the the Circuit Court of aforesaid Circuit for
the County of St LouisCounty of St Louis, for his said BrownBrown , freedom,
and hath been hold to Charles K. Anderson,
now if said BrownBrown shall during the pendency of
said suit have reasonable liberty of attending his counsel
& the Court & shall not be removed out of the
Jurisdiction of Said Court or anyanyother
Court to said suit may be removed
or in which it may be pending & shall not be subjected to
any severity on account of his application
for freedom then this recognizance shall
be void, otherwise the same shall be and
remain in full force as witness our hands this
third August A.D. one thousand Eigh hundred & forty three.

Certified this day & year aforesaid
MullanphyMullanphy Judge 8th Jud.
Cir.of Mo.

Chas. R Anderson
Ely. Anderson

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