Jim Brown, by and through his next friend, Jenny Brown vs. William Head
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State of MissouriMissourias

St. Louis County
In the St. LouisSt Louis Circuit Cort Nov Term 1844


Jim BrownJim Brown who sues by his next friend
Jenny BrownJenny Brown complains of WilliamWilliam Head
of plea of trespass and false imprisonment
for that whereas the said defendant on the day
of september in the year Eighteen hundred and forty
four made an assault upon the said plantiff
at the county and state aforesaid and then and there
imprisoned and attracted the said
kept and detained him in prison
then and there without any reasonable probable cause whatsoever
for a long span of time to wit for the space of
twelve hours then next following country to the
laws of the said state and against the will of the said
plantiff And the said plantiff further
of the committing of the said grievances was still is
a free person And Father that the said defendant
then and there held and still holds the said plantiff
in slavery and then wrongs to the said plantiff
the said defendant then and there did Countrary to
the pleas and dignity of the said state And to the
damage of the said plaintiff of Five Hundred
dollars and Therefore the said plaintiff brings
suit &c

EliasElias B SmithB Smith p.q..

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State of MissouriMissouri
as
St. Louis County
To the Hon. Judge of the Circut CourtCircuit Court of St. Louis County

ss

Your petitioner respectfully states to the
Court Your Honor that the honor mentioned in the Declaration above is
held in slavery by WilliamWilliam Read in this County and that
he the said Louis is entitled to his freedom. In Consequence of a action proceeding him in the state of Wrynim County to the laws of the
state of VirginiaVirginia to wit Jenny BrownJenny Brown the mother of said Jim
was brought into the state of VirginiaVirginia for the purpose of sale
by him the MartinMartin of which slaves then and is now a free person and was afterwards brought to
the state of MissouriMissouri and in said state of MissiouriMissouri she has
been held in slavery for more than twenty years against
her will during which time the said Lein was born
and now of the age of. fourteen years (14 years)

Your petitioner therefore prays your
Honor to allow him to sue as a free person
to establish his right to freedom and duly

Sworn to and submitted before me the 14th day Oct.1844
James JJames J Purely a Justice of the CountyCircuit Court
CourtCircuit Court and for St. Louis County JennyJenny her

X

markBrownBrown
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In the St. Louis Circuit CourtCircuit Court
Nov Term 1844

EliasElias B SmithB Smith p.q..

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State of Missiouri
CountyCounty of St Louis ofCounty of St Louis St. LouisCounty of St Louis

In the St. Louis Circuit CourtCircuit Court. - On reading the for giving petition

It is ordered that the petitionerâJimJim Brown BrownJim Brown " has
leave to sue as a poor person, and thatEliasElias B. SmithB Smith Esq.,
is hereby assigned as his counsel: and it is further ordered that
said Petitioner have reasonable liberty of attending his counsel and
the Court, as occasion may require, that he be not removed without
the jurisdiction of this Court, and that he be not subjected to any
severity on account of his application for freedom.

JohnJohn M MJohn M K.

Judge ,

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In the St. Louis County Court
Nov Term 1844

Jim BrownJim Brown by his next friend
vs Trespass
Wm Head

EliasElias B. SmithB Smith .
p.q..

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County of St. LouisCounty of St Louis,

ss.

The State Of MissouriMissouri,

To the Sheriff of St. Louis CountyâGreeting:

We command you to Summon WilliamWilliam Head
if he be found in your County that he be and appear before 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 Mon-
day of November next, then and there to answer unto
JimJim Brown BrownJim Brown who sues by his next friend
Jenny BrownJenny Brown of a plea of trespass
and false imprisonment
to the damage of said plaintiff Five hundred
dollars: And have you then there this writ.

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Witness, John RulandJohn Ruland , Clerk of our said Court,
with the seal thereof hereto affixed, at office, in the
city of St. LouisSt Louis, this 24th day ofOctober in the year of our Lord eighteen hundred and forty four

John RulandJohn Ruland

Clerk.
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I acknowledge myself bound for all costs that may accrue in the above cause. Witness my hand and seal, at St. LouisSt Louis, this day of 184

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Executed this writ in the County of St. LouisCounty of St Louis
on the 2nd day of October 1844 by reaching it and the
declarition to WilliamWilliam Head the [ deffendant ] and
also by reading to Said WilliamWilliam Head the orders
of the Judge endorsed upon this writ

Fee $1.50

WilliamWilliam Milburn MilburnWilliam Milburn

Sheriff

By

R DowlingR Dowling Deputy

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No 229

St. Louis Circuit CourtCircuit Court
November Term 1844

JimJim Brown BrownJim Brown by his next
friend JennyJenny Brown BrownJenny Brown
vssummonsWilliamWilliam Head

Trespass & false imprison=
=ment

Damages $ 500
E B SmithB Smith p.q.
Filed Oct 24th 1844

John RulandJohn Ruland Clerk

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It is ordered that the petitioner have
reasonable liberty, to sue as a poor
person and EliasElias B SmithB Smith assigned
her as counsel. It is further ordered
that she have reasonable liberty to
attend the Court and her counsel as
occasion may require and that she
be not removed out of the jurisdiction
of this court & that she be not
subjected to any severity on account
of her application for freedom

Free â (138)
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plea filed 15p 290trespass feby 2 184617 p 72

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JimJim Brown BrownJim Brown who sues by his
next friend Jenny BrownJenny Brown
vs
WilliamWilliam Head

In St. Louis Circuit CourtCircuit Court
by Nov. term 1844.

And the said defendant WilliamWilliam Head
by his attornies, comes and
defends the force and injure when
and say, that he is not guilty of the
said suppored trespass above said what
charge in any part thereof in manner
and form, as the said plaintiff hath
above thereof complained against here
for this he puts himself upon the
country

LeslieLeslie Lord

forDeft.
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Jim BrownJim Brown
by hsi next friend
v
WilliamWilliam Head

Plea

LeslieLeslie Lord

forDeft. Filed Nov 18th 1844

John RulandJohn Ruland Clerk