Mary Brown, by and through her next friend, Jenny Brown vs. William Head
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State ofMissouri MissouriMissouri
St Louis County

In the St LouisSt Louis Court
Nov Term 1844

MaryMary BrownBrown who sues by her next friend
JennyJenny Brown BrownJenny Brown complains of WilliamWilliam Head
of pleas of Trespass and False imprisonment
For that whereas the said defendant on the
day of September in the year Eighteen hundred and forty fourmade an assault upon the said plaintiff
and then and there imprisoned had bruised and ill
-treated the said Plantiff and kept and detained
in prison then and there without any reasonable
or probable cause whatever for a long span of
time for the span of Twelve hours then
next following contrary to the laws of the said
state and against the will of the said plaintiff

And the said plaintiff further
owns that the said plaintiff before and at the commit
-ting of the grievances was and still is free
person. And that the defendant then and there
hold and still holds the said plaintiff in slavery
And other wrongs that the said plaintiff
said defendant then and there did Contrary to
the laws and dignity of the said State And hath
damaged the said plaintiff of Five Hundred
dollars Therefore the said plaintiff sues

EliasElias B. SmithB Smith


p.q.
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State MissouriMissouri
St Louis County

To the Hon Judge of the Circuit CourtCircuit Court of
St Louis County

Your petition respectfully states to the said
your Honor Court,that the person mentioned in the Declaration above
is sold in slavery by WilliamWilliam Head in this county
said that she the said MaryMary BrownBrown is entitled to him freedom
in consequence of a certain proceeding had in
the State of VirginiaState of Virginia to wit JennyJenny Brown BrownJenny Brown the mother of said MaryMary was brought
into the said State of VirginiaState of Virginia By her then Master for the purpose of sale
Contrary to the laws of the state of VirginiaVirginia by reason of which she was then and is now a free person and was
afterwards brought to the State of MissouriMissouri and in
said State of MissouriMissouri has been kept in slavery against her will
for more than twenty years during which time the said MaryMary
was born and is now of the age of fifteen years.

Your petition prays
this court to permit and allow her to sue as a free person
to establish her right to freedom and as unduly found the
pray -
Sworn to and subscribed before on the 14th day of October 1844

JamesJames J JJames J Purely a Justice of the CountyCircuit Court
CourtCircuit Court & for St Louis County JennyJenny her

x

markBrownBrown
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In the St. LouisSt LouisCircut CourtCircuit Court Nov Term 1844

EliasElias B SmithB Smith p.q.

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State of MissouriMissouri
St Louis County

ss

On reading the above Petition,
It is ordered that the petitioner
MaryMary BrownBrown has to sue as poor person
and EliasElias B SmithB Smith says is hereby assigned as her counsel
and his further ordered that the said petitioner
have reasonable liberty of attending his counsel
and the court as occasion require and
that she be not removed from the jurisdiction
of this Court and that she be not subjected
to any severity as result of her application
in sue for her freedom

John M KrumJohn M Krum

Judge 8, Jud.Cir,us
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In the St LouisCircuit Court CircuitCircuit Court CourtCircuit Court
Nov Term 1844

MaryMary BrownBrown by her next
friend. vsTrespass to

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 summonWilliamWilliam Head 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 Mon-day of November next, then and there to answer unto [ Meary ] Brown who sues by next friend of a plea of
trespass and false imprisonmment
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 twenty fourth day of October 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 for the County ofCounty of St Louis St. LouisCounty of St Louis
On the 24th day of october 1844
by reading it and the declaration to WilliamWilliam
Head the [ deffindant ] and also by reading to the said
WilliamWilliam Head the orders of the Judge endorsed upon
this writ

Fee $1, 50

WilliamWilliam Milburn MilburnWilliam Milburn Sheriff


By

R Dowing Deputy

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No. 230

St LouisCircuit Court Circuit CourtCircuit Court November term 1844

MaryMary BrownBrown by next friend
James Brown
v summons
read & now

WilliamWilliam Head

Trespass & false imprisonment
Damages $500.
SmithSmith p.qOct 24th 1844

Filed Oct 24 1844
John RulandJohn Ruland Clerk

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This ordered that the petitioner has
reasonable liberty to sue as a poor person
and EliasElias BB Smith . SmithB Smith assigned her as counsel
It is further ordered that she have reas
-onable liberty to attend the Court and
her counsel as occasion may require
and that the she be not moved out of the
jurisdiction of this Court and that she be
not subjected to any severity on account
of her application for freedom.

Free â(188)

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plea filed15 p 290 Dismissed Feby V.1846 17p72

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MaryMary BrownBrown who who sues by
her next friend JennyJenny Brown BrownJenny Brown
v..
WilliamWilliam HEad

In the Saint LouisCircuit Court Circuit CourtCircuit Court
of Nov Leave 1844

And the said defendant WilliamWilliam Head
by LeslieLeslie Lord his attornie comes
and defends the force and
injury where he and says that
he is not guilty is the said supposed
trespass aforesaid to his charge on
any part thereof in manner and
form as the said plaintiff hath
above thereof complained against
him of this he puts himself upon
the country &c.

LeslieLeslie Lord
for Defn

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MaryMary BrownBrown
by her next friend
v.
WilliamWilliam Head

Plea
LeslieLeslie Lord
on Deft..

Filednov18th 1844

JohnJohn Ruland RulandJohn Ruland Clerk