Stephen Brown, by and through his next friend, Jenny Brown vs. William Head
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State of MissouriMissouri

St. Louis County ss

In the St. Louis Circuit CourtCircuit Court
November Term 1844

Stephen BrownStephen Brown who sues by his next friend
Jenny BrownJenny Brown complains of WilliamWilliam Head
of a plea of trespass and false imprisonment
for that whom the said defendante and the tenth day of September
in year eighteen hundre and fifty four made on assault upon the said plaintiff county aforesaid
and then and there imprisoned beat Bruised and
illtreated him the said aforesaid plantiff and kept and
detained her in prison that and then without any
reasonable or probable cause whatever for a a long
span of time towit for the span of tweleve hours
then and following contrary to the law of the
state and against the will of the said plaintiff
and the said plaintiff further owns that she the
said plantiff before and at the time of the committing
of the said grievance was and still is a free
person and that the said defendant then
and there held and still holds the said plaintiff
in slavery and wrongs to the said
plaintiff the said defendant then and
there did Contrary to the peace and dignity
of the said state and to the damages
of the said plaintiff of Five Hundred dollars
therefore the said plaintiff brings suit.

EliasElias B. SmithB Smith .
p.q.

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State of MissouriMissouri
St. Louis County

SS

The Circuit CourtCircuit Court of St. Louis County

Your petitioner purposefully states to St. LouisSt Louis
Court your Honor that the person mentioned in the declaration above held
in slavery by by WilliamWilliam Head in the County and that the now
Stephen BrownStephen Brown is entitled to his freedom in Consequence
of a certain grounding had in the the state of VirginiaVirginia to wit
Jenny BrownJenny Brown the Master of said StephenStephen was brought by her
then North into the state of VirginiaVirginia Contrary to the laws of the
said 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 kept in slavery against him with for more than
twenty years during which time the said StephenStephen was
born and is now at the age of Seventeen years

Your petitioner prays this court
a permit and allow him the said StephenStephen to sue as a free
person to establish his right to freedom and as in duty

Sworn to and subscribed before the 14th day of oct 1844

James JJames J Purely A Justice of the

County CourtCircuit Court for St. Louis County

X

Jenny BrownJenny Brown her mark
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In the St. LouisSt LouisCir. CourtCircut Court
November Term 1844

SmithSmith p.q.

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State of MissouriMissouri
St. Louis County

On reading the above
afore going petition

This ordered that the petitioner
Stephen BrownStephen Brown have him and
hereby an his counsel and
ordered that said petitioner have reasonable liberty
of attorny his counsel and that court as occurence
may require and that he be no removed
from the jurisdiction of this court and that
he not subjected to any severity on account of
his application to sue for his freedom

John M KrumJohn M Krum
Judge 8

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In

the St. Louis Circuit CourtCircuit Court
Nov Term 1844

Stephen BrownStephen Brown
his next friend
vs Trespass to
Wm Head

Elias R. 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 summonStephenStephen BrWilliamWilliam 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 StephenStephen Brown
BrownStephen Brown by his next friend Jenny BrownJenny Brown of a
plea of trespass & 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 twenty fourth 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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plea filed15 p 290. Dismissed feby v.184617 p 72

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No231
St. Louis Circuit CourtCircuit Court
November term 1844.
Stephen BrownStephen Brown who sues
by his next friend JennyJenny Brown
BrownJenny Brown
v summons

WilliamWilliam Head

Trespass & false imprisonment

[ Damt ]. $ 500.

SmithSmith p. q.

FiledOctober 24th 1844

John RulandJohn Ruland Clerk

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This ordered that the petitioner have a
reasonable liberty to sue as a poor person
and EliasElias B. SmithB Smith assigned her as counsel
it is further ordered that he have reasonable
liberty to attend the Court and her counsel as ses=
-sion may require, and that she be not removed
out of the jurisdiction of this court and that
she be not subject to any severity on account
of her application for freedom.

Free â(138)

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Executed this writ in the CountyCounty of St Louis
ofCounty of St Louis St. LouisCounty of St Louis on the 2nd day of November 1844
by reading it, and the declaration to WilliamWilliam
Head the defendant, and also by reading to
the said WilliamWilliam Head the orders of the
Judge endorsed upon this writ

Fee $2.00

WilliamWilliam Milburn MilburnWilliam Milburn Shff

By

R. Dowling Deputy

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StephenStephen Brown BrownStephen Brown who sues by his
next friend Jenny BrownJenny Brown
v.
WilliamWilliam Head

In the St. LouisCircuit Court CircuitCircuit Court CourtCircuit CourtNov. Term 1844

And the said defendant by LeslieLeslie Lord
his attorney, cause and defends the force
and injury when Lc. & says that he is
not guilty of the said supposed Trespass
above laid to his charge in any part thereof.
in manner and force as the said plaintiff
hath above thereof complained against
him for this he puts himself upon
the country Lc..

Leslie & Lord
for Deft..

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Stephen BrownStephen Brown
by his next friend
v.
WilliamWilliam Head

Plea Seu. Issue

LeslieLeslie & Lord

for Deft.. FiledNov 18th 1844John RulandJohn Ruland Clerk