MillyMilly, by her attorney, Jno. C. EdwardsEdwards, complains of Wiley WilliamsWiley Williams of a plea of trespass : For that the said Wiley WilliamsWiley Wiley WilliamsWilliams, on the 23rd. day of June, 1829, with force and arms, made an assault upon the said Miley , to wit, at the county of St LouisSt. Louis & MissouriState of Missouri, and then and there beat bruised, and iii treated her, the said MillyMilly, and kept and detained her in prison there, without any reasonable or probable cause, for a long time, to wit for the space of twelve hours then next following, & nevertheless the said MillyMilly overs that before and at the time of committing the grievance she was and still is a free person, and that the defendant held and detained her and still holds and detains her in slavery, countrary to the law of the land and against the will of the said MillyMilly. And other wrongs to the said MillyMilly then and there did to the great damage of the said MillyMilly; wherefore the said MillyMilly saith she is injured and hath sustained damages the amount of five hundred dollars; and therefore she brings her suit .

Declaration

We command you to summon Wiley WilliamsWiley Williams that he be and appear before the Judge of our Circuit CourtCircuit Court at the next term thereof to be held at the City of St LouisCity of St. Louis within and for the County of St LouisCounty of St.Louis on the fourth monday of July next then and there to answer unto MillyMilly of a plea of trespass to the damage wherefore the said MillyMilly saith she is injured and hath sustained damages_ the amount of five hundred dollars and have you then there this writ.

Your petitioner, MillyMilly, represents to your honour that she was born in the State of MarylandMaryland the property of one Lee; that she was sold to Moses Bigsby, and by him taken to the OhioState of OhioOhio about fifteen years ago: that she was by the said Moses Bigsby , detained in the OhioState of OhioOhio about fifteen months: that she is now hold in sloavery by Wi_ley WilliamsWilliams in the county of St LouisSt. Louis, and State of Mossouri, when she is advised and be_lieves she is entitled to her freedom. Therefore your petitioner prays that she may be permitted to sue as a poor person to establish her right thereto, and that such other and further orders may be made in the premises as the law di_rects and as may seem meet and proper to your honour.

County of St LouisCounty of St.Louis, MissouriState of Missouri, Sct. This day personally appeared before me a Justice of the Peace for the County and State aforesaid, MillyMilly, the above petitioner, who, being duly sworn, says that the fact set out in the fore_giving petion are true to the best of her knowledge .

Sworn to and subscribed this 23rd June, in the year of our Lord one thousand eight hundred and twenty nine.

The within named MillyMilly is permitted to sue as poor person on the within petition to establish her freedom & the clerk of the Circuit CourtCircuit Court of St. Louis County is hereby directed to hear the trespass herein for that pur -pose -and John C.EdwardsEdwards Esquire is hereby asigned as her counsel . It is moreover ordered that the petitionee have reasonable to allow her counsel and the court when occures may require and that the petitioner shall not be taken or removed out of the jurisdiction of the court nor be subject to any severity because of her application for freedom.

Petition to sue in forma pauperis

Wiley WilliamsWiley Williams not found in my county

We command you to summon Wiley WilliamsWiley Williams that he be and appear before the Judge of our Circuit CourtCircuit Court at the next term thereof to be held at the city of St LouisSt. Louis within and for the County of St LouisCounty of St. Louis on the fourth Monday of November next then and there to answer unto MillyMilly of a plea of trepass whereafore the said MillyMilly saith she is injured and hath sustained damages to the amount of Five Hundred Dollars and have you then there this writ.

We Command you as we have often heretofore commanded you to summon Wiley WilliamsWiley Williams that he be and appear befor the Judge of our Circuit CourtCircuit Court at the next term thereof to be held at the City of St LouisCity of St. Louis within and for the County of St LouisCounty of St.Louis on the fourth Monday of March next then and there to answer unto MillyMilly of a plea of trespass wherefore the said MillyMilly saith she is injured and hath sustained damages to the amount of Five Hundred dollars and have you then there this writ.

Willy Williams not found in my County and not rumor within the town 50

alias summons summoned February 20th 1830 Returnable to month Term

Wiley WilliamsWiley Williams not found in my county Nov 7. 1829