To the Honourable William C Carr Judge of the Circuit Court
for the 3rd - Judicial Circuit in the State of Missouri now sitting
for the County of St. Louis , your petitioner Dolly a colored woman
about 40 year of age resident of St. Louis Humbly to yourHonour
that the is now held in slavery by a certain John Young &
your petitioner humbly conceiving that she is entitled to her
right to freedom prays that she may be permitted to
institute a suit (as a poor person / for purpose of obtaining the same and that
counsel may be assigned her, your petitioner states, that
the ground upon which she claims her freedom is that
the said John Young conveyed her to the Fever River
mines in the north western Territory, & / kept and detained
her there six months contrary tothe, usages & customs
of that County and your petitioner as is duty bound
will pray &c

Dolly by
Strother & Evans her
Attys

State of Missouri
County of St. Louis In the St. Louis Circuit Court - Wednesday 26th March 1828

George F Strother and James Evans present the petition of Dolly a woman of
Color praying that she may be permitted to institute suit againt John Young to
Establish her right to freedom and that she may be permitted to sue as a poor person
therefore the Court permits the said Dolly to sue as aforesaid and direct that an action
of assault and battery and false imprisonment be commenced against the said John
Young in the name of the said Dolly and assign James Evans and George F Strother
Esquires as her Counel and it is ordered by the Court that the said defendant permit
the said Dolly to have a reasonable liberty of attending her counsel and the Court
when the occasion may require it and that the said Dolly the plaintiff shall
not be taken or removed out of the juridiction of this court and that she shall
not be subject to any severity of treatment on account of her said application
for freedom -

A true copy of the order A. Gamble Clerk

Dolly
vs
Jn. Young
petition filedmarch 26th 1828

A Gamble clk

State of Missouri
County of S Louis Circuit Court 3rd Judicial
Circuit July Term 1828

Dolly a coloured woman by her attorneys
complain of John young of a plea of Trespass
assault Battery & False imprisonment. For that
the said John Young on the day of in
the year A.D 1827, with force & arms & made an
assault upon the said Dolly , towit, at the County of
St . Louis aforesaid & there & there seized & laid hold
of the said Dolly & with great force & violence took
& conveyed the said Dolly to Fever river in the North
Western Territory & then & there imprisoned the said
Dolly & kept & detained her in prison without
justifiablecausewhatsoever for a long space
of time, towit for the space of sixmonths then
next following contrary to the laws of the
said North Western Territory and the said Dolly
aver, that before and at the time of the committing
of the grievances she was & still is a free person
& that the Deft held & detained her still holds &
detainsherinslavery against the will of the said
Dolly , whereby she the said Dolly was then & there
greatly exposed injured & restrained of her liberty
towit at the County aforesaid & other wrong to
the said Dolly there & there did against the peace
& diginity of the state aforesaid & other damages of the
said Dolly five hundred dollers therefore

Executed this writ on John young April 12th 1828 in the
City of S Louis by reading the same to him

R Simpson Sheriff
By L P Timonds Dp Sheriff Service $ 1.00

No 7 July Term 1828
St Louis Circuit Court

Dolly
vs
John Young

This is an action of Trespass
assault & Battery & False imprisonment

Strother & Evans PQ

filed April 1st 1828 A Gamble clerk

The State of Missouri
County of St Louis To the Sheriff of S Louis County
greeting

We command you to summon John Young
that he be and appear before the Judge of our Circuit
Court at the next term thereof to be held at the
city of S Louis within and for the County of S Louis
on the fourth monday of July next then and there
to answer unto Dolly a woman of color of a plea
of Trespassassault&Battery & false imprisonment
to the damage of said plaintiff of five hundred
dollars and how you then there this writ

Witness Archibald Gamble clerk of
our said Court at office this
first day of April 1828 Archibald Gamble clerk Strother & Evans
for Pltff

To the Honorable William C. Carr judge of
the 3rd Judicial Circuit in the state of missouri & for the
County of St Louis .

Your petitioner Dolly a free woman
of color, now held in slavery by John Young represents
to your Honor, that by an order of the Circuit
Court of the said County of St Louis made at the
last March Term of said Court, obtained an order
permitting of the said Dolly to institute suit against
the said John Young to establish her right to freedom
that to declaration of this petitioner was
filed against the said John Young for the threats and
declaration of the said John Young your petitioner
has reason to believe and does beleive, that because
of her application for freedom, the said John Young
will treat her with great severity and that he will remove
her out of the jurisdiction of this court before
the trial of the said cause instituted to establish her
right to freedom your petitioner therefore prays
that your Honor may issue a writ of HabeasCorpus
and have your petitioner brought before you and
cause the said John young to enter into a recognizance
with security agreeable to Carr & your petitioner

her Dolly markSworn to this
10th day of May 1828

State of missouri
3 Judicial Circuit

Be it remembered that on
this 12th day of May 1828. personally appeared before me
the subscribed judge of the Circuit aforesaid
John Young and DougalOFerguston Jr.
of the county of St Louis and acknowledge them
to owe to the state of missouri the sum of
four hundred dollars each, to be levied of their
respective goods & chattles lands & tenaments
on condition following whereas one Dolly
a coloured woman has instituted suit
against said John Young to by her right
to freedom agreeably to the statute in such
cases made & provided & has petitioned
the undersigned to cause the said John
Young to enter into recognizance eith securety
that she the said Dolly shall not be removed
out of the jurisdiction of the Circuit Court
for the County of St Louis now therefore if the
petitioner Dolly shall at all times during the
pendency of the suit aforesaid have reasonable
liberty of attending her counsel and shall not
be removed out of the jurisdiction of the court
aforesaid & that she shall not be subjected to
any severity because of her application for
freedom, then this recognizance to be void
otherwise to be in full force & effect

Taken & certified before me the day
& year aforesaid at my chambers
in the County of St Louis given under my
law & seal Will . C. Carr

State of Missouri
Third judicial CircuitThe state of Missouri to John young of
the county of St Louis in the circuit aforesaid
Greeting

You are hereby commanded that the
body of a certain woman of colour named Dolly in your
custodypossession or power (who has been permitted
to institute suit against you to establish her right
to freedom and who has petitioned me to issue a
writ of habeas corpus to cause you to give security
that you will not remove her the said
Dolly out of the jurisdiction of the court agreeably to
the provisions of the statute in such cases made
& provided) you have before me at my house
at the hour of twoO Clock to day then & there to
do subject to & receive what of right ought
to be done in the premises

given under my hand & seal at
chambers this 12th day of may 1828 Will . C. Carr
judge 3 circuit

"By the HabeasCorpus
Act."

State missouri
vs
John Young

Filed 13th may 1828 Archibald Gamble clerk

The within named John appeared before
me aspursuant of the within writ
& having entered into recognizance
agreeably to the statute in such cases
made & provided with
Ferguson as security the said Dolly
is remanded into his possession.

In the St louis Circuit court Nov Term 1828

and the said John Young by his attorney, comes and defends the force and
injury when & and says that he is not guilty of the said supposed trespass above
laid to his charge, or any part thereof, in manner and form as the said Dolly hath
above thereof complained against him. And of this he the said John Young puts himself
upon the county

McGirk for deft.

John Young
ats
Dolly

pleas
issue or
not guilty

Filed nov 28th 1828A G clk

County Of St. Louis , Sct.
The State Of Missouri ,To The Sheriff Of S Louis County..Greeting.

You are hereby commanded to summon William Skinner Herman L Hoffman
Otis Reynolds . Thomas Cohen -
that setting aside all manner of excuse and delay, they be and appear in proper person before the Judge
of our Circuit Court ,on theforthwithday of, at the City of St .
Louis , then and there to testify and the truth to say in a certain matter of controversy now pending
in our said Court, wherein Dolly is plaintiff,
and John Young is defendant,
on the part of the plaintiff; and have you then there this writ.

Witness, Archibald Gamble , Clerk of our said Circuit Court ,
at the City of St. Louis , thisfourth day of
April in the year of our Lord one thousand eight hundred
and nine A Gamble Clerk C.C.

March 1829

Dolly
vs John Young

William Skinner .

Herman L . Hoffman

Otis Reynolds

Thomas Cohen .

forthwith for pltffs

Executed the writ on WSkinner H.L Hoffman. Otis
Reynolds & Thomas Cohen April 6. 1829 by reading
to them the same

R.Simpson Shrf Service $ 2.00

Execute

County Of St.Louis , Sct.
The State Of Missouri ,To The Sheriff Of Saint Louis County..Greeting:

You are hereby commanded to summon William Skinner Herman L Hoffman
Otis Reynolds and Thomas Cohen
that setting aside all manner of excuse and delay, They be and appear in proper person before the Judge
of our Circuit Court , on the Fifth day of August, at the city of St .
Louis , then and there to testify and the truth to say in a certain matter of controversy now pending in
our said Court, wherein Dolly is plantiff
and JohnYoung is defendant,
on the part of the plantiff; and have you then and there this writ.

Witness, Archibald Gamble , Clerk of our said Circuit court,
at the City of St. Louis , this Third day of
June in the year of our Lord, one thousand eight hundred
and twenty nine Archibald Gamble Clerk, C. C.

Executed this writ on William Skinner . Herman L
Hoffman & Thomas Cohen June 5th 1828OReynolds
not found

R Simpson Shff

July 1829

Dolly

John young
for the plaintiff

William Skiner

Herman L Hoffman
Otis Reynolds

Thomas Cohen

on 5th august Servce - 1.50

County Of St.Louis , Sct.
The State Of Missouri ,To The Sheriff Of Saint Louis County..Greeting:

You are hereby commanded to summon William Skinner Herman L Hoffman
Otis Reynolds Thomas Cohen
that setting aside all manner of excuse and delay, they be and appear in proper person before the
Judge
of our Circuit Court , on the First day of December, at the city of
St. Louis , then and there to testify and the truth to say in a certain matter of controversy now pending
in our said Court, wherein Dolly is plantiff
and JohnYoung is defendant,
on the part of the plantiff-; and have you then and there this writ.

Witness, Archibald Gamble , Clerk of our said Circuit
court, at the City of St. Louis , this 27th day
of October in the year of our Lord, one thousand eight
hundred and twenty nine Archibald Gamble Clerk, C. C.

Executed this writ on Thomas Cohen Nov 2nd on
William Skinner & Herman L Haffman Nov
3rd on Otis Reynolds Novr 4th 1829 by Reading
the server to them

R. Simpson Sheriff
by > Brotherton Dp Shff Service $ 2.00

November Term 1829

Dolly
vs
John Young
for plaintiff

William Skinner 3

Herman L Hoffman 3
Otis Reynolds 4

Thomas Cohen 2

on 1st December.