To the Hon, the Judge of the Circuit Court of the Third
Judicial Court, State of Missouri , Saint
Louis County

Your Petitioner Jack represents
that he was born in Africa , was
brought from Africa to South Carolina , was
brought from South Carolina to the City of
Saint Louis in the County of Saint Louis and
State of Missouri by David Williamson and
sold by him to Charles Collins , who sold him to James English and the said
English took him to Carolton in the State of Illinois
in the year One thousand eight hundred Twenty nine
where he said Jack resided
Twelve Months and that he was brought from
Illinois to Saint Louis & Saint louis County & State
of Missouri by the said Charles Collins , that he
now resides in the City, within the County of Saint
Louis & State of Missouri

Your petitioner states that he
is still held in slavery by the said Charles Collins
in the County of Saint Louis and State of Missouri
when he is advised and believes that he is entitled
to his freedom and therefore your petitioner prays
that he may be permitted to sue in forma pauperis to
estabish his right thereto and that other and further
orders may be made in the premises as the law directs,
and as may seem & proper to this Hon Court

JackXhis mark

State of Missouri
St. Louis County Ss

This day came before me Jack

the above named petitioner & on his
oath says that the facts in the above petition
stated are true

Stated are true
Sworn to before me
September 23 1830Bird
JackXhis mark

The within named Jack is hereby permitted
to sue as a poor person to establish his right to free
-dom and George F . Strother Esquire is assigned as his counsel. It is moreover order that the said
Jack have reasonable liberty to attend his his counsel
& the court when occasion may require: and that
he shall not be taken out of the jurisdiction of the
Circuit Court for the County of St Louis ,
> nor be subject to any severity because of his application
for freedom

Given under my hand This24. of Sept 1830.
Will C. Carr
Judge 3rd Circuit

Petition to sue in
forma pauperis

Filed 17March 1831
A Gamble Clk

Served this writ on Charles Collins
on the 17th March 1831 by offering to read
it & the declaration to him which he re-
fused to hear read & acknowledged service the order endorsed on said writ by
reading it to him on the same day at
at the same place

Jn. K Walker Shff

The other defendant William not
found in my County
9July 1831

John K Walker Shff

No. 3-
July Term 1831-
St Louis Circuit Court

Trespass assault & battery &
false imprisonment
The Clerk will issue sum

Geo. F Strother AttyFiled 17March 1831-
A Gamble Clk

Dismissed at defendants costsBook 6 page 285
Archibald Gamble Clerk

Fee bill 215

St Louis County Circuit Court
of the Term of July 1831 State of Missouri

Saint Louis County Jack a man of colour who by
permission of the Court sues in forma pauperis complains of
William Sewel Charles Collins For that on the first
day of September in the Year of our Lord 1830the said
Charles Collins made an assault on the said Jack
to wit at the City of Saint Louis
State of Missouri and then and there seized and laid
hold of the said Jack and with great force and violence
pulled, and draged about him the said Jack and
then & there struck the said Jack a great many violent
blows and strokes and then and there imprisoned the
said Jack and kept and detained him the said Jack ,
in prison there without any reasonable or probable cause
whatsoever for a long space of time to wit for the space of
six Months then next following contrary to law and against
the will of the said Jack whereby the said Jack was then and
there not only greatly bruised and wounded and was thereby greatly
exposed and his life endangered to wit within the County
aforesaid And the said Jack avers that before and
at the time of committing the said grievances he was &
still is a free person and that the defendant Charles
Collins held and detained him and still holds and
detains him in slavery to wit within the County of Saint
Louis aforesaid and other wrongs to the said Jack ,
then and there did against the peace of the State and
to the damage of the said Jack of Five hundred
dollars and therefore he brings suit

Geo F Strother
Atty

County of SLouis Ss
The State of Missouri To the Sheriff of S Louis County Greeting-

We command you to summon William Sewel and Charles Collins
that they 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 March next
then and there to answer unto Jack a man of Color of a Plea of
assault & battery and false imprisonment to the damage of said
plaintiff of five hundred dollars and have you then there this writ

Witness Archibald Gamble Clerk of our said Court
at Office theSeventeenth day of March 1831-
Archibald Gamble Clerk

The within named Jack is hereby permitted to sue as a poor person
to establish his right to freedom and George F Strother Esquire is
assigned as his counsel- It is moreover ordered that the said Jack
have reasonable liberty to attend his counsel & the court when occasion
may require, and that he shall not be taken out of the Jurisdiction
of the Circuit Court for the county of S Louis nor be subject to any sever-
ity because of his application for freedom

Given under my hand at hand at Chambers this 24th of sept-
1830 Will C Carr Judge 3rd Circuit