Nelly Richards
Petition--

Filed 17March 1831, A Gamble Clk

To the Hon. Judge of the Circuit Court of the Third
Judicial Circuit, Saint Louis County State of
Missouri .March Term 1831.

Your Petitioner Nelly Richards Represents
to this Honourable Court that she was born in
Charles County Maryland , lived there until she
was fourteen years old the property of Kitty Middleton
at whose death she was left free, after the death of Kitty
Middleton her daughter sent the Petitioner to Virginia
Forquier County to William Sewel the Husband of
Kitty Middleton's daughter, about four years since the said
William Sewel moved with his Family to Indiana
and the Town of Indanopolis,
of
where your Petitioner was allowed
allowed freedom by the Judgment of the Court of
that State, that after that the said Sewel removed
your Petitioner to Louisville Kentucky and brought
her from that place to the City of Saint Louis
That your Petitioner is Twenty four years old_
Your Petitioner states that she is still held in slavery
by the said William Sewel in the County of Saint Louis and
State of Missouri where she is advised and believes that
she is entitled to her freedom and therefore your petitioner
prays that she may be permitted to sue in forma pauperis
to establish her right thereto and that such other and
further orders may be made in the premises as the
Law directs and as may seem and proper to
this Hon Court--

Nelly Richardsxher markSworn to & subsribed this 10th day of March 1831 Before

State of Missouri
Third Judicial Circuit, To wit,

It is hereby ordered that the within named Petitioner
Nelly Richards be permitted to sue as a poor person
to establish her right to freedom and G. T. Strother Esq
is assigned as her counsel. It is moreover ordered that
the said Nelly have reasonable liberty to attend her counsel
and the court whenever occasion may require: and that
she shall not be removed out of the jurisdiction of the
Court nor be subjected to any severity on account of her
application for freedom. Given under my hand at my chambers this11th. of march 1831.

Will . C. Carr
Judge of 3d Circuit aforesaid

No. 2.
July Term 1831 S Louis Circuit Court

Trespass assault battery
& false imprisonment
The Clerk will issue
Summons

Geo. F. Strother
Atty
Filed 17th March 1831
A Gamble Clk

The defendant not found in my
County9th July 1831Non est. 50 cts

Jn K Walker
Sheriff

St Louis County Circuit Court
of the Term ofJuly 1831 State of Missouri
Saint Louis County

To wit Nelly Richards , a woman
of colour who by permission of the Court sues in forma
pauperis, complains of William Sewel For that on the
first day of August in the Year 1831 the said William
Sewel made an assault on the said Nelly Richards
to wit at the City within the County of Saint Louis and
State of Missouri and then and there seized and laid
hold of the said Nelly Richards and with great force and
violence, pulled and draged about her the said Nelly
Richards and then and there struck the said Nelly Richards
a great many violent blows and strokes and then and
there imprisoned the said Nelly Richards and kept
and detained her 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 did against the will of the said Nelly
whereby she the said Nelly Richards was then and there
not only greatly bruised and wounded but was thereby
greatly exposed and her life endangered to wit at the
City of Saint Louis aforesaid and and within the said
County and the said Nelly Richards avers that before
and at the time of committing the said grievances she was &
still is a Free_ Person and that the defendant William
Sewel held and detained her and still holds and detains
her in slavery to wit at the County of Saint Louis aforesaid
and other wrongs to the said Nelly Richards then and
there did against the peace of the State and to the damage
of the said Nelly Richards of Five hundred Dollars
and therefore she brings suit

Geo F Strother
Atty.

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

We command you to summon William Sewel 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 Nelly Richards of a plea of trespass 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 the seventeenth day March eighteen hundred and thirty one Archibald Gamble Clerk

State of Missouri
Third Judicial Circuit-to wit

It is hereby ordered that the within named petitioner Nelly Richards be permitted to sue as a poor person to estab-
lish her right to freedom and G.F. Strother Esq. is assigned as her counsel
It is moreover ordered that the said Nelly have reasonable liberty to attend
her counsel and the court whenever occasion may require and that she
shall not be removed out of the Jurisdiction of the Court nor be subjected
to any severity on account of her application for freedom

Given under my hand at my Chambers this 11th.. of March 1831
Will C. Carr Judge of 3d Circuit aforesaid_