To the Honourable the Judge of the St Louis Circuit
Court . This petition of Margaret , Henry   Sally ,
persons of colour, represents to your Honour, that
they, as they belive are entitled to their freedom on
the following grounds: theirmother Jane was formerly
the slave of Col.Dallam of Maryland and by
him taken to the State of Kentucky   where
she resided untill a fewyears since, and where your
your petitioners were born, that her
master removed her from Maryland he informed
her that he had manummitted her, such
manummissions to take effect at a future
time, and that said time had elapsed before your
petitioners were born; your petitioners say
that they are informed   believe that said
manummission of their matter was by deed
and that the deed is now of record in the proper
office in the state of Maryland , which can be
obtained. They also state that some time after
the arrival of their mother in Kentucky she
was by her said master actually freed   discharged
from all service   obedience, he giving her
complete   perfect personal liberty and power
to do with her self what she pleased, and requiring
from her neither service or wages for her time.
That from that time until the time of her masters
death a period from ten to fifteen years she
lived as a free person with the consent of her
master as aforesaid in the same town or neighborhood
with him. That they your petitioners
were with their mother, brought to St Louis by
a son of their old master Cal Dallam namely
William Dallam , who afterwards went to Kentucky and that they are now claimed by him as his slaves
and that said Dallam by his agents have been and
now are making preparations to carry off your
petitioners to the South beyond the reach of
assistance   where it will be impossible for
them to assert their right to freedom your petitioner
say that they are all imfants under twenty
one years- they therefore pray that they may
severally be permitted to sue as poor persons
by their next friend George Brown , and that
your honour will assign them counsel for
to prosecute their suits for freedom- And as
your honour has already authorized their
said mother to sue for her freedom, your petitioners pray your honour to grant them
the same privilege in which case they believe
they will be able to establish their right to
freedom   your petitioners will pray etc

Henry
Sally
Margaret
by
their next
friend George Brown

State of Missouri

Third Judicial Circuit Court : It is hereby ordered
that an the foregoing petition that the subscribers thereto
Henry , Sally and Margaret be permitted to sue as
poor persons by George Brown their next friend
to establish their right to freedom and John Newman
Esq is assigned on their counsel - It is also ordered
moreover that said Henry Sally and Margaret shall have reasonable
liberty to attend their counsel and the Court when other occasion may require
  that said Henry , Sally and Margaret not be removed out of the jurisdiction
of the Circuit Court of St Louis County nor be Subjected to any
severity because of their application for freedom given under
my hand their 22 day of July A.D 1831.

Margaret
Sally  
Henry
Petition

Filed July 22nd 1831A gamble Clk

The defendants not found in my
County 12th Novr 1831

No 4 St Louis Circuit Court
November Term 1831

Margaret by next friend
vs
William
Declaration

DallowFiled 23rd July 1831 Archibald Gamble Clerk

This is an action of trespass
assault   battery   false
imprisonment
$ 500 summons

In the St Louis Circuit Court
County of St Louis , to wit, November Term 1831

Margaret a girl of colour
an infant under the
age of twenty one years by George Brown her
next friend complains of William Dallow in
custody   of a plea of trespass of assault   battery
  false imprisonment for that heretofore
to wit, on the twentieth day of july in the year
Eighteen hundred   thirty one at the county aforesaid
the said Defendant with force   arms made
an assault upon the said plaintiff   then
  there beat wounded   ill treated her and then
  there with force and arms falsely   unlawfully
imprisoned the said plaintiff   kept her and
detained her in prison there without any
lawful authority or cause for a long space of
time to wit for the space of twodays there next
ensuing - and said plaintiff further says that
before and at the time of the committing of the
said several grievances she was   still is a
freeperson   that said Defendant held   detained
  still holds   detains her in slavery wherefore
the said plaintiff says she is greatly injured
and hath sustained damage to fivehundred
dollars   therefore she sues   etc

John Newman esq

The State of Missouri
County of Saint Louis . ssTo the Sheriff of the county of Saint Louis
Greeting

We Command you to summon William Dallam that he be and appear
before the Judge of our Circuit Court at the next November term thereof
to be held at the city of St Louis within and for the County of Saint Louis
on the fourth monday of November next then and there to answer unto
Margaret a Girl of color an infant under the age of twenty one years by George Brown her next friend of a plea of trespass assault and Battery and false imprisonment wherefore the said plaintiff says she is greatly injured
and hath sustained damage to five hundred dollars and have you then there
this writ

Witness Archibald Gamble Clerk of our sid Circuit
Court at Office this Twenty Second day of July One
thousand Eight Hundred and thirty one Archibald Gamble Clerk

copy of the order of the Judge on endorsed on the petition of plaintiff  

State of Missouri - Third Judicial Circuit to wit; It is hereby ordered that on
the foregoing petition that the subscribers thereto Henry Sally and Margaret be
permitted to sue as poor persons by George Brown their next friend to establish
their right to freedom and John Newman Esq is assigned as their counsel it
is also ordered moreover that said Henry Sally and Margaret shall have
reasonable liberty to attend their counsel and the court when occasion may
require and that said Henry Sally   Margaret shall not be removed out
of the Jurisdiction of the Circuit Court of St Louis County nor be subjected
to any severity because of their application for freedom- given under my
hand this 22 day of July A D 1831

Will C Carr