To the Circuit Court of St Louis County in the State of
Missouri

Your Petitioner James Wilkinson a man of color represents
to said court that he is justly entitled to his Freedom
but is now held in Slavery by Aaron Young in the County
of St. Louis & is claimed by said Young as his Slave -
your Petitioner states that in the fall of the year 1827 at St
Louis said Aaron Young agreed with your Petitioner that
he might pass free as he pleased & laboras he pleased
& that when ever your Petitioner would pay said Aaron
Five hundred dollars he said Aaron would liberate your
Petitioner from Slavery - your Petitioner says that in the
fall of 1827 & winter of 1828 - he went into the State of
Illinois & hired himself to labor with one Osborn in said
State of Illinois & Laboured with Said Osborn in Illinois
about four months & your Petitioner says that he
went into the State of Illinois & Laboured with said
Osborn as aforesaid with the permission & consent
of said Aaron Young - Your Petitioner Says that
afterward in the year 1828 - your Petitioner went to
Galina in the State of Illinois in Company with Young
the brother of said Aaron & Staid & Laboured at
Galina in that year about four months & your
Petitioner says that he went to Galina aforesaid &
Staid & Laboured there as aforesaid with the assent
& permission of Said Aaron Young - Your Petitioner
further says that after the year 1827 he paid said
Aaron Yang Four Hundred Dollars & afterwards as a
consideration for Petitioners freedom & that he completed
the payment of this sum more than four years ago
yet Said Aaron Young held your petitioner in
slavery & refuses to emancipate him your Petitioner
Prays to be permitted to sue as a poor person to
Establish his freedom that counsel may be assigned
to him & that such further orders may be made
in his behalf as his case requires & this warrants
& he will
pray &

James his Wilkinson
Mark

State of Missouri
St. Louis County ss

This day personally appeared before me
Patrick Walsh a Justice of the Peace in
and for said county James Wilkinson the
within named Petitioner & I read the said
Petition to said James & he being duly sworn
on his oath says that the facts in the within
petition stated are true

James Wilkinson
Petition for
leave to sue in
form a pauperis

filed April 2nd 1833 A Gamble
Clk

order permitting to sue Book 6 - page 446

State of Missouri Circuit Court third Judicial Circuit
July Term AD 1833.

Saint Louis County of James Wilkinson by Bird his attorney
complains of Aaron Young of a plea of trespass on
the case for that heretofore towit on the first day
of January on the year of eighteen hundred
& Twenty eight the said defendant withforce & arms an assault
did make upon him said plaintiff & him said
plaintiff did then & there beatbruisewound & ill
treat & him said plaintiff did then & there imprison
& hath kept & detained said plaintiff in prison there
for a long span of time towit from the day last
aforesaid untill this time without any just or legal
cause whatsoever & other wrongs to the said plaintiff
then & there did against the peace & dignity of said
State. And the plaintiff avers that before & at the
time of the committing the said secured grievances he
was & still is a free person & that said defendant
held & detained & still holds & detains him in slavery
wherefore said plaintiff says he is greatly injured
& hath sustained Damages to five hundred dollars
therefore he sues &c.

G A Plffs atty

County of Saint Louis ss
The State of Missouri To the Sheriff of the county of Saint Louis Greeting

We command you to summon Aaron 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 St. Louis within and for the county of Saint Louis on the
fourth Monday of July instant then and there to answer unto James
Wilkinson of a plea of trespass on the case to the damage of said plaintiff
of five hundred dollars and have you then there this writ

Witness Archibald Gamble Clerk of our said
circuit court at office this fifth day of July one
thousand eight hundred and thirty three Archibald Gamble Clerk

Gustavus A Bird Esquire presents to the court the petition
of James Wilkinson a man of color praying that he may be permitted
to institute suit against Aaron Young for Establishing his right to freedom
and that he may be permitted to sue as a poor person thereupon the court permit
the said James Wilkinson to sue as foresaid and direct that an action of assault
and Battery and false imprisonment be brought in the name of the said
James Wilkinson and Assign the said Gustavus A Bird as his counsel and
it is ordered by the court that the said Aaron Young permit the said
James Wilkinson to have a reasonable liberty of attending his counsel and
the court when occasion may require it and that the said petitioner
shall not be taken or removed out of the Jurisdiction of this court or be
subject to any severity of treatment on account of his said application
for freedom

a true copy of the order A Gamble Clerk

No 102 Saint Louis Circuit Court
July Term 1833

James Wilkinson
vs
Aaron Young

This is a suit for freedom
declaration in the form
prescribed by Statute Trespass
& Damages $500 -

An order that made last
Term permitting said
Plff to sue as a poorperson
to Establish his freedom
&c.&c.. The Clerk will
please issue a summons
& copy of said order

G A Bird Plffs
attyFiled 5th July 1833 Archibald Gamble ClerkOrder permitting plff to sue &c Book 6 page 446
Judgment by default Book 7 page 34

Served this writ by reading at the defendants usual
place of residence in St. Louis County
a certified copy of the writ and declaration
with a free white member of his
family over the age of fifteen years to
whom I made known the contents
thereof on the 6th July 1833

Service $1.00 Jno. K. Walker shff
by Stone
Shff