Nelson Kerr his
Petition to sue for
freedom & the order
of Luke E Lawless
Judge to authorizing suit

No 104
St Louis Circuit Court July Term 1834

To the Honorable Luke E Lawlesss Judge of the
Third Judicial Circuit of the state of Missouri

Your Petitioner Nelson Kerr a free man of
color represents to your Honor that he is justly
entitled to his freedom but that he is now
held & detained
in Slavery by Matthew Kerr
in the County of St. Louis and State of Missouri
and is claimed by said Matthew as his
slave. Your petitioner states that during
the months of September, October, November, &
December in the year 1833& in January & February
1834 while your petitioner was claimed by said
Matthew as his slave your petitioner was
hired to labor to Labor the State of Illinois
by said Matthew with one Mr Adams
& that said Matthew has settled with
from said Mr. Adams the pay for
the of your petition rendered in
the State of Illinois as aforsaid
your petitioner therefore prays that he
may be permitted to sue as a poor
person to Establish his freedom, that
counsel may be assigned to him &
such further & other order may be
made in the premises as his &
the Law warrants

Nelson his markXMark

Nelson the above named petitioner on his oath says that the facts in the above petition
Stated are true & that he is able to prove them

Sworn to and subscribed before me
this 23rd day of June A D 1834
Patrick Walsh Justice of
the peace St. Louis County
Nelson hisxmark Kerr

I Luke Lawless Judge of the Third Judicial Court of the State of Missouri do hereby order
that the within named petitioner Nelson Kerr
be permitted to sue as a poor person to establish
his freedom and I do hereby assign Gustavus A
Bird as his counsel to commence & prosecute his suit
for freedom and I do further order that
said petition have reasonable liberty of
attending his counsel & the St Louis Circuit Court
when occasion may require and that said petitioner Shall not be taken or removed and out of
the jurisdiction nor be subjected to any severity of
treatment because of his application for
freedom

St louis July 3rd 1834

State of Missouri Circuit Court Third Judicial
Circuit
July TermAD 1834

St Louis County SS Nelson Kerr a man of color by
Bird his attorney complains of Matthew Kerr
of a plea of tresspass assault & battery & false
imprisonment for that heretofore, towit on
the first day of September in the year of our
Lord eighteen hundred & thirty three at St Louis aforsaid the said defendant with
force & arms an assault did make upon him
said plaintiff & him the said plaintiff did
then & there hurt bruise wound & ill treat
and the said defendant did then & there
unlawfully imprison the said plaintiff & hath kept
& detained him in prison there from
then untill the commencement of this
suit & other wrongs to the said plaintiff
then & there did against the peace & dignity of the state and the plaintiff
that before & at the time of the
committing said the
said plaintiff was and is now a free person
and the defendent held & detained & still
holds & detains plaintiff in slavery wherefore
plaintiff says his is greatly injured & hath
sustained damages to five hundred dollars
therefore he sues to

GA Bird atty
for Plff

County of Saint Louis ss
the state of Missouri
To the Sheriff of the County of Saint Louis Greeting

We Command you to Summon Matthew Kerr that he be and
appear before the Judge of our Circuit Court at the next term thereof
to be held at hte City of Louis within and for the County of Saint
Louis on the fourth monday of July then and there to
answer unto Nelson Kerr a man of color of a plea of assault
and battery and false imprisonment wherefore plaintiff ways he is
greatly injured and hath sustained damages to five hundred dollars and
have you then there tjos writ

Witness Archibald Gamble clerk of our said
Circuit Court at office this tenth day of July
one thousand eight hundred and thirty four
Archibald Gamble clerk

I Luke E Lawless Judge of the third Judicial Circuit of the state of Missouri do hereby
order that the written named petitioner Nelson Kerr be permitted to sue as a poor person to
establish his freedom and I do hereby assign Gustavus A Bird as his coundel to
commence & prosecute his suit for freedom and I do further order that said petitioner
have reasonable liberty of attending his counsel & the St Louis Circuit Court when occassion
may require and that said petitioner shall not be taken or removed out of the jurisdiction
of the court not be subject to any severity of treatment because of his application for
Freedom

LE Lawless
St. Louis July 3rd 1834
The above is a true copy of the order made by the Judge permitting the plaintiff to sue
Archibald Gamble clerk

Served this unit on Matthew Kerr by
reading it & the to him or
the 11th day of July 1834 in the city
of S. Louis I also read to him at the
same time the above copy of the order
of the judge permitting him to

Fee $ 5.00
Jno K Walker

And the said defendant by Gamble
his attorney and defend the force and injury
when and says he is not guilty of the
paper above laid to his charge in manner
and form as the said plaintiff hath above thereof
complained against him and of this he puts
himself upon the county &

FiledAugst1834 A Gamble Clk HR Gamble atto for deft

discontinued book 7 page 275 Pltf

No 104
Saint Louis Circuit Court
July Term 1834

This is a suit for
freedom in form tresspass
assault & battery & false
imprisonment damages
$ 500 plaintiff has
to sue as a poor
person counsel has been
assigned to as the
petition & order here within
filed . The clerk
and please issue a summons to

GA Bird
atty for Pltf
Filed10th July 1834
Archibald Gamble clerk