To the Honorable John M. Krum , Judge of the
Circuit Court of the Eighth Judicial Circuit:

Your petitioner, Jesse , a man of color, would
humbly represent to your Honor that he was
purchased and held as a slave by one Milton
Duty, in his lifetime, sincedeceased, that
the said Duty, being there a resident of the
State of Mississippi , by his last will and
testament, dated the twenty-sixth day of October
A.D. 1836, directed that, at his decease
your petitioner among other slaves which
he then owned, should be manumitted
and set free. Your petitioner further
represents that the said Duty removed your
petitioner, amongst other his said slaves,
to the State of Missouri in the month of
March A.D. 1837, and in the month of
August A.D . 1838, departed this life in
the city and county of St. Louis and State
of Missouri , having made no other will
than the one above mentioned; that the
said will was, as your petitioner is informed
and believes, established and admitted
to Probate, in the Probate court of
Warren County in the State of Mississippi
on the twenty-sixth day of November A.D.
1838, and, on the twenty second of June A.D.
1839, was recorded, as the last will and testament
of the said Duty, in the County Court
of , and letters of administration
thereof granted to one George W .|Coon, of the said city and county of St .
Louis , who now, as your petitioner verily
believes, wrongfully and unjustly holds your
petitioner in slavery. Your petitioner therefore
humbly prays your Honor that he
may be allowed to prosecute this his suit
for freedom, as a poor person, that counsel
be assigned him, and that the usual
orders in such cases be made on his behalf,
and as is duty bound he will
ever prays  C.

State of Missouri
County of St Louis
ss

This day personally appeared
before the undersigned, Jesse , the above named
petitioner, who being duly sworn on his oath
says that the facts stated in the foregoing
petition are true to the best of his knowledge
and belief.

his Jess
MarkSworn to and subscribed
before me the 28th day of
May 1844 Peter Bruess
Justice of the Peace

State of Missouri
St. Louis County
ss.

Jesse , a man of color, plaintiff
in this action, complains of George W .
Coons , defendant in said action, of a plea
of trespass and false imprisonment; for that
the said defendant on the twenty fifth day
of May in the year of Our Lord eighteen
hundred and forty four, with force and
arms, at the County aforesaid assaulted the
said plaintiff and then and there beat, bruised
and ill-treated him, and then and there imprisoned
him and then and there kept and
detained him in prison, without any reasonable
or probable cause whatsoever for a long time
to writ: for the space of six hours then next
ensuing, against the will and consent of the
said plaintiff and contrary to the laws of
the State of Missouri , and the liberties of
the people thereof; and the said plaintiff
avers that before and at the time of the committing
of the grievances above set forth he the
said plaintiff was, and still is, a free person, and
that the said defendant wrongfully and
unjustly, held and still holds him, said
plaintiff, in slavery; and other wrongs
to the said plaintiff then and there did
against the peace of the State of Missouri
and to the damage of said plaintiff
five thousand dollars, and therefore he sues

Risque
  Townsend for plff.

  to sue as a
poor -   R,

Counsel  c

St. Louis Circ. Ct. Nov.
Term 1844.

Jesse (a man of Color
vs
George W . Coons

This is a suit for freedom.
let summon
Risque  Townsend
p. q.

Filed May 28th 1844. John Ruland , Clk Petn. filed
BK15p82.

County Of St. Louis , ss.
The State Of Missouri ,To the Sheriff of St. Louis County—Greeting:

We command you to Summon George W. Coons , if he be
found in your County, that he be and appear
before the Judge of our Circuit Court , on the first day of the next term thereof, to
be held at the City of St. Louis , within and for the county of St. Louis , on the third Monday
of November next, then and there to answer unto Jesse a
man of color, of a plea of trespass   false imprisonment,
to the damage of said plaintiff five thousand
dollars: And have you then there this writ.

Witness, John Ruland , Clerk of our said Court,
with the seal thereof hereto affixed, at office, in the
city of St. Louis , this third day of
June in the year of our Lord eighteen
hundred and forty four. John Ruland Clerk

I acknowledge myself bound for all costs that may accrue in the above cause.

Witness my hand and seal, at St. Louis , this day of 184

Default   Judgment for freedom   costs March 26th 184516 p 137. (136)

No 32 In the St Louis Circuit Court
>November Term 1844

Jesse a man of color
vs
Summons 10th June
George W. Coons

Trespass   false imprisonment
Damages $ 5000.00

Risque   Townsend . p.q.

"It is ordered that said petitioner have
leave to sue as a poor person   the Court doth assign
Messrs Risque   Townsend as Counsel for said petitioner: and it is further ordered that
said petitioner have reasonable liberty
to attend his
counsel   the Court, as occasion may require, that
he be not removed without the jurisdiction of the
Court, and that he be not subjected to any severity
on account of his application for
freedom".

Filed June 3rd 1844 John Ruland Clerk In forma pauperis () (113)

Executed this writ in the County of
St Louis on the 10th day of June 1844 by offering
to read it and the declaration to George W Coons
which he refused to hear- also by reading to the
said George W Coons the orders of the Judge
endorsed upon this writ.

William Milburn Shff
By N.C. Osburn Depy Fees $ 1.50