State of Missouri asSt. Louis County
In the St. Louis Circuit Cort Nov Term 1844

Jim Brown who sues by his next friend
Jenny Brown complains of William Head
of plea of trespass and false imprisonment
for that whereas the said defendant on the day
of september in the year Eighteen hundred and forty
four made an assault upon the said plantiff
at the county and state aforesaid and then and there
imprisoned and attracted the said
kept and detained him in prison
then and there without any reasonable probable cause whatsoever
for a long span of time to wit for the space of
twelve hours then next following country to the
laws of the said state and against the will of the said
plantiff And the said plantiff further
of the committing of the said grievances was still is
a free person And Father that the said defendant
then and there held and still holds the said plantiff
in slavery and then wrongs to the said plantiff
the said defendant then and there did Countrary to
the pleas and dignity of the said state And to the
damage of the said plaintiff of Five Hundred
dollars and Therefore the said plaintiff brings
suit &c

Elias B Smith p.q..

State of Missouri
as
St. Louis County
To the Hon. Judge of the Circut Court of St. Louis County

ss

Your petitioner respectfully states to the
Court Your Honor that the honor mentioned in the Declaration above is
held in slavery by William Read in this County and that
he the said Louis is entitled to his freedom. In Consequence of a action proceeding him in the state of Wrynim County to the laws of the
state of Virginia to wit Jenny Brown the mother of said Jim
was brought into the state of Virginia for the purpose of sale
by him the Martin of which slaves then and is now a free person and was afterwards brought to
the state of Missouri and in said state of Missiouri she has
been held in slavery for more than twenty years against
her will during which time the said Lein was born
and now of the age of. fourteen years (14 years)

Your petitioner therefore prays your
Honor to allow him to sue as a free person
to establish his right to freedom and duly

Sworn to and submitted before me the 14th day Oct.1844
James J Purely a Justice of the County
Court and for St. Louis County Jenny herXmark Brown

In the St. Louis Circuit Court
Nov Term 1844

Elias B Smith p.q..

State of Missiouri
County of St. Louis In the St. Louis Circuit Court . - On reading the for giving petition

It is ordered that the petitioner“ Jim Brown " has
leave to sue as a poor person, and that Elias B. Smith Esq.,
is hereby assigned as his counsel: and it is further ordered that
said Petitioner have reasonable liberty of attending his counsel and
the Court, as occasion may require, that he be not removed without
the jurisdiction of this Court, and that he be not subjected to any
severity on account of his application for freedom.

John M K.Judge ,

In the St. Louis County Court
Nov Term 1844

Elias B. Smith .
p.q..

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

We command you to Summon William Head
if he be found in your County that he be and appear before 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 Mon-
day of November next, then and there to answer unto
Jim Brown who sues by his next friend
Jenny Brown of a plea of trespass
and false imprisonment
to the damage of said plaintiff Five hundred
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 24th day of
October 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

Executed this writ in the County of St. Louis
on the 2nd day of October 1844 by reaching it and the
declarition to William Head the deffendant and
also by reading to Said William Head the orders
of the Judge endorsed upon this writ

Fee $1.50
William Milburn Sheriff By R Dowling Deputy

No 229 St. Louis Circuit Court
November Term 1844

Trespass & false imprison=
=ment

Damages $ 500
E B Smith p.q.
Filed Oct 24th 1844
John Ruland Clerk

It is ordered that the petitioner have
reasonable liberty, to sue as a poor
person and Elias B Smith assigned
her as counsel. It is further ordered
that she have reasonable liberty to
attend the Court and her counsel as
occasion may require and that she
be not removed out of the jurisdiction
of this court & that she be not
subjected to any severity on account
of her application for freedom

Free ✓ (138)

plea filed 15p 290trespass feby 2 184617 p 72

In St. Louis Circuit Court
by Nov. term 1844.

And the said defendant William Head
by his attornies, comes and
defends the force and injure when
and say, that he is not guilty of the
said suppored trespass above said what
charge in any part thereof in manner
and form, as the said plaintiff hath
above thereof complained against here
for this he puts himself upon the
country

Leslie LordforDeft.

Plea

Leslie LordforDeft. Filed Nov 18th 1844
John Ruland Clerk