To the Hon Circuit Court for the County of Saint Louis :
The petition of James a free person of colour aged about
nine years humbly represents that he was born free the child of Martha
Ann a woman of colour entitled to freedom but in fact held
in slavery by Sarah Young : that after the decease of said
Sarah Young, your petitioner along with his mother said
Martha Ann was held in slavery by Hiram Cordell
Administrator of the Estate of said Sarah Young and yet is
held in slavery by the said Hiram Cordell : and the said
Martha Ann has presented her petition to this Court
for leave to sue said Cordell for her freedom and in said
petition has set forth the grounds upon which she is entitled
to her freedom, and your petitioner begs have to refer to
said petition of Martha Ann   prays that so much
as sets forth her title to freedom may be taken as
part of this petition: and your petitioner humbly prays
that he may be permitted to sue said Cordell for the
recovery of his freedom by judgement of law, and may
present such suit as a poor person and have counsel
assigned him by the Court   have reasonable liberty
of attending his counsel and the Court, and further that
all persons claiming under said Cordell   the said
Cordell himself be restrained by the order of the court
from removing your petitioner out of the jurisdiction
of this Court   so will ever pray  c

The mark X of James
by his Mother Martha Ann

Saint Louis ss. Martha Ann the mother of the above named James the petitioner
makes oath and says that the facts set forth in the foregoing petition
are true.

The mark of X Martha Ann

Subscribed   Sworn in open court this
18th day of April AD 1844 — before me

John Ruland Clerk

No. 8. Nov. T. 1844

James a Free Black
vs
Hiram Cordell

Petition to sue for
freedom &c

Filed April 18th 1844. John Ruland Clerk.

Petition filed order Bk 15 p 5.

In the Circuit Court for Saint Louis County
November Term, 1844. Saint Louis County

James, a person of colour, who by leave of the Court
first had and obtained brings this suit as a poor person, by Field his counsel assigned by the Court for this purpose, complains
of Hiram Cordell in a plea of Trespass, for that the said James
before and at the time of the committing of the greivances hereinafter
mentioned, was and yet is a free person, and the said Hiram
Cordell on the 1st day of January now last pastwith force and
arms at Saint Louis aforesaid in and upon the plaintiff
did make an assault   then   there did imprison the
platinfiff   kept and detained him in prison for a long
space of time to wit for one month then next ensuing,
and then and there held   ever since has held   still holds
in slavery the said plaintiff and other wrongs to the plaintiff
then   there did against the peace, and to the great
damage of the plaintiff, and for the recovery of his freedom
the plaintiff brings suit &c

Field

James, coloured person vs Hiram Cordell
Suit for freedom
in forma pauperis

Let summons insue

Field