To the Honourable the Judge of the St Louis Circuit Court . This petition of Margaret , Henry   Sally , persons of colour, represents to your Honour, that they, as they belive are entitled to their freedom on the following grounds : their mother Jane was formerly the slave of Col. Dallam of Maryland and by him taken to the State of Kentucky   where she resided untill a few years since, and where your your petitioners were born , that her master removed her from Maryland he informed her that he had manummitted her, such manummissions to take effect at a future time, and that said time had elapsed before your petitioners were born; your petitioners say that they are informed   believe that said manummission of their matter was by deed and that the deed is now of record in the proper office in the state of Maryland , which can be obtained. They also state that some time after the arrival of their mother in Kentucky she was by her said master actually freed   discharged from all service   obedience, he giving her complete   perfect personal liberty and power to do with her self what she pleased , and requiring from her neither service or wages for her time. That from that time until the time of her masters death a period from ten to fifteen years she lived as a free person with the consent of her master as aforesaid in the same town or neighborhood with him. That they your petitioners were with their mother, brought to St Louis by a son of their old master Cal Dallam namely William Dallam , who afterwards went to Kentucky and that they are now claimed by him as his slaves and that said Dallam by his agents have been and now are making preparations to carry off your petitioners to the South beyond the reach of assistance   where it will be impossible for them to assert their right to freedom your petitioner say that they are all imfants under twenty one years- they therefore pray that they may severally be permitted to sue as poor persons by their next friend George Brown , and that your honour will assign them counsel for to prosecute their suits for freedom- And as your honour has already authorized their said mother to sue for her freedom, your petitioners pray your honour to grant them the same privilege in which case they believe they will be able to establish their right to freedom   your petitioners will pray etc

Third Judicial Circuit Court : It is hereby ordered that an the foregoing petition that the subscribers thereto Henry , Sally and Margaret be permitted to sue as poor persons by George Brown their next friend to establish their right to freedom and John Newman Esq is assigned on their counsel - It is also ordered moreover that said Henry Sally and Margaret shall have reasonable liberty to attend their counsel and the Court when other occasion may require   that said Henry , Sally and Margaret not be removed out of the jurisdiction of the Circuit Court of St Louis County nor be Subjected to any severity because of their application for freedom given under my hand their 22 day of July A.D 1831.

Margaret Sally   Henry Petition

The defendants not found in my County 12th Novr 1831

Margaret by next friend vs William Declaration

This is an action of trespass assault   battery   false imprisonment $ 500 summons

Margaret a girl of colour an infant under the age of twenty one years by George Brown her next friend complains of William Dallow in custody   of a plea of trespass of assault   battery   false imprisonment for that heretofore to wit, on the twentieth day of july in the year Eighteen hundred   thirty one at the county aforesaid the said Defendant with force   arms made an assault upon the said plaintiff   then   there beat wounded   ill treated her and then   there with force and arms falsely   unlawfully imprisoned the said plaintiff   kept her and detained her in prison there without any lawful authority or cause for a long space of time to wit for the space of two days there next ensuing - and said plaintiff further says that before and at the time of the committing of the said several grievances she was   still is a free person   that said Defendant held   detained   still holds   detains her in slavery wherefore the said plaintiff says she is greatly injured and hath sustained damage to five hundred dollars   therefore she sues   etc

We Command you to summon William Dallam that he be and appear before the Judge of our Circuit Court at the next November term thereof to be held at the city of St Louis within and for the County of Saint Louis on the fourth monday of November next then and there to answer unto Margaret a Girl of color an infant under the age of twenty one years by George Brown her next friend of a plea of trespass assault and Battery and false imprisonment wherefore the said plaintiff says she is greatly injured and hath sustained damage to five hundred dollars and have you then there this writ