The petition of Squire Brown a man of color respectfully represents that he is of instituting a suit against one Charles R Anderson in order to establish the right of your petitioner to freedom that his claim is founded upon the following grounds to wit that sterry Brown who had formerly owned your petitioner for some six or eight years to the fifth day of May 1841.& during the time he so owned your petitioner hired out your petitioner to work in the County of St Clair State of Illinois at various times between the years 1839 & 1841. for several months at a time. Your petitioner represents further that since May 1841. he has been from said & Brown his former & is now deemed by the said Anderson as his property & that he is now by the said Anderson held in slavery.

Your petitioner therefore prays that he may have learn to sue as a poor person in order to establish his right to freedom

ss

Squire Brown the petitioner above named being duly sworn deposes & says that the facts set forth in the above petition are true to the best of the knowledge beliefs of this deponent

Be it remembered that this within named Squire Brown is hereby allowed to sue as a poor person & Benjamin B Dayton is assigned as his counsel. and it is hereby ordered that said Brown have reasonable liberty to attend his counsel & the court as occ- asion may require . that he be not removed out of the jurisdiction of the St Louis circuit court that he be not subjected to any severity on account of his application for freedom In listing which set may hand this seventeenth day of January 1844 —

Squire Brown plaintiff in this suit by his attorney complains of Charles R Anderson of a plea of trespass

In that the said defend ant heretofore to wit on the first day of January eighteen hundred forty four at the City of St. Louis at said County with force & arms made an assault on said plaintiff & then beat bruised & ill treated him & then & there im prisoned him & kept him in prison for a long space of time to wit for the space of ten days then next- following contrary to the laws this State of Missouri & against the will of the said plaintiff. & other ways to the said plaintiff then & there did against the Law of the State of Missouri to the damage of the said plaintiff of five hundred dollars.

And the said plaintiff avers that before & at the time of the committing of the grievances aforesaid by the said defendant he the said plaintiff was & still is a free person & that the said defendant held & still holds him in slavery. Therefore he brings his suit

Squire Brown vs Charles R Anderson

Suit for freedom Trespass

Dam $ 500. ad pleas June 18

Peter & filed (by consent) & Plff allowed to the as a poor person order assigning Counsel &c & plea filed BK 14 p 338. Venue changed to Comr. pleas BK 15 p 131 (June 18. 1844.)

Buyam B Dayton buy duly sum deposes & says that on the 17th day of January a suit was commenced in the St. Louis County Court by Squire Brown against Charles B Anderson for freedom . by filing a declaration by Consent & also a Petition that plaintiff have been to sue as a poor person as provided by Statutes at the an order was made by the Honorable Bryan Mullanphy Judge of said Court that said Brown had as a poor person that this be assigned as his Counsel. also an with that said Brown have reasonable liberty to attendhis Counsel & the Court as occasion might require. & that he be not removed out of the jurisdiction of the said Court& that he be not subject to any severity on account of his application. John M Shrew Esq an attorney of appeared for the said Anderson & concealed to all the said orders & the of the said declration & also on behalf of Todd & Krum of which his is to filed a plea for the said Anderson on the day after said and this further says that he is informed by John W Constable of St Louis Court that he said at the request of said Anderson this day awarded Brown took him to the Slave Boat Admiral for the purpose as said Anderson told him of him south. that said Brown was put on said boat what was for New Orleans In what with said Brown has defauled for that place. this affiant believes therefore that said Brown is now by out of the jurisdiction of this Court Subscribed to this 19th January 1844 before me

to the sheriff of the county of St. Louis greeting whereas - Bryan Mullanphy the Judge of our Circuit Court of the Eighth Judicial Circuit, which includes the county of St. Louis is satisfied from the foregoing affidavit that Squire Brown a man of color a petitioner for freedom, who has instituted suit in said court to recover the same, is about to be removed out of the Jurisdiction of said court, you are hereby commanded to seize said petitioner wherever he may be found and bring him before our said Judge on Twentieth January in 1844 at nine o'clock A. M. at the goal in said county and summon any person claiming him or in whose possession he may be found to appear before our said Judge at said time & place & have you then there this writ- As witness the hand of our said Judge At Chambers in the City of St Louis this nineteenth day of January in the year of Our Lord One thousand Eight hundred and forty four

Executed this writ in the County of St Louis on the 20th day of January 1844 by seizing the body of Squire Brown and having him before the Honorable Bryan Mullanphy Judge of the 8th Judicial Circuit of Missouri at the goal as I am herein commanded and also by reading it to Israel Morris , he being the person claiming the said Squire Brown and in whose possession he was found

whereas Squire Brown a man of color has been brought before me by virture of warrant hereto annexed and one Israel Morris who claims him being, at the St Louis goal on 20th Jany 1844, called, comes not there upon the sheriff is hereby ordered to take possession of said Squire Brown , and hire him out from time to time during the pendency of the suit that hath been brought by said Brown in the St Louis County Circuit Court to recover his freedom and take a bond from the hirer in the penalty of hundred dollars conditioned as provided by eighth section of the act approved 27 Jan 1835 entitle "an act to enable persons held a in slavery to sue for their freedom - "

In the matter of Squire Brown a person of colour vs Israel Morris & C. R Anderson

Judgt is Morris & Anderson for costs of this proceding BK 14 p 357. Motion to set same aside as to Anderson filed Feby 12th 1844 & overruled 14 p 398. motion to set aside last overruling (for a rehearing ) filed Feby '44 overruled BK 14 p sustained 14p 422 & no to set aside judgt overed & Bill of Exs. filed 14p 422.

Charles R.Anderson comes & moves the Court that so much of the judgment of this court renderd on the Twenty sixth day of January A D 1844 as that said Anderson pay the costs & charges incurred in this behalf, be set aside & vacated . Because the same is without authourity in law.

In the matter of Squire Brown a person of color

Mo. to vacate judgt . as to Chas .R.Anderson-

Charles R Anderson by his attornies move the court to set aside the made in this cause one overruling the motion of said Charles R.Anderson filed on a former day of the present term of this Court, & that a new trial be granted to said Charles R Anderson

Motion to set aside order —

Be it remembered that on the 12th day of February 1844 Char -les R. Anderson filed his motion in words & figures following to wit: (here insert said motion) which motion the court overruled thereupon the said Charles R Anderson on the 29th day of February AD 1844 filed his motion in word & figures following to wit: (here insert said motion) which motion the court overruled to which judgment of the court the said Charles R Anderson by his this his bill of exceptions may be signed & sealed &