The petition of Suzette alias Judith Bequette alias Suzette Merry aged about twenty five years in behalf of herself and her children. John aged about eight years old, Angelique aged about two years, and Edmund aged about two months, humbly represents to this honorable Court, that she was born in the town of Ste. Genevieve in the State of Missouri in the family of Nicholas Beauvais, who held and claimed her as a slave from the time of her birth until his death, which happened sometime in the year eighteen hundred and fourteen or fifteen , when upon the division of the property of said Beauvais among the heirs of said deceased she fell to the lot of Julie Jarrot , the daughter of said Beauvais , who had intermarried with Nicholas Jarrot of the town of Cahokia in the State of Illinois . That said Nicholas as soon as he had attained possession of your petitioner conveyed her to the town of Cahokia in the State of Illinois , the residence of said Jarrot , That your petitioner remained sometime with said Jarrot , who transferred and sold your petitioner to one McCracken the son -in-law of said Jarrot by whom she was sold to one Louis Pincinneau who sold her to John Reynolds , who now holds and detains or pretends to claim and hold your petitioner as a slave, your petitioner further represents that she has been held and detained as a slave in Illinois , ever since she was first taken there by Jarrot first by said Jarrot then by McCracken , afterwords by Pincinneau & now by said John Reynolds .

Your petitioner is advised and believes that neither she nor her children, who were all, born since your petitioner was taken to the state of Illinois , can legally be held in slavery, She therefore humbly prays this honorable Court permit her to institute suits for herself and children to recover their freedom and that she and her said children may sue as poor persons to establish their freedom aforesaid and that this honorable Court would assign them Counsel and your petitioners will ever pray State Jos Charless Jr.

Joseph Charless Jr . presents the petition of Judith Bequette in behalf of herself and her children praying that they may be permitted to institute suit against John Reynolds to establish their right to freedom and that they may be permitted to sue as poor persons thereupon the court permits the said Judith Bequette and her said children to wit John, Angelique, and Edmund to sue as aforesaid and direct that an action of assault and Battery and false imprisonment be commenced against the said John Reynolds in the name of the said Judith Bequette and in the name of the said John , Angelique and Edmund by their next friend and assign Joseph Charlesd Jr. Esquire as the counsel and it is ordered by the Court that the said defendant permit the said Judith Bequette , John , Angelique and Edmund to have a reasonable liberty of attending her counsel and the court when the occasion may require it and that the said Judith , John , Angelique and Edmund the Plaintiffs shall not be taken or removed out of the Jurisdiction of this Court and that they shall not be subject to any severity of treatment on account of her said application for freedom

Suzette alias Judith a free woman of colour who is permitted by the Court to sue by her next friend, as a poor persons by Charless her attorney assigned as counsel by the Court Complains of John Reynolds of a plea of Trespass , for that the said defendant heretofore to wit on the first day of January eighteen hundred and twenty eight, with force and arms at the city of St. Louis , unlawfully an assault did make upon the body of said Suzette alias Judith , and then and there did beat bruise and ill treat her, said Suzette , and then and there imprisoned her said Suzette , and kept and detained her in prison, without any reasonable or probable cause whatsoever against the will of said Suzette and has ever since kept and detained her said Suzette in prison, and still keeps and detains her in prison without any reasonable or probable cause, whatsoever con- trary to the laws of this state. And the said defendant avers that before and at the time of the committing of the said several grievances she was and still is a free person and that the said defendant holds and detains her in slavery and the said defendant other wrongs then and there did to her said to her said Suzette against the, peace and dignity of the state. Wherefore the said Suzette says she is injured, by the said defendant, and has sustained damaged to the amount of six Hundred dollars and therefore she sues. Charless Jr. atty for pltff

We command you to summon John Reynolds that he be and appear before the judge of our circuit count at the next term thereof to be held at the city of St. Louis within and for the County of St. Louis on the fourth monday of July next. Then and there to answer unto Suzette alias Judith of a plea of Trespass wherefore the said plaintiff says she is injured by the said defendant and has sustained damages to the amount of six hundred dollars and have you then there this writ