To the Honorable William C Carr Judge of the Circuit Court of St Louis County
Your petitioners Anson and Michael persons of color by their next
friend William Clark represent that their mother Matilda is a free woman
so adjudged by the courts of Missouri under the territorial government,
that about 13 years since after her right to freedom was established she went to
reside in the state of Illinois that your petitioners were born after the said
Matilda became free and have continued to reside from thence forth in the
State of Illinois with their mother free and at liberty until this day when they
were claimed as slaves by one Elijah Mitchel and others and forcibly taken from
the said state of Illinois and brought to the county of St Louis where they are now
detained as slaves by the said Elijah Mitchel and Russel