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 assert
that their mother Matilda was 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 their
birth in the state of Illinois with
their mother until this day free and
at liberty will 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 Sd
Elijah Mitchel Mitchel and Russel
who are about to remove them by force
beyond the jurisdiction of this court
and state. Your petitioners pray
that they may be authorized to sue
to establish their right to freedom and
that your honor may open a writ of
habeas corpus to prevent[?] them being[?]
conveyed[?] from the said jurisdiction and
they will every[?] pray.
Anson & Michael by William Clark their[?] next friend
May 2, 1832
