In the District Court of the Third Judicial District holding terms at Port Townsend in Jefferson County Washington Territory
In the matter of the Application of Mrs Lee Sing Wot for a Writ of Habeas Corpus } Petition for Writ
To the Hon C.H. Hanford Chief Justice of Washington Territory and Judge of the above entitled court the petition of Mrs Lee Sing Wot respectfully shows
That she the said Mrs Lee Sing Wot is unlawfully imprisoned, detained, confined, and restrained of her liberty by Charles M. Bradshaus, Collector of Customs for the District of Puget Sound in Washington and Oregon at Port Townsend in the County of Jefferson and Territory of Washington.
That said Charles M. Bradshaus, Collector as aforesaid has and does illegally imprison, detain, and confine your petitioner in the Custom House at Port Townsend aforesaid, awaiting a steamer of conveyance to cause your petitioner to be transported out of the United States of America and into British Columbia, alleging that your petitioner being a Chinese woman is not entitled to land or remain in the United States of America
That said imprisonment, detention, restrain, and confinement are illegal in this wit
That your petitioner is a Chinese woman and is the legal wife of Lee Sing Wot who is a merchant member of the firm of Zuong Lin Hing & Co, 733
Commercial Street San Francisco California and your petitioner was on her way to join her husband at San Francisco California, when she was arrested imprisoned and detained by said Charles M. Bradshaus Collector as aforesaid and is now so as aforesaid arrested, imprisoned, and detained the certificate duly executed by the Chinese Government showing that she is entitled by the Chinese Government showing that she is entitled to enter and remain in the United States which certificate is hereto attached, made part thereof marked exhibit "A"
Wherefore your petitioner prays that a writ of Habeas Corpus may be granted directed to the said Charles M. Bradshaus Collector as aforesaid, commanding him to have the body of said Mrs Lee Sing Wot before your Honor at a time and place therein to be specified, to do and receive what shall then and there be considered by your Honor, concerning said Mrs Lee Sing Wot, together with the time and cause of her detention, and said writ, and that she the said Mrs Lee Sing Wot may be restored to her liberty.
Mrs Lee Sing Wot by Morris B. Sachs her Atty
