Nelly Lemon v. John H. Bayne. Petition for Freedom
The petition of Nelly Lemon for herself and her infant children, Thomas, Lavinia, Betsey, Dennis and Amy, respectfully sets forth to your honors.
That she is a woman of color and entitled to her freedom, and also that her aforementioned five children are entitled to their freedom, that they are all now held in a state of slavery by one John H. Bayne contrary to law and your petitioner's just rights. Your Petitioners therefore prays your honors to grant her & her children such relief as she & they may be lawfully entitled to and such process of your honorable Court against the said John H Bayne as is usual in such cases to compel the attendance of the said John H Bayne in your Honorable Court to answer this petition, and to enter the usual security & recognizance not to remove your petitioner beyond the Jurisdiction of your honorable Court and is duty bound your petitioners will ever pray &c &c
Coxe & Smith
Nelly Lemon et al.
John H. Bayne
petition for freedom
Filed 19 March 1830.