Nelly Lemon v. John H. Bayne. Petition for Freedom

 

To the Honrble the Judges of the Circuit Court of the District of Columbia for the County of Washington

The petition of Nelly Lemon for herself and her infant children Thomas, Lavenia, Betsey, Dennis, Amy, Harriet, Kitty, respectfully sets forth to your Honors that she is a woman of color and entitled to her freedom and also that her aforementioned seven children are entitled to their freedom that they are all now held in a state of slavery by a John H Bayne contrary to law & your petitioners just rights. Your petitioner therefore prays you honors to grant her & her children such relief as she & they may be lawfully entitled to and such process of your Honbl court against the sd John H Bayne as is usual in such cases to compel the attendance of the said Bayne in your Honlb Court to answer this petition & to enter the usual security & recognizance not to remove your petitioners beyond the jurisdiction of your Honlb Court and as in duty bound your petitioner will ever &c

F. S. Key & BP Smith attys for Petitioners

 

60.

Nelly Lemon for herself & children
vs
John H. Bayne

Peto for freedom

Filed 15th Feby 1832.