Nelly Lemon v. John H. Bayne. Petition for Freedom
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
Nelly Lemon for herself & children
John H. Bayne
Peto for freedom
Filed 15th Feby 1832.