Kitty v. Samuel McPherson. Petition for Freedom
To the Hon the Judges of the Circuit Court of the District of Columbia for Washington County,
Humbly complaining sheweth unto your Honours, your Petitioner negro Kitty or Kate, that she is entitled to her freedom, that nevertheless she has been seized & is now falsely imprisoned & held in slavery, by a certain Samuel McPherson, or some one claiming through him, as your petitioner is informed, she has been sold to a foriegn negro trader, & is about to be removed from the jurisdiction of your Honourable Court. That your petitioner claims her freedom under the last will & testament of a certain Miss Mary Brooke, late of the County & District aforesaid, a copy of which is herewith filed, as to your Honours will appear from reference thereto.
Your petitioner being without relief except from your Honourable court prays that her rights may be enquired into, & that your Honours would forth with grant your most gracious writ of injunction directed to said Samuel McPherson & all others claiming through or by him or under him & all others whatsoever forbidding & restraining them from holding your petitioner in bondage & especially from removing your petitioner from the Jurisdiction of your honorable court, till her rights can be inquired into & your petitioner prays ever process will afford her such other further relief as to your Honours may seem meet & proper, & thus she will ever pray respcly &c
Thos Turner
Sol: and atty for Petitr
District of Columbia,
Washington County Ss
On this 30th day of April 1831 personally appears John D. Scott before me the subscriber one of the justices of the peace in & for the county & District aforsaid & makes oath on the Holy Evangels of Almighty God that the matter & things set forth in the foregoing petition are true to the best of his knowledge & belief
Sworn to before
Edmd Brooke
Ordered by the Court that the injunction in this cause be continued until the further order of this court under the said that Samuel McPherson give bond to the United States with surety by the approved by this [illegible] of its Judges bounty in the sum of $600 conditioned that he due will not sell or remove or cause or permit the within mentioned Petitioner Kitty to be sold out of the District of Columbia or removed therefrom.
Test
W. Brent Ck
June 22 1831
This will be brought by the [illegible] and is the [illegible] Mr. Brent will forthwith issue the subpa & writ of injunction. As the woman is now in jail & may be attempted to be removed. Mr Boone obligd by apprising the jailer of the injunction & require him to return her [illegible] into the[?] hands the Marshall. For fear the [illegible] in the copy of the [illegible] I [illegible] it [illegible]
Thos. Turner
Col Brent
Clk Apl 30. 1831
156 371
Appear
May 1831
Negro Woman Kitty or Kate
vs.
Samuel McPherson
Petn. for Freedom
filed 30th April 1831
On filing this Petition let Injunction issue as prayd
J S Morsell
30 Apl 1831
Wm Brent Esq
clk Cty Washg
Col. Brent,
Please file this issue subpoena & writ of injunction &c & give [illegible]
Thos. Turner for Pr
Apl 30th 1831.
