O Say Can You See

On a Petition for leave to sue for the recovery of her freedom in forma pauperis

Having been assigned by the Court as Counsel for the Petitioner to prosecute her claim aforesaid. And to make a Statement of the facts of the case from which her claim to her freedom arises. the subscriber begs leave to state to the court, that it appears from the Affidavit of John Smith attached to the Petition in this case filed. that the said Benjamin D Patterson has for more than six years past been an Inhabitant of the Town of Alexandria. that after he had continued his residence in the said Town that is to say about three years ago the Petitioner was imported into the Town of Alexandria from the State of Maryland by and with the consent of the said Benjamin D Patterson and of his father to whom she formerly belonged. that the said girl was given to the said Benajmin by his said father. and that she has continued to reside within the said Town of Alexandria since the time of the said gift and for more than twelve   months. It does not appear from an accurate Inquiry which has been made in the clerks office of this county or from any other evidence that the said Benjamin D Patterson or any other person has complied with the requisitions of the Act of Assembly by taking the oath prescribed upon importation of slaves.

On the facts above stated the subscriber has no difficulty in stating his opinion that the petitioner is entitled to her freedom and should be permitted to sue for the recovery of it in forma pauperis.

R. I. Taylor

Decr. 27 1809