Brooks, Michael : Freedom Suit, Richmond City

To the worshipful Court of Husting of the City of Rich.d The petition of Michael Brooks a man of colour states to your Worships that he is now detained in slavery, by John M Smith of the City of Richmond that he has been from infancy entitled to his freedom that his mother was free by birth and has been deprived of that [?]ing by the iniquity of those to whom she was intrusted and who had the control and posession of her during her childhood. That the facts which he believes he can prove are that his mother was placed to nurse in the family of a person of the name of David Via in the County of Louisa, that said David, being indebted to his other brother Gideon Via pledged her to him as security for the payment of the debt, that she was removed to the County of Hanover with said Gideon this family who emigrated to that County where she was probably forgotten for a length of time that when Gideon Via died, she & her children of whom she has had eight, were distributed among said Gideon's children, that his mother fell to the share of --Via now living near the meadow bridges of Hanover & that he became to the posession of Via who sold him to [?] Fulcher who sold him to his present master said Jno M. Smith that since this period he as become reacquainted with his title to freedom and

should have been laid claim it of some time ago, but being ignorant knew not how to proceed; that he had reason to believe said Smith knew of his pretensions to his freedom, and being required by him to go up to distant part of the country and apprehending some unfair proceeding against him he made application for advice and now begs to be permitted to see in forma [?] and that a reasonable time he allowed him to satisfy the Court of this property of his being heard in this behalf - that [?] [?] he assigned him counsel -

I am of opinion that the fact above alleged [?] the free birth of the mother of the said Michael Brooks--being proved, the said Michael will be entitled to his freedom

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