erk.
Territory of Oregon, )
) ss.
County of Polk )
To the Honorable Cyrus Olney, Associate Justice of the
Supreme Court of Oregon Territory.
The petition of Robin Holmes of said County in the aforesaid Territory, represents, that he is the father of Mary Jane Holmes, James Holmes, and Roxanna Holmes, minors, who are under the age of twenty one years, to wit, Mary Jane being about the age of eleven years, James about the age of nine years, and Roxanna about the age of seven years; that said minors are now imprisoned and restrained of their liberties in the county of Polk and Territory aforesaid, by one Nathaniel Ford, or by some other person, or persons, under the command and controll and by the authority of the said Nathaniel Ford, against the will and without the consent of the said Mary Jane, James, and Roxanna Holmes, as well as of your petitioner, that the restraint held over said minors by the said Nathaniel Ford is illegal it being without the authority of law or the process of any court. That your petitioner believes said minors are imprisoned and restrained of their liberties under the pretence that slavery is tolerated by the laws of this Territory, and that they the said Mary Jane, James and Roxanna are the slaves of the said Nathaniel Ford. That the said Nathaniel Ford has for a long series of years held said minors under a most galling and degrading servitude, has, and still claims them as his chatties, and that your petitioner has been informed and verrily believes that the said Nathaniel Ford intends ere long to depart this Territory, and your petitioner has reason to believe that it is the intention of the said Nathaniel Forcl to take along with him the said minors for the purpose of selling them into perpetual slavery in counties beyond the jurisdiction of the Courts of this Territory thereby forever debarring your petitioner from the pleasure of their society, and the benefit to be derived from their services, which rightfully belong to him. That your petitioner has often made application to the said Nathaniel Ford to have the said Mary Jane, James and Roxanna given up to him, which the said Nathaniel Ford has as often refused to do. Wherefore your petitioner prays that a writ of Habeas Corpus may be issued to have the bodies
