To the hon: The Circuit Court of the District of Columbia sitting for the County of Alexandria.

Humbly complaining your Petitioner Winny, a Woman of Colour, shews unto your Honours, That she is illegally detained in slavery by a certain Alexander Moore of the Town of Alexandria, to whom she has been hired for a term of service by a certain Elizabeth Cox of the State of Virginia who claims your petitioner as her property, or by the authority of the said Elizabeth Cox. Your Petitioner further shews unto your Honors, That on or about the first day of February in the year 1813, your Petitioner then being a resident of the State of Virginia, was hired from thence by the said Elizabeth Cox, her mistress then being also a Resident of Virginia, or by her authority and consent, to a certain Walter Jones Jr. esq. then residing in the City of Washington in the District of Columbia, to serve the said Walter Jones Jr. for the term of Twelve Months thence ensuing and that in pursuance of the said hiring your Petitioner, was removed, immediately from the State of Virginia to the city of Washington aforesaid. When she was kept in the service of the said Walter Jones Jr. for a long space of time, towit, for the space of twelve months immediately ensuing her removal into the City of Washington from the State of Virginia as before stated. In consequence of which said hiring, removal, and detention in the City of Washington as aforesaid, your Petitioner is advised she has become entitled to freedom under the Act of the Assembly of Maryland. Your Petitioner submitting these parts to the consideration of your Honors, humbly prays to be allowed to sue in forma pauperis in your honorable Court for the recovery of her freedom. And your Petitioner as in duty bound will ever pray.

Winny

I have made inquiry respecting the truth of the matters set forth in the forgoing Petition for freedom, and an informed that the following facts will be proved by competent and credible testimony (viz). That Winny the petitioner, on or about the 1st day of February 1813 was hired by her mistress, then being a resident of the State of Virginia, only the consent and authority of her said Mistress, directly from the State of Virginia into the City of Washington in the District of Columbia, to Walter Jones Jr. of that city, in whose family she remained in the said City, with the knowledge and consent of her Mistress for Twelve Months and more. I am therefore of the opinion that the Petitioner is probably entitled to freedom.

J. D. Simms