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some person or persons pretending to be the heirs of his father William Simmons may attempt to rob him of that liberty which the said Daniel (the only person who has any shew of title to his service) wishes him to enjoy being satisfied for the purchase money by the services already rendered, and which his father by his will has entitled him to. Your petitioner prays that his right to liberty may be declared by law that he may not be deprived of that right which constitutes the greatest blessing and that the wishes of his father may not be defeated And in as much as laws have been passed, which would render the stay of your petitioner in this state illegal, since the time at which he would have been free if not laboring in the service of the said Daniel for the price of his freedom unless it did appear that previous to their passage he possessed the right to freedom although justly deprived of the enjoyment at that time, your petitioner further prays, that the laws which would prevent his residence within this state may not be permitted to have an operation which would be ex post facts as affecting his right previously existing, and that he may be permitted to remain within his native state. For the verity of the facts mentioned in this petition your petitioner begs leave respectfully to refer the documents accompanying it. And as in duty bound he will ever pray