Alice: Freedom Suit, Arlington County
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past resided with said Edeler, and has of late commonly passed as his wife - but by what authority, if any this sale was made is not known to your Oratrix. But she avers that at and before the time she was sold to said Peter Mortey, that she distinctly and repeatedly informed him of her claim to freedom - but notwithstanding this he persevered in making the purchase and has removed your Oratrix from Washington to this place, being so far on the way to the southern or western county to which she is about to be carried. All which actings and doings are contrary to equity and good conscience & tend to the manifest injury of your Oratrix. In tender consideration hereof and forasmuch as she is without remedy according to the strict rules of the common law. To the end therefore has the said defendants may time and perfect answer make to all and singular the [illegible] & things stated in the forgoing bill as if they were herein again set down & they thereunto particularly interrogated. And more especially the said Samuel Edelen may set forth and declare whether he did not give to your oratrix a paper as before stated and afterwards permit her to go at large without interruption or claim on his part. Did he sell your Oratrix, & if so, what endevered him to change his mind, after your Oratrix had so long been at large as a free person. And that the said Mortey may say whether he was not informed when he bought your Oratrix that she had a claim to her freedom. Had he heard nothing of it. & what did he hear about her claim. And that such other and further relief may be granted her as may be consistent with equity & good conscience, may it please your honors to grant her the United States most gracious writ of purpose etc.
District of Columbia Alexandria County } to wit Personally appeared Alice a Mulatto woman complainant in the forgoing bill before the subscriber a justice of the peace for the County aforesaid & made oath that the matters & things stated in the forgoing bill are as far as stated upon her own knowledge, true - & so far as upon the information of others she believes to be true. And she further states that the papers given to her by the said Saml Edelen as her free papers and which she was informed & verily believes to have a full & sufficient deed of Emancipation, have been by accident lost by her - & she is therefore now unable to produce the same. Given under my hand [8th?] day of January 182[1?] Adam Lyney