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Lemmon: Freedom Suit, Augusta County

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The seperate [separate] answer of John Reynolds to the Bill of complaint of Lemmon a black man late the property of Joseph Holmes deceased, exhibited against the said John Reynolds and others in the Honourable the Superior Court of Chancery holden for the Staunton district. This defendant saving and reserving to himself now and at all times hereafter all and all manner of benefit of advantage and exception to the complainents [complainant's] said bill of complaint, for answer thereunto or unto so much thereof as materially conceives this defendant to make answer unto he answereth and saith: That it is true as stated in the said complainants Bill that the said Joseph Holmes did make and publish his Will, and in and by the same bequeathed the said Lemmon his freedom after the death of the said Joseph Holmes and also his Sorrel Horse, with a saddle and bridle and Ten dollars that the said Will was lost, and afterwards was reduced to writing and illegally as this defendant conceives admitted to record in the County Court of Kanawha; That this defendant as the administrator of Joseph Holmes deceased, did retain the said plaintiff Lemmon in his possession, because he did not believe that the said Will furnished him with Legal and proper grounds, upon which to rest his claims to emancipation and therefore permitted Suit to be instituted against him which said Suit progressed and terminated in manner as stated by