Barbara: Freedom Suit, Scott County
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owes half of the value of said slaves; and that [Isaac] Richmond who married on of this deft's. sister, was the owner, by purchase, try right of his wife, of the other half. That [illegible] year ago, said Richmond because indebted to Benjamin Esthill, [Esgr.] in this sum of $200, and this debt because said Richmond's [illegible] for the [lay] meet thereof; that said Richmond to receive their debt to execute a deed of trust conveying this interest, one half or aforesaid, of those slaves, to John S Martin a trustee for the benefit of their debt. This debt has lately been compelled to pay the said $200 an such security and will be obliged to pay about $50 more of interest and costs. And this debt and the [illegible] would have made a sale of said slaves permanent to the conditions of said trust deed, long time ago, but for the restraining order of this court. So that this debt, is the only person immediately interested in this said two slaves. This debt denies that if the allegations of the just bill were wholly true, that the let thou any right to restrain the said sale of said slaves, or to recover their freedom, or to recover the said slaves in any other way. He however extremely denied it was serial allegation, of the bill, not admitted in this one lever, and calls whose the let for proof thereof. He denies all right of the bet to restrain this rent, by the law of this Common we all, and pray that the said restraining order be [dissolved], and that he be recruited to make a sale of the said slaves, according to his legal and equitable right. And this debt having this fully answered the said bill or so much thereof, as he is advised, is material for him to answer, may to be here dismissed with his cost & c.