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Barbara: Freedom Suit, Scott County (Part 1 of 2)

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the bill; the said court overrules said motion, and refused to dissolve the injunction or to dismiss the bill, without any other proof than that then & now contained in the record, which refusal was erroneous, because the ptt's bill stood denied without proof, & upon the demurer as well or the answer the injunction ought to have been dissolved & the bill ought to have been then dismissed. For these and other errors to be assigned at bar, & which are apparent on the said record, and your petitioner, being advised, that an appeal is necessary to settle the principles of this cause, and to avoid expense and delay, he prays that your Honor will grant him an appeal from both the orders aforesaid, for the errors aforesaid, to the superior court of law & chancery holden in & for the county of Scott, and your petitioner will every pray &c. Jonathan Osborne I Samuel Logan counsel for the petitioner, Jonathan Osborne, do hereby certify that in my opinion, there is sufficient matter of error for reversing the decrees or orders in the foregoing petition mentioned. Given under my hand this 12th day of September 1831 Samuel Logan atto for Jonathan Osborne