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

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carry them away, and reduce them to slavery and cary them out of the Jurisdiction of the Court and probably to sell them as slaves in a distant country, so that they would not be able to establish their rights to freedom under the said, will; Your Oratrix will further state that the said Richmond on a former occasion took possession of her and her children, and was attempting to carry them off, but he was prevented from effecting his purposes by the interposiition of others who brought your Oratrix and children back within the jurisdiction of this Court where she has remained in peace until this time, waiting the event of the suit aforesaid. The said Richmond has on this day attempted violently to take your Oratrix and her children into possession, and to carry them off to distant parts of the country, and on her refusing to go with him has treated her with great violence. Under these circumstances, your Oratrix is advised that her only relief and most proper mode proceeding is to seek the equitable protection of this Court, and to pray that they will restrain the said Richmond, his Co-Defdts, or any others acting under their authority for interfering with herself and her children, and that they may be put into the Custody and protection of the Shff of this County till her right to freedom shall be ascertained and the further Order of this Court. Your Oratrix will further [suggest?] that she has reasons to fear that should the said Richmond or his Co-Defts and particulary the former be permitted to take possession of her or her children that he will treat them with great cruelty in consequence of their insisting on their rights to freedom; she further states that the said Richmond has repeatedly stated in the presence of respectable persons in Estilville, that he will not regard the order of any judicial power in favor of your Oratrix and children, and that he will in defiance of any such take possession and defend it at the risk of his blood and life: The premises considered, and in as much as by the Death of said Comfort Osborne, your Oratix situation has been somewhat changed, and must remain some what doubtful till the Suit in the high Court of Chancery shall be determined, she prays that the order heretofore entered in the cause committing her and children to the Shff, shall be enlarged so as to afford her further protection as she has already prayed, that the said Isaac Richmond and the other Co-Defts in the original bill if necessary made Defts to this bill and answer the premises and that the Court will grant such other and further relief as may be necessary in her case &c and that a writ of Subpena may be issued Mayo