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

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To the worshipfull the County Court of Scott in Chancery sitting. The answer of Isaac Richmond of the County of Franklin in the state of Tennessee, to the bill of complaint of Barbara a woman of colour for herself & her children in the worshipfull court against him and others. This respondent saving all exceptions to the said bill answering saith. That having purchased from the widow and heirs of Stephen Osborne decd all their interest in the slaves in the bill mentioned, and being himself an heir he was publickly removing to his residence in Tennessee with the complt only when he was forcibly robbed of her by William Robinson who sets up an unfounded claim to her under a pretended purchase from one of the heirs. To this purchase the admr William Kilgore being a party, in interest, consented, and likewise gave possession of the slaves to your Respdt and assented to their removal: but now it appears that the said Kilgore having sold his interest to your Orator without recourse, instead of Combining with this deft to deprive the complt of her rights appears to be combining with the Complt and her advisors to deprive this deft of his purchase and rights. This deft and others had previous to his purchase instituted suit in the Superior Court of Chancery at [Wythe?] to set aside the will under which complt claims her right to freedom, in which he confidently expects success, as the will was made under circumstances which render it null, and was fraudulently obtained as is confidently believed. This deft denies abusing the Complt, or that he was removing her to prevent her hereafter obtaining her freedom if she should be entitled thereto but he promised her and really intended to bring her back if the will was not set aside. As her claim is founded on a will, a copy of it could be easily obtained, and her rights (if any) under it as easily asserted in Tennessee as here. This deft objects to the juris diction of this worshipfull court, and denies its right to interfere in this case; and especially its right to take from his possession his property, after bond & security had been given to have the complt & her children forth coming, to answer the future order and decree of this court. If the Complt and her children are entitled to freedom under the will aforesaid (which