Abby: Freedom Suit, Petersburg City (Part 1 of 2)
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premises considered) to grant to your oratrixes the Commonwealths writ of subpoena and injunction commanding to. The injunction is awarded upon security being given in the penalty of two thousand dollars that the plaintiffs in case the injunction be dessolved [dissolved] shall be forthcoming July the 2nd 1804 -G Wythe Papers A.B.C.D. to be filed with the bill, Set the securities sufficience [sufficient] be verified by affidavit to be returned to the Chancery Office. G Wythe To the foregoing bill the defendants appeared by council and put in the following answers to wit. The answer of David Bradley and Elizabeth his wife defendants to the bill of complaint of Abby, Sally, , , ,Louisa, John and Airy negroes and paupers, complainants exhibibetted [exhibited] against these defendants and Andrew Woodley and Elizabeth his wife and Edward Winston and Woody his wife in the Honble. the District Court Richmond. These defendants saving and reserving not themselves all manner of exception to the uncertainties and imperfections in the said complainants said Bill of Complaint contained for answer thereto or to so much thereof as these defendants are advised is material for them to make answer unto that they answering say. This defendant David saith that Abby and Sally who were reputed to be the children of Chloe were were in the possession if Mary Bradley for a number of years and so continued to the time of her decease and as this defendant resided with the said Mary they then came to his possession but whether they were the absolute property of the said Mary Bradley or not this defendant doth not know. This defendant continued the possession of the said slaves will some time in the year 1792. When he by a deed duly executed and and recorded in the County Court of Isle of Wight did liberate them from which time they and their increase have enjoyed their freedom (except Louisa). This defendant does not recollect ever to have heard his mother the said Mary express any wish to manumit the said slaves, but after her decease some of the said Mary Bradley's children did consider themselves interested in them as this defendant understood but none of the children that were then living made any objection to his setting them free although they had knowledge that such was his intention. It is admitted that Louisa Airy and John are the children of Sally as they have stated. As also that the judgement spoken in the bill was obtained in the District Court of Suffolk. This defendant knows nothing of the execution and the progress made upon it as to the slaves only from hearsay but suppose it true as the complainants have alleged having understood it from Woodley one of the plaintiffs in the action at law. This defendant Elizabeth is an entire stranger to all the circumstances as to the said negroes. She heard before she intermarried with the Defendant David that he was in possession of such slaves but he informed her that he intended to liberate them. The defendants deny all manner of unlawful combination confederacy to in and by the Complainants bill charged against them, without that, that there is any other matter or thing in the Complainants said bill of complaint, contained material or effectual for the the defendants to make answer unto and not herein and hereby sufficiently answered unto confessed or avoided traversed or denyed [denied] is true to the knowledge and belief of these defendants all which matters and things these defendants are ready to air or as this Honble. Court shall [accuse?] and humbly