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Abby: Freedom Suit, Petersburg City (Part 1 of 2)

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pray to be here dismissed with their reasonable cost in this behalf wrongfully sustained. Nansemond County to wit David Bradley and Elizabeth his wife maketh oath before me that the foregoing answers are true as far as they know and verily believe. Given under my hand this 23 rd day July 1804. Henry Harrison The joint and several answers of Andrew Woodley and Eliza his wife and Edward Winston and Woody his wife defendants to the bill of Complaint exhibitted [exhibited] against them and David Bradley and Eliza his wife in the Richmond Chancery District Court by Abby Sally Louisa John and Airy paupers Complainants. These defendants saving to themselves every benefit of exception to the imperfections of the said Bill for answer thereto say, that the said slaves Abby and Sally were not the absolute property of Mary Bradley at the time of her death nor at any time before except perhaps she may possibly have received dower therein as of the Estate of Parsons Bradley that a negro woman slave named Chloe was the [Aucertor?] [Auctioneer] from whom the plaintiff have descended. That on the 28th day of May in the year 1768 the said Chloe had but one child Abby, one of the plaintiffs who and her mother Chloe were then inventoried and appraised at the instance of the said Mary Bradley and William Ragsdale, Administrators of the said Parsons Bradley as his the said Parsons Bradley Estate, that after the death of the said Parsons Bradley and the date of the said inventory and appraisment [appraisement] the said Chloe had another female child named Sally who is the mother of the said Louisa Airy and John. That these defendants know not by what means the said Parsons Bradley acquired a Title to the said Chloe and Abby nor as they conceive need any other title be produced thereto, since the inventory aforesaid is the very act of the said William Ragsdale upon whose testimony the plaintiffs themselves rely that if the defendants