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

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were to conjecture in what manner the said Parsons Bradley acquired the said slaves or at least the original stock they would be inclined to say in order in some manner to reconcile the said William Ragsdales affidavit with his inventory that he the said William Ragsdale conveyed the negroes to the said Parsons Bradley on some consideration or other. That these defendants however know nothing of the true source of title nor as they are advised are they bound further to enquire [inquire]. And these defendants farther answering say that the said Parsons Bradley died intestate some time in or about the year 1768, leaving the said David Bradley his only child and the said Mary Bradley herself died in the year 1790. While the said Mary Bradley and the said David Bradley her son were living together that the said slaves of Course as these defendants are advised descended to the said David Bradley. And these defendants farther answering say that the Judgement obtained by them against the said David Bradley and Elizabeth his wife at the Suffolk District Court on the 24th day of May 1804 and the execution awarded thereon stands now in full force unreversed and therefore they claim the benefit thereof in the same manner as if it were more specially pleaded that it was obtained on Confession. That these defendants are therefore not bound in this place and against the present plaintiff to enter into any discussion of the original merits of the case. That if however such a discussion should be required these defendants beg leave to state the case as follows; the said Elizabeth was before her inter marriage with the said David Bradley the widow of one John Harrison who died in August 1790 and whose executrix she was. his estate was shortly afterward sold on a credit of nine or twelve months it cannot be supposed that she could well commit any considerable