Abby: Freedom Suit, Petersburg City (Part 1 of 2)
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anno domini one thousand eight hundred and four[.] William Ragsdale Prince Geo. County Sct. Sworn to before me the 8th of September anno domini 1804. Isaac Hall Suffolk September 10th 1804 The affidavit of John Garey taken at the house of John McCowling by consent of both parties to be used as evidence in a suit now depending in the high Court of Chancery in the District of Richmond wherein Abby & al paupers and plaintiffs against Andrew Woodley and etc Defendants. This deponant being first sworn deposes and says that he lived in about eight miles of Parsons Bradley at the time of his death and that after his death the widow Mary Bradley moved down near to this deponents. That he was well acquainted with Mary Bradley and her two sons John and David that there was several negroes which this deponent always understood was the property of Parsons Bradley decd and was only held and hired out by Mary Bradley as the widow of said Bradley, that John the son was a lunatic and died before his mother and this deponant always understood that David Bradley was the whole and sole heir to the said negroes which his mother so held after her death and this deponant was confirmed in this opinion when David Bradley came of age to act for himself from his knowledge David Bradley sold three of the said negroes to Michael Heathcote and others in the town of Petersburg and that after the death of Mary Bradley her son took possession of the balance of the negroes that he had not sold and that after keeping them some time in his possession he emancipated them as this deponent has
understood and further this deponent sayeth not. John Garey this day John Garey appeared before me a Justice of the peace for the County of Nansemond and made oath that the allegations contained in the above affidavit are true to the best of knowledge and belief. Given under my hand and seal this 10th day of September 1804. John C Cohoon (Seal) (21) The affidavit of Richard Yarbrough taken to be read as evidence in a suit in Chancery now depending in the Honble [Honorable] the District Court of Richmond wherein Abby and others paupers are Complainants and Andrew Woodley and others are defendants. The said Yarbrough saith that David Bradley in the month of May last informed him that he had several years before perhaps twelve or fourteen emancipated several slaves that one of them a female by the deed was to be liberated when she arrived to the age of twenty one and between the time of the execution of the deed and the period at which the said female was to be free she had a female child which was called Louisa, that he conceived that the said Louisa was his property and that he had made sale of her, that Andrew Woodley the defendant told him as soon as he understood it which was the day following that he had no right to the said Louisa and that he would persecute him for having so done, upon which the said David went after the purchaser paid him his money and took the girl back. The said David still insisted that Louisa was his property. And altho' he would deliver the said Andrew the said Girl in consequence of an order