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Rachel & Rachel, Jr.: Petition, Northumberland County

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one yellow silk bonnet, one pair of blue yarn Mitts, one silver plated buckle, one trunk cover'd with black leather, one chest one pair of stays & one red spotted silk handkerchief the wearing & body cloaths of your Oratrix & the said Rachell her child with their bedding with the said Trunk & chest to contain & preserve them. That your Oratrix having for a short space of time left the said House on her necessary business he the said Zachariah Barr against every rule of Justice equity & good conscience possess'd himself of the aforesaid wearing cloaths & other things of your Oratrix And your Oratrix sheweth that she hath often in the most friendly manner applied to the said Zachariah Barr to deliver up to her the aforesaid wearing cloaths & the articles herein before ascribed which your Oratrix hoped he would do more especially as he had made oath duly to perform the Will & Codicil of the said John Barr But now so it is May it please your Worship that the said Zachariah Barr regardless of Equity & good concience regardless of the Dying request of a tender & boundiful Brother to whom he owes his whole Estate nay regardless of the most Solemn Oath of him the said Zachariah Barr & denying to his said Brother as far as lay in his power the priviledge of Disposing of his estate but intending to defraud & oppress your Oratrix (just freed from Slavery and bondage) and cast her out naked upon the world absolutely refusing to deliver up to your Oratrix her aforesaid wearing apparell Bedding trunk & chest and that under the most unjust feigned & false pretences that as he is Administrator of the said John Barrs Estate & must perform his will & thereby is accountable to his Sister Ann Hay who lives in & is a Native of that part of Great Britain called Scotland, & his other Sister Ann Eaton of the County aforesaid tho' your Oratrix charges that no woman in Scotland would dress or enrich herself with the wearing Cloaths of a black woman who must go naked for want of them and as for the said Ann Eaton your Oratrix positively charges that she has often declared to the said Zachariah Barr that she would give up any right she may have in the said apparel & other things to your Oratrix in consideration whereof & for that your Oratrix is only [illegible] in Equity where fraud & matters Testamentory are only relievable To these and therefore that the said Zachariah Barr may upon his Corporal oath true & perfect answer make to all & singular the promisses and that the said Zacharaih Barr may be compelled by the Judgment & desires of your Worship to deliver up to your Oratrix all the before mentioned wearing apparel Bed Blankets Trunk & Chest May it please your Worship to grant unto your Oratrix aforesaid [illegible] maners to compel the said Zacharaich Barr to appear before you or some other Justice of the peace for the said County to Answer the above complaint.

And your Oratrix shall pray &c