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Tennessee and has been afflicted with fits so that he seems to have lost care for his said children She further states that the said Stephen Osburn had the children his heirs so that the James Washington and Lucinda could not be equally divided between them in the manner the law has prove in their case and that Mr Robison one of sd. Stephen Osburns heirs pltff. against all the other heirs defts. to take the advantage of your oratrix combining together have brought suit in your worshipful court to have the said James Washington and Lucinda sold and divided and have not made the said children the said Austin Day nor your oratrix in any manner defts. and At your last April term a conditional decree has passed without opposition to have the said two children sold She further states that an issue is directed by the chancelor to try the validity of the said Stephen Osburns sd. will which issue your oratrix believes will be decided next September in her favour, and if so she believes by the assistance of some of her friends and of some debts due to her she will be able should her said children be sold to purchase them herself and so prevent them and their ofspring from being forever enslaved but if they are sold under the present decree that awful consequence must follow All which actings & c.
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- The prayer of your Oratrix is that the same persons both pltf. and defenadants [defendants] in said suit and all the parties to the said Deed of Trust may be made Defendants to this bill and that they may be compeled [compelled] to answer the same fully as if again set out by way of interrogations that the said conditional Decree to sell the said children may be set aside that the Trustee under the said Deed of Trust be restrained from executing the same that your oratrix may be permitted as their guardian to defend them against the said bill and said Deed for the sale of them, and to prove while the witnesses are living and before the said children are removed to ports [illegible] their right to freedom. And for that person an issue may be directed to try the fact of their right to freedom under the said contract and that your Oratrix may be permitted to defend their right without being subject to costs And that such other and further relief may be extended to your oratrix and her said children as to Equity belongs and is suited to her case May it please your worships to grant &c
- Your Oratrix further states that Isaaac [Isaac] Richmond, who intermarried with one of the said Stephen Osborns daughters, in claiming not only the share of his said wife in your in your Oratrix's said children but the share of five others of the Heirs and distributees [distributes] of the said Stephen by purchase from them. And has executed a Deed of trust for the six shares thus claimed by him, to one John S. Martin as Trustee to secure one Jonathan Osborne against a responsibility which he incurred to Benjamin Estill, Esqr. by becoming