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To his Honor John Brown Judge of the high court of Chancery holden at Staunton the answer of John Kelly to a Bill of Injunction exhibited against Philip Gaines and this respondent by Frederic Idle and for answer saith that he was assigned counsel by the Court of Grayson for the slave Hagar at the
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To his Honor John Brown Judge of the high court of Chancery holden at Staunton the answer of John Kelly to a Bill of Injunction exhibited against Philip Gaines and this respondent by Frederic Idle and for answer saith that he was assigned counsel by the Court of Grayson for the slave Hagar at the time that the petition was offered to the Court to direct a suit to be prosecuted for Hagar in forma pauperis against Philip Gaines for his freedom this respondent further states that there is not nor was any combination between Philip Gaines and this respondent for the freedom of the Slave Hagar nor did this respondent know of such a petition to be offered to the Court until the evening before as he recollect having answered the complainants bill or so far as he thinks it material prays the Injunction to be disolved [dissolved] and to be dismist [dismissed] with his costs.  
time that the petition was offered to the Court to direct a suit
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to be prosecuted for Hagar in forma pauperis against
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Grayson County to wit  
Philip Gaines for his freedom this respondent further states that  
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there is not nor was any combination between Philip Gaines
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This day came John Kelly before me William Ballard a Justice of the Peace for said County and deposed that the foregoing answer is true so far as relates to his own acting and doings and so far as relates to the acting and doings of others he
and this respondent for the freedom of the Slave Hagar  
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believes to be true Given under my hand this 29 day of October 1808         
nor did this respondent know of such a petition to be  
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offered to the Court until the evening before as he
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William Ballard
recollect having answered the complainants bill or so far  
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as he thinks it material prays the Injunction to be
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disolved and to be dismist with his costs.
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Grayson County to wit
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This day came John Kelly before me William Ballard a Justice
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of the Peace for said County and deposed that the foregoing
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answer is true so far as relates to his own actings and doings
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and so far as relates to the actings and doings of others he
+
believes to be true Given under my hand this 29 day of
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October 1808        William Ballard
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Latest revision as of 09:38, 26 September 2019

To his Honor John Brown Judge of the high court of Chancery holden at Staunton the answer of John Kelly to a Bill of Injunction exhibited against Philip Gaines and this respondent by Frederic Idle and for answer saith that he was assigned counsel by the Court of Grayson for the slave Hagar at the time that the petition was offered to the Court to direct a suit to be prosecuted for Hagar in forma pauperis against Philip Gaines for his freedom this respondent further states that there is not nor was any combination between Philip Gaines and this respondent for the freedom of the Slave Hagar nor did this respondent know of such a petition to be offered to the Court until the evening before as he recollect having answered the complainants bill or so far as he thinks it material prays the Injunction to be disolved [dissolved] and to be dismist [dismissed] with his costs.

Grayson County to wit

This day came John Kelly before me William Ballard a Justice of the Peace for said County and deposed that the foregoing answer is true so far as relates to his own acting and doings and so far as relates to the acting and doings of others he believes to be true Given under my hand this 29 day of October 1808

William Ballard