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so lost but
so lostbut is fortunately armed with the most clear and satisfactory testimony to
Latest revision as of 16:14, 27 February 2020
so lost, but Your Orator is fortunately armed with the most clear and satisfactory testimony to establish the fact that the paper did exist both by the Evidence of those persons who saw it and also by the admissions of the said Stevens himself. He also charges that the said obligation is of full force, never having in any way been complied with on the part of said Stevens. Your Orator also states that on the [blank] day of [blank] 1851 he was again fortunately able and is still, to redeem the said slaves and accordingly he did on that day offer to pay the said Stevens the sum of $800 and demanded of him the said slaves, that for fear the said Stevens might require a legal tender he procured the sum of $800 in gold and offered it to him, that the said Stevens refused & still refuses to return the said slaves as he had undertaken to do, & Your Orator now here offers and tenders to pay the said sum of money and is ready to obey any interlocutory or other order Your Honor may make in regard to the said sum of money, Either to the said Stevens or into Court - and he prays that the said slaves be returned to him by said Stevens. Your Orator further states that he wishes to get the said slaves themselves. In tender consideration of the premises and as your orator is without remedy at law, Your Orator prays that the said John Stevens be made party Defendant to this Bill and that he answer its allegations on oath, & that you will decree that the said Stevens shall redeliver to him the said slaves upon the pay't of the said sum of $800, which sum Your Orator now here offers to pay to him the said Stevens, and to make every other order which may be necessary and proper to ensure to Your Orator his rights in regard to said slaves, & [q't?] any other and further relief whether specifically prayed for in this Bill or not which to Equity may seem meet. W. C. Flournoy H. H. Marshall [illegible] To the Honorable Judge of the Circuit Court of Prince Edward. (filed 18th Aug '52) Your Orator Edward Williams states to your Honor that at July Rules 1852 he filed his original Bill in this Court and since that time he has ascertained some facts in relation to the charges made in said Bill which he deems of importance to his case. And he therefore prays this may be regarded as his Amended Bill. The statement to which he refers is as follows. Since the filing of the said original Bill Your Orator has thought much upon the subject of this controversy and he remembered distinctly and now charges that the said Stevens promised Your Orator to state in writing on the Bill of Sale which Your Orator Executed to him for the said slaves that Your Orator should have the privilege of redeeming them at the sum of $800, as he undertook to do in the said Bond. Your Orator through his agent informed his Counsel of this fact and Your Orator's Counsel examined the record of a suit between G. W. Bradley & the said Stevens in the office of this Court and there found that the Bill of Sale referred to was therein filed. And on the back of the said Bill of Sale the following words in substance written & signed by the said Stevens are found. "The Negroes are redeemable