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Daniel: Freedom Suit, Northampton County (Part 1 of 3)

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remained free and liberty from the time of the pronouncing the said decree of the said Circuit Court on the 12th day of December 1851, until they were taken under the said execution, that the said Leah, Mary Jr, George Jr, Jimmy and Joe have never before sued for their freedom which had been detained in slavery by the said Polly Frost and her said husband the said William Wilson, from the deaths of the said Nancy White up to the time of the levy of said execution upon them as above stated.

Your orators and oratrixes expressly charge that they were regularly and legally emancipated by the said Will of the Nancy White from the year 1849 and and are now entitled to their freedom. They further charge that there has been paid upon account of the claim or bond on which said suite of Pitts vs. White was instituted, and the said scire facias and execution upon the same sued out, the whole amount due upon the same, except about the sum of $200; together with some arrears of interest on the said sum of $200; and that the said William G. Pitts admr. de bonis non as aforesaid has often so declared, and that the said William G. Pitts admr as aforesaid has sued but the said execution for the whole amount of the ^]said original judgement with a fraudulent purpose in collusion with the said James H. White to defraud your complainants to make them slaves and to recover more than is due to him, and that the said James H. White, admr as aforesaid fraudulently and in collusion with the said William G. Pitts, admr. as aforesaid suffered the said award of executions to be entered against him, for a price agreed upon between them, or an understanding that some price would be paid; and your orators and oratrixes charge that the said James H. White admr. as aforesaid scire facias upon the plea of the statute of limitations in such cases made and provided. Your orators and oratrixes charge