Daniel: Freedom Suit, Northampton County (Part 1 of 3)
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that even if they were liable to the said execution that there is now due on the same only about the sum of $200; and that their hires for a short time would pay that and; where they would surely be entitled to their freedom for tender considerations whereof, and was made as your orators and oratrixes are remediless in the premises except by the aid of a court of equity, may it please your honor to cause the said William G. Pitts admr de bonis non with the will annexed of Major Pitts deceased, James H. White admr debonis non of Obedience White decd, Charles I. D. West, William Wilson and Polly, his wife, formerly Polly Frost and John H. Winder, late Sheriff of Northampton County to be made parties defendant to this bill, and their full and perfect answers to make the same, and especially to answer whether or not the said Daniel, Mary Sr, Abram alias Abraham, and Leah, was in the possession of the said Nancy White at the time of her death, under her claim of title, and had been so in possession under such claim for several years? and whether or not the said George Sr. is the child of the said Mary Sr & born since the death of the said Nancy White? and whether or not the said George Jr, Mary Jr, Jimmy, and Joe are the children of the said Leah, and born since the death of the said Nancy White? and that the said William G. Pitts be required to answer whether or not all except about $200; with some arrears of interest; has been paid upon the bond or claim on which the said original judgement was made and said scire facias & execution on same were paid, and how much has been paid on the same, all he knows about any payments or credits on, and offsets against the same, and how much more remains due on the same? and whether there was any agreement between him and the said James H. White, and any price and how much to be paid by him to the said James H. White, or any, understanding between them, and what, that the said James H. White should suffer the said award of execution to be entered against him by default, or any other agreement between them and what was such agreement? and whether he or otherwise through has assigned away the said claim or original judgement, or award of execution on the said execution on the same to the said Charles I. D. West, or any other person, and what was the consideration of such transfer or assignment? and whether or no more than five (5) years had elapsed between the first qualification of an administration upon the estate of the said Obedience White and the revival of the original judgement in the said suit of Pitts vs. White, by the said scire facias? And the said Charles J. D. West be required especially to answer whether the bond or claim upon which the said original judgement was founded, or award of execution or execution on the same has been assigned or otherwise transferred to him, by said William G. Pitts or any one else, and what was the consideration of such transfer? and that the said execution do levied upon your orators and oratrixes may be stopped, stayed and suspended, and that the said John H. Winder late sheriff as aforesaid be injoined from selling your orators and oratrixes under said executions by your honor's writ of injunction, and the your honor may direct him to hire our your orators and oratrixes, and to hold the heirs of the same subject to the [future?] decree of this court, and that your orators may be allowed to sue for their freedom, and that many be declared to be free by the decree of their court, and that they may [have?] such other and further relief or equity and the circumstances of their case admit and acquire, and may subpoenas pro se.
Henry A. Wise & Aaron [illegible] Neale, Counsel for complts
Northampton County to wit. - Mary Sen, one of the complainants in the above Bill of complaint, having been first duly sworn, says that all other facts set forth in this above bill written her knowledge are true, and