Daniel: Freedom Suit, Northampton County (Part 1 of 3)
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to believe nor does he believe that any such payment was ever made and he calls for full proof of the allegation nor does he know any thing of the supposed admissions by Wm. G. Pitts nor does he know if any were made when they were made, and he insists that he is no way bound by any such admissions if any were made by said Wm. G. Pitts. And this defendant further answering saith that he has no reason to doubt that the relationship of said slaves is correctly stated within said bill of complaint. And this defendant for further answer saith that he denies the right of the complainants allegation to inquire into the validity of the said judgement against the said Obedience White's admr. de bonis non, in this suit; and he denies that the said negroes ever were in the possession of the said Nancy White for the term of five years, o for any time longer than two or three years, if they were ever so long in her possession. And this defendant calls on the complainants for full proof of all matters charged in the said bill of complaint not herein expressly admitted to be true, and prays that the injunction awarded in this case may be dissolved, and his reasonable costs in this case most unjustly expended awarded to him etc. [Cls?] J. D. West [Muis?] W. Fisher p.d. Northampton County, Sct. This day Charles J. D. West whose name is above subscribed personally appeared before me and made oath, that the facts stated in the above answers so far as they are stated on his own knowledge are true, and so far as they are stated are the information of others that he believes them to be true. Given under my hand this the 8th day of October 1852. Wm. T. Nottingham J.P.A.C.