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Echols, Peregrine v. Leftwich, Exrs. of Thomas: Chancery Cause, Lynchburg City (Part 1 of 5)

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To the Honorable Creed Taylor Judge of the Chancery District Court holden at Lynchburg Your orator Peregrine Eckhols [Echols] respectfully represents that some time in the year [blank] a certain James Flannigan was indebted to a certain William Ward in the sum of £40 - and the said Flannigan being at that time unable without sacrificing the little property he possessed to discharge the said debt yet being at all times wishing and desiring (however unable) to satisfy all just demands against him, for the purpose of paying the aforesaid debt due to Ward some time in the [blank] entered into a verbal agreement with a certain Thomas Leftwich in substance as follows: the said Flannigan was the owner of a negro slave named Betty & commonly called Betty Flannigan to whom he was much attached yet being sincerely disposed to discharge the aforesaid debt he agreed to place the said slave in the possession of the said Thomas Leftwich as an indemnity and security in consideration of the said Thomas Leftwich having voluntarily undertaken to pay sd Ward the debt due as above mentioned. That in pursuance of his undertaking the said Leftwich did pay to Ward the aforesaid debt, but did not at the same time take into his possession the said slave Betty on the contrary he permitted her to remain in the peaceable possession of the said James Flannagan untill about the year [blank] when disregarding the terms of his agreement he unlawfully & iniquitously (took the said slave and her three children [blank] which had been born subsequently to the above mentioned agreement and while the said slave remained in the possession of the said James Flannigan) from the possession of the said Flannigan and corruptly sold them to a certain Joseph Echols for the sum of $[blank]. Your orator further expressly avers that when the aforesaid agreement was entered into between the said Flannigan & Leftwich it was fully understood between them that said Leftwich was only to take possession of the said slave as a pledge to secure the reimbursement of the money with interest which had been advanced by the said Leftwich to Ward as hereinbefore set forth & that it was one of the conditions of the said agreement that the said Flannigan should at any time during his life be permitted to redeem the said slave and