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James Duggar v. John Baird, Jr.: Chancery Cause, Petersburg City

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To the Worshipful the Mayor & Alderman of the town of Petersburg in Chancery sitting: Humbly complaining sheweth to your worships your orator James Duggar that about the middle of the month of January in the year 1787, your orator hired a negro boy named Edward, from Mrs. Elizabeth Shackleford for the sum of Six pounds, that when your orator hired the said boy, he was nearly naked, and therefore his mistress agreed that if your orator would immediately clothe him, the price of such clothing should be deducted from the sum to be paid for his hire. That your orator in consequence of the said agreement forthwith furnished the said boy with clothing to the value of two pounds twelve shillings, & four pence half penny. That while the said boy lived with your orator, his mistress at two different times, obtained from your orator cash & other articles to the amount & value of one pound & seven pence half penny, for which she never made any compensation - orders for which articles in the handwriting of the said Letitia Shackleford are hereto annexed as part of this bill. That while the said boy resided with your orator he caught the small pox, in the cure of which disease your orator, from the expense of nursing & maintenance, was compelled to pay the sum of one pound sixteen shillings; so that your orator was entitled to a discount against the said hire of five pounds nine shillings; as will more fully appear from an account exhibiting the above articles of charge, which is hereto annexed & prayed to be taken as part of this Bill. Your orator farther states that during the said year, the said Letitia Shackleford departed this life, after whose death John Baird Junior, hereafter prayed to be considered as defendant hereto, came to your orators house, and demanded that the said boy, then in a very languishing & diseased condition should be delivered to him. To this demand your orator without scruple or hesitation acceded, as the boy from his indisposition was of no value or service to him, but after keeping the said boy about two or three days the said Baird returned him to your orator, and then required your orator to sign a paper which he exhibited. Your orator here expressly avers that he informed the said Baird at this time, that he had a discount against the amount of the said hire, which would leave but a small part thereof due, & that when he signed the paper, he conceived he was merely acknowledging that he would be indebted that balance at the end of the twelve month; for your orator further declares, that the paper was not read to him, & that he signed it from a full belief that a man of the defendant Baird's independence and