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William J. Isabell vs. Elisha Peters, etc.: Chancery Cause, Amherst County (Part 1 of 3)

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The separate answer of Seth Halsey to a bill of Complaint exhibited against himself and another in the Circuit Superior Court of Law and Chancery for the County of Amherst, by William J Isbell, Robert Isbell, and Maurice H Garland administrator with the will annexed of Christopher Isbell dcd. This respondant saving and receiving to himself the full benefit of all just execution to the many errors and uncertainties in the said bill of complaint contained, for answer so much thereof as he is advised it is any way material he should answer, he answers and says - That he was not the owner of the slave Edmund in the bill mentioned. Edmund was the property of his Co-defendant Elisha Peters, in whose behalf this respondant sold him to the plaintiff William J Isbell. This respondant doth not recollect whether he stated in the progress of the negotiation that he was selling Edmund as the agent of Mr Peters, he however entertains no doubt but that Isbell knew at the time of the sale that he was but an agent in the transaction, but whether he did or not, there was no danger in the concealment of that fact from him, if indeed it was concealed. Elisha Peters is the father in law of this respondant, and he very well knew that as between them it was of no manner of consequence in what form the slave was sold, whether in his own, or in the name of that defendant. The first time that this respondant