Thomas T. Craghead vs. Richard Kidder Randolph: Chancery Cause, Prince Edward County (Part 3 of 3)
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Virginia Pleas before the Justice of the Peace for the County of Prince Edward: Be it remembered that at rules taken in the Clerks office of said County Court for the month of July 1831, Thomas T Craghead, by his Attorney exhibited his Bill in Chancery, against Kidder Randolph, Peyton Randolph and Wm. Berkeley, which bill is in these words: "To worshipful court of Prince Edward in Chancery sitting: humbly complaining sheweth unto your worships Thompson J Craghead: That a certain K Randolph is justly indebted to your Orator in the sum of $[blank] upon the following account: that many years ago the said Randolph left this countey leaving a negro woman slave the property of the said Randolph in this county, and he moved to the state of Rhode Island: that the said negro woman, named Betty became old & infirm & helpless and in this situation came into the possession of your Orator: - that your Orator had a conversation with William Berkeley, a near conve-ion and agent of said Randolph, about said Betty - that William Berkeley promised your orator that he should be paid a sum of money for and in consideration of services rendered said Betty by your Orator: that said Berkeley had money belonging to said Randolph for the purpose of paying his (Randolph's) debts as agent for him: that notwithstanding said promise to pay your orator for his services rendered to said Betty and not withstanding his holding money belonging to said Randolph yet he has neglected to perform and comply with his said promise to your orator: that your Orator has gone on to clothe & support, lodge & nurse said helpless & infirm, old & decrepid negro woman from the [blank] day of [blank] in the year [blank]: That Wm Berkeley & Peyton Randolph are indebted to said K