.MjkyMjc.MTA2MTc5

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To the Hon. William Leigh, Judge of the Circuit Superior Court of Laws and Chancery for the County of Prince Edward. Humbly Complaining, respectfully showeth unto your Honor, your orator Henry Jackson, an infant of tender years, who sues by his Guardian and next friend, Pleasant Labby of the Town of Lynchburg, that many years ago, To wit: about the year 1834, his grandfather Pleasant Partin purchased from a certain William R. Smith of the County of Cumberland, five Negroes, to wit: Mary, a woman, and her four children, Lucy, Daniel, Anthony, & Grace at the price of $1500. At the time of making this purchase, it was the intention of his said Grandfather, declared and made known to the said Wm B. Smith, and to the father of your orator James M. Jackson, to give in absolute fee, three of said negroes, to wit: Mary the mother, and Anthony and Grace, the two youngest children, to your orator - and he did in fact make the gift as hereinafter stated. After the negroes had been as aforesaid purchased, and his grandfather had announced to the said James M. Jackson, his intention as aforesaid to give three of them to your orator, some question arose as to the form in which the title should be made. When the said James M. Jackson remarked they had as well be conveyed to him, and the grandfather remarking that he would be a proper guardian for his son, consented that the said Smith should make a bill of sale to the said James M. Jackson. The understanding all round being that he should hold the negroes, for and as the property of your orator. With this understanding, the said Wm B. Smith executed a bill of sale, conveying the three negroes, above named, to the said James M. Jackson, and they were delivered to him to be kept for your orator's benefit. As to the two others, they were conveyed directly to the said Pleasant Partin. That the fact of this gift on his grandfather's part to your orator was notorious - well known in the Town and neighborhood of Farmville, and at all times acquiesced in and recognised by the said James M. Jackson. That he kept the negroes in Farmville for several years until he removed them to Richmond about the year [blank] That the profession of said negroes, was perfectly understood by the friends and intimates of the family, and openly abound by the said James M. Jackson as above stated and he made no pretense of claiming them as his own property, until some time in the year 1842 or thereabouts, when having become greatly embarrassed in his circumstances and finding himself largely in arrears to the Branch of the Farmer's Bank at Farmville, he made a deed of trust conveying other property and the said three negroes, to A. Vaughan in Trust, to secure the Bank, and indemnify his endorser Patrick Jackson. A copy of this deed will be filed & prayed to be regarded as part of this bill. That the Bank, by its said Trustee has from time to time proceeded to sell certain of the property embraced in said deed of trust and applied the proceeds to the payment pro[illegible] of the debt due as aforesaid, but that a large balance thereof to wit: $ [blank] is still unpaid. That recently the Bank by its said Trustee, as probably by the agency of the said Patrick Jackson, the endorser as aforesaid of the said James M., has caused or permitted to be sold