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Latest revision as of 13:39, 5 June 2020

The Separate Answer of John H Smith to a bill of Complaint exhibited against himself and others in the Circuit Superior Court of law and Chancery for the County of Prince Edward, by Henry Jackson an infant, sueing by his next friend Pleasant Labby. This respondent saving all just Exceptions to said bill for its many errors of law and face, and Demurring to the same as fully as if the Demurrer was formally drawn up, and without moving said Demurrer, for answer thereto saith that he purchased on the [blank] day of September 1846, of A. Vaughan Trustee in a deed Trust executed by James M Jackson, conveying certain property to him, to secure the payment of large debts due to the office of discount and deposit of the Farmers Bank of Virginia at Farmville, a negro girl named Grace, one of the negroes Conveyed by said deed, at the price of $600.00 cash and he paid the whole amount of the purchase money in cash. On the day of the purchase received a bill of sale for said Girl from said A. Vaughan & P.H. Jackson and an order from said Trustees for the said Girl, then in the town of Lynchburg in the possession of the wife of said James M. Jackson who was represented in having gone thither on a suit. Respondent likewise had the concurrence of P.H. Jackson in the purchases with whom indeed, the price to be paid was agreed upon & was also informed that said James M. Jackson either had authorized or would concur in said sale, that having this purchased and paid for the said Girl, he went to the said town of Lynchburg, and found her at the house of Pleasant Partin, the Grandfather of the infant Complainant and demanded her of him, that he seemed reluctant to deliver the Girl and said he had wished to purchase her for his