From Transcribe Wiki
Jump to navigation Jump to search

The answer of William A Howard to a bill of injunction exhibited against him in the chancery court of the county of Prince Edward wherein Edward W Preston is plaintiff and this respondent is defendant. This respondent now and at all Times saving and reserving to himself all benefit of objecting to the jurisdiction of the court aforesaid (now protesting against the right of said court to assume jurisdiction in this case) and of all exceptions which might be taken to the complainants bill for errors therein contained; for answer thereto or to so much thereof as he is advised is material to answer. answers and says that it is true as alledged in the complainants bill that the complainant and this respondent made an exchange of negroes, it is also true that the negro that this respondent received of the complainant in exchange for a healthy, hearty negro, was at the time of the trade and as this respondent believes, had been for sometime, time previous thereto, diseased and unhealthy, to such extent that he died in the course of a few weeks after this respondent got him. The circumstances under which the exchange was made were as follows the complainant came to this respondents house and finding him sick in bed requested to see him saying that he wished to obtain permission of this respondent to get his negro (Jacob)