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The answer of James Minor to a Bill of Injunction exhibited by Robert Lewis against Himself and Nelson Barksdale, before the Honorable John Brown, Judge of the Superior Court of Chancery holden for the Staunton District. This defendant reserving to Himself all manner of exceptions &c, for answer thereto, saith, That being possessed of and owning a Negro man named Will, and the same in the Bill of the Complainant mentioned, who had been guilty of theft and running away, tho' a valuable slave for work, he in the Spring of the year 1816, employed the Deft Barksdale to endeavor to effect a sale of Him. That in pursuance of this authority this authority the Deft Barksdale went with the negro to Buckingham Court House and on returning Home, delivered to this Deft the Bond of the Complainant Lewis, for the sum of $450 payable [blank] as the price for which he had sold Him. That this Deft expressly required the said Barksdale to conceal nothing of the character of the Negro & his former conduct, & he presumes he did not from the price he got for Him & the manner in which it was made payable, the negro being sound & healthy, a valuable work Hand, & not an old man. That upon the Bond of the complainant becoming due & His refusal to pay it off, this Deft instituted suit thereon in
the County Court of Albemarle & obtained Judgement as stated in the Bill. This Deft being personally unacquainted with the Facts & circumstances attending the sale, cannot further answer the allegations of the Bill of the Complainant, than by stating that he believes, & expects to prove, them to be groundless & untrue. He prays to have the Benefit of His Judgement at Law, & to be dismissed
from this Worshipful Court, with his Costs & damages adjudged unto Him &c.
Albemarle County Sct This day the above Deft James Minor appeared before me a Justice of the peace for sd. County & made oath on the Holy Evangelists, that the above statements are true. Given under my Hand this 5 day of April in the year 1818 T [Goss?]