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The Affidavit of David Talley Jun'r Taken this 29th day of November 1813 at the Plase and House Appointed agreeable to notice given in the Suit now depending in the Superior Court of Chancery for the Richmond district Between the Legatees of David Terrell Dec'd the Pltffs in this Cause - and Patty Terrell, Joel Yancy Collins Bradby and Edmond Herndon the Defts. This deponant sayeth that he has Been Well Acquainted with the Land and Plantation Lying and Being on Both Sides of Seneca Creek Belonging to the Estate of David Terrell Dec'd for some years past - and when his Father Rented the plantation it was in repair sufficient for Croping Considerable Better then at this time - this deponant is fully of Opinion that the Plantation and the Meadow full Sufficient for the Ample Support of the Patty Terrell without Cuting any Part of the Land this deponant Remembers that at the time his Father took the plantation that Patty Terrell and Edmond Herndon the Ex'r gave him full Liberty to Cut and Clear the Land where ever he could find the Best Spots and to put the same under such a fence as might be sufficient to take Care of the Tobacco - and this Deponant heard the said Patty say at the same time that she did not intend the Land to be of any Value to the Legatees of the said Terrell by the time She was done with it as she intended to have it all cut down. This Deponant well remembers that the Meadow at that time was a Very good one and aforded a quantity of Excellent Hay, full sufficient for all Her stock and to spare and the said Patty said that Her Husband always made more Hay from the Meadow then Wintered all his stock and she Set more Store by the Meadow than any other thing Belonging to the plantation. The Meadow Extended down to the Gate on the Creek which was all worked up