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The Joint answer of William Watts & Edward W Saunders, Committee &c of Martha Watts to a Bill exhibited against them by Fleming Saunders in the Circuit Court of Campbell County
 
The Joint answer of William Watts & Edward W Saunders, Committee &c of Martha Watts to a Bill exhibited against them by Fleming Saunders in the Circuit Court of Campbell County
The Respondents, saving to themselves the benefit of every proper & legal exception to the said Bill of Complaint, answer thereto & say - That they believe the statement of the Plaintiff in relation to the [allotments] of the slaves in the Bill mentioned to Martha Watts in the year 1836 is correct. As to the condition & value of the said slaves at that time your Respondents are not informed, but both the number is allotted & their ages & value will appear by the Report of the Commissioners who allotted them or can be shewn by other proof before the Commission, who may take the accounts asked for by the Plaintiff. It is admitted that Martha Watts was at the time of said allottment & is up to the present time of unsound incapable of managing her own property - that she owned [and?] Land upon which said Slaves could be kept & maintained & that they remained upon the Lands of the Plaintiff up to the time when they were sold by the Respondents in the year 1849, acting under a Decree or Order of the County Court of Campbell. A portion of the slaves of Martha Watts not included in said last allottment in number about [14 written in left margin] fifteen had been on the Land of Plaintiff for a much longer period, how long your Respondents do no accurately know, nor are they informed as to their value & services during the period they so remained in the custody & control of the Plaintiff. It is farther admitted that during the period said slaves so remained on the Lands & were in the custody & control of the Plaintiff, they were humanely & kindly treated by him & greatly increased in number & value, probably to the full extent stated by the Plaintiff. The relative number & value of the
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The Respondents, saving to themselves the benefit of every proper & legal exception to the said Bill of Complaint, answer thereto & say - That they believe the statement of the Plaintiff in relation to the allottments of the slaves in the Bill mentioned to Martha Watts in the year 1836 is correct. As to the condition & value of the said slaves at that time your Respondents are not informed, but both the number is allotted & their ages & value will appear by the Report of the Commissioners who allotted them or can be shewn by other proof before the Commission, who may take the accounts asked for by the Plaintiff. It is admitted that Martha Watts was at the time of said allottment & is up to the present time of unsound mind incapable of managing her own property - that she owned and Land upon which said Slaves could be kept & maintained & that they remained upon the Lands of the Plaintiff up to the time when they were sold by the Respondents in the year 1849, acting under a Decree or Order of the County Court of Campbell. A portion of the slaves of Martha Watts not included in said last allottment in number about [14 written in left margin] fifteen had been on the Land of Plaintiff for a much longer period, how long your Respondents do no accurately know, nor are they informed as to their value & services during the period they so remained in the custody & control of the Plaintiff. It is farther admitted that during the period said slaves so remained on the Lands & were in the custody & control of the Plaintiff, they were humanely & kindly treated by him & greatly increased in number & value, probably to the full extent stated by the Plaintiff. The relative number & value of the

Latest revision as of 17:37, 21 January 2022

The Joint answer of William Watts & Edward W Saunders, Committee &c of Martha Watts to a Bill exhibited against them by Fleming Saunders in the Circuit Court of Campbell County The Respondents, saving to themselves the benefit of every proper & legal exception to the said Bill of Complaint, answer thereto & say - That they believe the statement of the Plaintiff in relation to the allottments of the slaves in the Bill mentioned to Martha Watts in the year 1836 is correct. As to the condition & value of the said slaves at that time your Respondents are not informed, but both the number is allotted & their ages & value will appear by the Report of the Commissioners who allotted them or can be shewn by other proof before the Commission, who may take the accounts asked for by the Plaintiff. It is admitted that Martha Watts was at the time of said allottment & is up to the present time of unsound mind incapable of managing her own property - that she owned and Land upon which said Slaves could be kept & maintained & that they remained upon the Lands of the Plaintiff up to the time when they were sold by the Respondents in the year 1849, acting under a Decree or Order of the County Court of Campbell. A portion of the slaves of Martha Watts not included in said last allottment in number about [14 written in left margin] fifteen had been on the Land of Plaintiff for a much longer period, how long your Respondents do no accurately know, nor are they informed as to their value & services during the period they so remained in the custody & control of the Plaintiff. It is farther admitted that during the period said slaves so remained on the Lands & were in the custody & control of the Plaintiff, they were humanely & kindly treated by him & greatly increased in number & value, probably to the full extent stated by the Plaintiff. The relative number & value of the