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Hannah: Freedom Suit, Arlington County (Part 1 of 3)

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The supplemental answer of Arthur P. West to the Bill of Complaint of Negro Hannah and others exhibited against him in Chancery in the Circuit Court of the District of Columbia for Alexandria County filed by leave of the Court - This defendant saving and reserving & answereth and saith. That he denies that any contract or agreement for the purchase to manumission of the Complainants in the above cause or any of them was ever made between Charles Jackson and Stephen West as the said Complts. have in their said bill charged. And this deft. denies that said Jackson performed any acts of labor or service for the said Stephen West, that any other consideration, than that of wages or money & provisions for the said Jackson's support and maintenance - And this deft solemnly dismiss that there is any truth in the allegations in said Compts. bill that charges this deft with bond - And as to the relief prayed by the said Complts. in their said bill under the pretended contract or agreement therein charged, this deft asserts for his defence and in bar of such relief or act of the parliament of England made in the 29th year of King Charles the 2d. reign intitled [entitled] "are not for prevention of bonds and perjuries" and which act now in force in the State of Maryland at the time that when the said complts. charge in their said bill that the said pretended agreement or contract (under which they claim a right to be free, was made. That in the said act it is among other things indicted "That no action shall be brought whereby to charge" any person upon any agreement, that is not to " be performed, within the space of one year from the " making thereof, unless the agreement upon which " such action shall be brought, or some memorandum or note thereof shall be in writing and " signed by the party to be charged therewith or some " other person thereunto by him properly authorised And this deft avers that neither the said Stephen West nor any person by him lawfully authorised did ever make or sign any contract or agreement.