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

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To the Honorable the Judges of the Circuit Court of the District of Columbia sitting in chancery. The separate answer of Arthur P. West to the supplemental bill filed in said Court by Negro Hannah & others against this defendant & Benjamin Oder. This defendant reserving now and at all times all manner of benefit & advantage of exception to the many imperfections of the said supplemental bill for a full answer thereto nevertheless as to so much thereof as he is advised that it is material or necessary for him to make answer unto, he answers & prays that true it is that in the answer which this defendant made to the original bill filed in this cause he asserted the right of himself and one Benjamin Oder to the complainants as now charges under a bill of sale from his father Stephen West to this defendant & the said Oder. But particularly denies that the said bill of sale was not made for any full or valuable consideration or was wholly voluntary, or that it was never intended