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

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intended by the said bill of sale to place the property & slaves therein mentioned out of the power & control of the said Stephen West. And avers that the said bill of sale was made for a fair full and bonafide consideration beyond that in the said bill of sale expressed and mentioned which has been actually paid. That the actual consideration for the said bill of sale was a large sum of money owing from the said Stephen West to this defendant for monies lent to him & paid & advanced for him & at his request prior to the execution thereof. And also certain debts of him the said Stephen West & his son Charles H. L. West, which were by this defendant assumed at the like request about the time of the execution of the said bill of sale & by this defendant since discharged amounting in the whole to about seven thousand dollars. And this defendant further answering denies that he at the time of the execution of the said bill of sale, or at any time since or before knew of any right which the complainants had to their freedom. He states that he had heard of the contract stated in the bill to have been made by the said Stephen West with negro Jackson, but knows that the terms of that contact were never complied with or executed by the said Jackson. He having elected to receive the amount of his wages in money every dollar of which this defendant believes & charges was paid by the said Stephen West to the said Jackson. And this defendant insists that as it appears from the pleadings of the complainant that they never have been legally manumitted that it is wholly incompetent for them to sue or impede him in the present manner without that there is any other matter or thing in the said supplemental bill contained material or necessary for this defendant to make answer unto and not herein & hereby will & sufficiently answered unto confessed & avoided, traversed or denied is true. All which this defendant is ready to aver & prove as this court may award & humbly prays to be hence dismissed with his reasonable costs & charges