Sam: Chancery Cause, Augusta County (Part 1 of 2)
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of Harrisburg, a young lawyer who had been attending the court was on a visit at this house of your orator, to whom he is mostly connected by marriage. He informed your orator that in looking on the docket while at court he had discovered this suit brought by Sam standing upon the docket. Your orator told him what had passed in relation to the matter with the counsel of Sam. He then asked your Orator what he proposed to do; your Orator stated that he did not know what to do unless Mr. Effinger would tell him. Thereupon Mr. Effinger told your Orator that his only course would be to file a bill in Chancery. I undertook to do so for him. Your Orator gave him the items of account against Sam. & some time afterward received from him by mail the papers with instructions to apply for an injunction. The application to your Honor was rejected because of the imperfections of the Bill & your Orator now seeks to remedy those defects. The defence which your Orator proposed to make but for the mistake above stated rested upon the following state of facts. Sam the pltff. in the suit at Law was a very faithful & favorite slave of your Orator's father. Before the death of your Orator's father he made a division of most of his property among his children. In that division Sam fell to your Orator's brothers Zachariah & James jointly. Sam desired to purchase his freedom & his owner consented.but when the purchase money was paid a bill of sale was made conveying Sam to a person named Rankin. Sometime afterward Sam was again transferred by the bill of sale to a woman named [Farmer?] or some such name. While this title to Sam was in this condition he became apprehensive that he might be subjected for the payment of the debts of his nominal mistress. I applied to your Orator to take a transfer of him. Sam was at that time some seventy five years of age & your Orator felt disposed to take him & take care of him for the balance of his life in consideration of the fact that he had been a faithful family servant. I was the father of your Orator's favorite slave. A bill of sale was accordingly made to your Orator. but in order to satisfy Sam your Orator handed it to him. I suppose he still has it. Sam had st that time a mare & two colts & some articles of bedding & other furniture of little or no value. Your Orator found that Sam was about to exchange the colts for a piece of land near Staunton & in consequence of the condition of the title to Sam himself it required that your Orator should sanction the arrangement Your Orator: purpose being to take case Sam objected to his locating on the land proposed. I agreed to buy Sam's colts at valuation. They were valued at sixty five dollars for which your orator executed his bond being the same sued upon. Your Orator then took Sam home with him & gave him a cabin to live in. [There?]