Ned: Freedom Suit, Charles City County (Part 1 of 6)
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To the Honourable William Browne, Judge of the Sup court of Law & Chancery for the county of King and Queen- Humbly complaining show unto Your honor your Complainants Ned, James, Priscilla & Peter that on the day of in the year 1831 a certain George Moore of the county of King and Queen executed a deed of trust to a certain Thomas Dudley of said county by which he conveyed to said Dudley, this being his whole estate real and personal for the purpose 1st to keep his debts, 2nd to emancipate your Complainants & 3rd to secure to your Complainants the balance of his property, after payment of his debts Copy of deed included A is here refered [referred] to and prayed to be taken as part of his bill. Your Complainants further show that on the day of in the year the said George Moore departed this life, having first made and duly published his will, which is here refered [referred] to marked B and prayed also to be taken as part of this bill. In his said will the said Moore, recognises [recognizes] the deed aforesaid and substantially makes a part of his said will & appoints the said Thomas Dudley his ex'cr. The said Dudley has since died leaving six children to wit, Frances, Alexander, Josephus, Baylor Waller and, all of whom are infants under the age of 21 years. That a certain John Booker has qualified, as adm'r. with the will answered of the said George Moore, and threatens to take Josephson of your Complainants of the whole estate of the said George Moore, conveyed in the deed aforesaid under [pretext?] that it is necessary, for payment of debts &c your complainants charge, that this is not necessary as by the said Deed & Will the said Moore has charged his land & other personal estate (your complainants excepted) with the payment of his debts, which they charge is amply sufficient Your complainants are apprehensive That the said Booker may attempt to sell them, or that they may be taken, under execution & sold for payment of the debts of the said Moore