Ned: Freedom Suit, Charles City County (Part 1 of 6)
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The amended Bill of the Pltfs. filed by leave of the Court. Humbly complaining shew unto your Honor your petitioners Ned, James, Priscilla and Peter, that by the answer of the Deft John Booker the pretext for delaying or entirely deprecating the claims of your petitioners to their freedom in pursuance of the directions of the Deed to Dudley and the last will and testament of Geo. Moore it is alleged that John Moore decd. was under the will of Richard Moore entitled to thirty acres of land being in the Fork of the road towards Collins old store embracing an acre and a half on which the buildings at Centreville have been erected and which acre and a half was sold by George Moore to [Fairenhall?] and that the said George Moore also conveyed to Dudley in other acres lying in the Fork of the road - that by reason of such sale, in defect of title, the estate of George Moore may be made responsible in large damages and that your petitioners may have to be sold to pay them. Your petitioners which they do neither admit that the title thus conveyed is defective or that the estate of George Moore can in any event be made responsible beyond the price received for the land by George Moore, are advised that in order to put the question of title forever at rest, it is necessary and proper that Eliza the wife of John Booker the Deft. and who ever the only child and heir of John Moore decd. be made a party Deft. in this cause. Your petitioners here refer to the allegations in their original Bill, and pray that the same may be made and considered as part of this Bill. To the end that the said George Booker and Eliza his wife may be made parties Defts. to this suit and full true and perfect answer may make to the allegations herein contained