Jacob: Chancery Cause, Halifax County (Part 1 of 2)
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should he liberate the plaintiffs under the will aforesaid, as the legal distributees of Philip E. Vass claim them as slaves, and as a part of his property undisposed of by his will; this respondent thus has therefore felt unwilling to subject himself to liability or to take an steps towards discharging the plaintiffs [fear?] [lenditude?] without the sanction of some tribunal competent to decide upon their right to freedom under the will aforesaid. This respondent further states that the said distributees alledge as a reason for doubting the rights of the plaintiffs (their freedom) that they were not designated (except Jacob & Mary) in the will of Philip Vass Senr. as a bequest to the said P. E. Vass, but were contained in a general residuary clause, directing an equal division of the residue of his property, and that before any decision of such residue had been made so as to ascertain the slaves, belonging to P. E Vass under said residuary clause, the said Philip E. Vass executed his will as aforesaid, and departed this life - so that the beneficiaries intended by him, were at his death wholy uncertain. This respondent further states that by the laws of North Carolina (as he is informed), free negroes can not remove or be carried into that state as directed & contemplated by the sd. will. This respondent humbly submits to the judgement of this court the questions aforesaid arising under the will of said P. E. Vass; and the plaintiffs right to freedom - therefore, and is ready & willing to do in the premises as in the judgement of this honorable court may be comfortable to equity. This respondent having his interest in the matter in controversy except as the representative of the Estate of P. E. Vass, and his distributees being deeply interested therein this respondent submits whether they