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Barbara: Freedom Suit, Isle Of Wight County (Part 1 of 4)

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To the Honorable Richard H. Baker Judge of the Circuit Court of Isle of Wight; The Answer of Jeremiah Delk in his own right & as executor of Dawson Warren decd to the bill of complaints in said court exhibited by Barbara a person of colour suing in forma pauperis in her own right & that of her seven children against him. This defendant now & at all times hereafter saving & reserving unto himself all benefits & advantage of exception which can or may be had or taken to the many [errat?] , uncertainties & other imperfections in the said complainants bill of complaint contained for answer thereunto, as unto so much & such parts thereof as this defendant is advised is or are material or necessary for him to make answer unto, this defendant answering saith that he is as in complts bill charged the executor of Dawson Warren decd & that the exhibit (A) filed with said bill is a copy of the last will of the said Warren, which since his death has been duly admitted to probat. Your respondent denies that he ever as in complainants bill charged, promised the said testator that he would accept the bequests in said will in satisfaction of his interest in the negroes which the said testator descried to emancipate by the said will, your said respondent was not aware that the said testator had made the said will until subsequent to his death. Your respondent denies that by qualifying as executor of said will that he has elected to take the bequests given him in said will in lieu of his interest in the slaves which the said testator proposed to emancipate, or that he is concluded & estopped by said qualification from refusing to emancipate said slaves. The said testator Dawson Warren was a son of Samuel Warren who departed this life in the county of Surry in the year 1819 intestate, leaving his widow Cherry Warren, the said testator Dawson Warren, Samuel H