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 the County of Isle of Wight in Chancery sitting; The joint & severaly answer of Jeremiah Delk Executor of Dawson Warren & administrator of Cherry Warren decd & Margaret his wife late Warren, to the original & amended bill of complaint in said court exhibited by Barbara & others against them & others. There defendants now & at all times hereafter saving & reserving to themselves & each of them all benefit & advantage of exception which can or may be had or taken to the many errat, uncertainties & other imperfections in the said complainants said original & amended bill of complaint contained for answer thereunto, or unto & much & such parts thereof as there defendants are advised is or are material or necessary for them or either of them to make answer unto, there defendants severally answering say that your respondent the said Margaret, is the daughter of Samuel & Cherry Warren, that the former departed this life in the county of Surry in the year 1819, intestate, leaving his widow the said Cherry, Dawson Warren the testator in there proceedings mentioned Samuel H Warren & your respondent the said Margaret, the three children of the said Solomon & Cherry surviving, his distributees & heirs at law. The widow Cherry Warren on the 20th of Sept 1820, qualified in the County Court of Surry as the guardian of her said infant children Samuel H & Margaret, as will appear from the annexed certificate of qualification marked (P) prayed to be taken as a part of this answer. The former died in 1829, leaving his said mother, brother & sister surviving - in the year 1827 Exhibit (P) Answer your respondents intermarried. That in reference to the history of the title of the negroes in the proceedings mentioned belonging to the estate of the said Samuel Warren your respondents adopt the former answer filed in this cause by your said respondent Jeremiah Delk, showing their ownership on the death of Cherry Warren which event took place in the County of Surry in the year 1846. The said Cherry never settled her guardian transactions with your respondent, the said Margaret, who intermarried with the said Jeremiah during her infancy