John Tayloe vs. William Willis, etc.: Chancery Cause, Lynchburg City (Part 1 of 2)
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at the time, he knows he was a man of firm constitution & was sound and well at the time he left his house about three or four days before the sale. This respondent purchased the woman of negro trader & owned her from one to two years she had while his property a child which died at about 6 months old for her he gave $450 & she was a hearty healthy woman. The man took the woman for his wife & they both run away were taken up in the neighbourhood of Manchester brought home to your respondent & the next day after their return were sent off to be sold both in good health. Their having run away from your respondent was the reason which induced your respondent to sell them, he denies expressly that he had any doubt of their being in good health. This respondent was informed by the other deft that the man complained of his toe being frost bitten before he got to Lynchburg of which he informed the complainant. This respondent refers to the answer of the other deft for the representations made by him of the health of the negroes at the time of the sale & delivery and also what was the state of their health at the same time in the month of June 1818 when the money had become due. This respondent went to the town of Lynchburg where the complainant was & sent to him by Mr. Phaup for the money due on his bond which he refused to pay as the said Phaup informed your respondent. Your respondent then ordered suit on the bond. As this respondent returned from Lynchburg he saw the negroes in the possession of Mr. Hendrick the negroes wished your respondent to purchase them from Hendrick & after making a strong appeal to his feelings & saying they would never run away from him he offered Mr. Hendrick $1000 for them which he refused to take. The xmas afterwards the woman Rebecca came to the house of this respondent with a pass from Mr. Hendrick & insisted that this respondent should purchase herself & husband Mr. Hendrick brought the negroes to Charlotte Court House and offered them for sale This respondent then offered $1000 which Hendrick refused to take. This respondent does not know what change may have taken place in the health of the negroes after the sale but he is certain they were in good health at the time they left his house 3 or 4 days before the sale. This respondent never heard any complaint from the complainant about the health of the negroes untill about the time the money became due, he would have gladly taken them back at any time in the same condition they were when sold and having fully answered he prays that the injunction be dissolved & that he be hence dismissed with his cost. Richd Dabbs