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William Dickinson, Sr., etc. vs. Isaac Skillman, etc.: Chancery Cause, Lynchburg City (Part 1 of 2)

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The separate answer of Isaac Skillman to a Bill of Injunction exhibited against him in the county court of Bedford by Christopher Clark, this respondent saving to himself all benefit of exception to said Bill for want of form and certainty for answer to so much there of as he is advised and is material for him to answer - to answer to he reply, & says that he by no means admits the jurisdiction of this court over the case stated by the complainant in his Bill but protests against the same for the following reasons to Witt, that if all the allegations in the plfs Bill were true which he by no means admits, then the complainants plain and obvious remedy against this defendant is an action at law for damages in which the question made by the complainant can be fairly tried by a Jury of the country & for further answer to said Bill. This defendant says that it is true he was the owner of the slave in the Bill mentioned & that he sold said slave to the plft.. for the sum of $800 - it is also true that said slave was used by the deft. as a smith in his shop & that he did state as one of the several other reasons for wishing to sell said slave that the Deft. intended to & is continue his said shop and that a crop hand would suit him as well or better. This deft. however most expressly denies that he induced the complt. by representations of Randolps morality to become the purchases as is alledged in said Bill. On the contrary this deft expressly says that the moral Character of said Slave was stated to the complainant at the time of sale as one reason of this defts. wish to part with him in the course of the negotiation for the purchase of Randolph - this deft informed the plff.