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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 complaint exhibited against him by William Dickenson senr. and William Dickenson jr before the Honorable the Judge of the Superior Court of Chancery for the District of Lynchburg This Defendant saving and reserving to himself now and at all times hereafter the benefit of all just exceptions to the plaintiffs' bill to do much thereof, as he is advised is material answereth and saith that he admits that many years since he sold to a certain Christopher Clark a blacksmith the name of Randolph at the price of eight hundred dollars payable in twelve months from the time of the sale, but the defendant expressly denies that he made to the said Clark any representation of the honesty of the slave so sold, but on the contrary this Defendant did inform the said Clark that the said slave was not honest, but that he was addicted to pilfering to which the said Clark replied that nearly all slaves were addicted by such practices. This Defendant further states that the said smith was valuable as a workman, that he was well known to the said Clark, who had seen in the habit of having work done at the shop at which this smith worked, that he was sold to the said Clark upon credit at time when ordinary field negro men would have sold not much short of the price given for the said slave Randolph, oi sold upon the like credit. And this repondent feels satisfied that, except for the said Clarks subsequent embarrassments, he never would have applied to any court for the purpose of injoining any part of the purchase money of the said slave. This defendant has no knowledge except from report of what became of the said slave Randolph whether he was transported or hanged, but understand that the said Clark instead of keeping the said slave under his own direction and management hired him out in an adjoining county among slaves engaged in carrying on iron works, a situation calculated to destroy the honesty of a slave under the best character. This defendant residing in a distant state has no knowledge of the allegation of the plaintiffs in relation to the discovery of new testemony, to the negligence of the said Clark or in relation to any