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Admr. of Hiram Jordan vs. Margaret Swann, etc: Chancery Cause, Frederick County (Part 1 of 4)

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The Separate Answer of Lewis Jordan, a free Man of Color, to a bill of complaint &c, Exhibited against himself & others in the Circuit Court of Frederick County by Oliver M Brown in his own right and as admr of Hiram O. Jordan dec'd. Said Respondent reserving to himself now and at all times hereafter the full benefit of all just, legal and equitable exceptions to said bill for its Manifold errors, uncertainties, Misstatements &c, of Law and fact, for answer thereto, or such part thereof as his is advised it is Material or Necessary he should answer unto - answering Saith: That he has no personal Knowledge of the Matters and dealings, Set out in Said bill in connection with the alleged purchase of Maria nor the widow,, formerly the wife, of said Hiram O Jordan dec'd from Mrs Margaret Jordan, or of the [illegible] of any paper referred to in Said bill as [executed?] in connection with that alleged purchase, including the bond of the Complainant Oliver M Brown & others, [illegible] by him & them as he alleges, as Security of said Hiram O. for the alleged purchase Money of said Maria: or of that of the deed of trust alleged in said bill to have been Made by Sylvester Jordan, for the purpose of securing said purchase Money, or for the purpose of indemnifying said Oliver M. as said security &c. And therefore does not admit the same, or any part thereof, but requires full and particular proof thereof. Said Respondent further answering, Saith that Said Sylvester Jordan was, and still is, a Slave - That on the other hand, his Mother Kitty or Catherine the late married wife of said Sylvester was born free, and bound as an apprentice, as Respondent has heard, When a child to a Mr or a Mrs Lanie late of that part of Frederick County near Clarke - That said Sylvester belonged to the same [illegible] to [illegible] said Catherine was so bound, or to serve Quinton of the same family. That Some 20 years, more or less, ago, Said Catha-