Mary Floyd &c vs John Floyd 1780 - Transcribed by Gail M. Walczyk
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Northampton Ss.
To the Worshipful Justices of the County afsd in Chancery humbly complaining your Oratrix Mary Floyd Widow of John Floyd of said County decd Thomas Stringer and Anne his wife, James Floyd, Abel Garrison and Margaret his wife & Berry Floyd, William Floyd, Matthew Floyd, Benjamin Floyd, Elizabeth and Samuel Floyd Infants by James Taylor their next Friend humbly showeth That John Floyd late of said County, Father of your Oratrices Anne Stringer, and Margaret Garrison, and your Orators James, Berry, William, Matthew, Benjamin and Samuel Floyd and your Orator Samuel Floyd, on the __ Day of _____ Anno Dom. 1775 departed this Life intestate leaving the following Negro Slaves (to wit) James, Toby, Boston, Jacob, Sarah, Agness, Tabby and Grace. That your Oratrix Mary Floyd & John Floyd Heir at Law of said Decedant obtained Administration on his Estate and had the said Slaves & other Personal Estate Appraised But no so it is, may it please your worships that the said John Floyd keeps possession of said Salves and refuses to pay the Plaintiffs children of the said Decedant their proportionable Part of the appraised Value of said Slaves as to deliver your Oratrix Mary Floyd her Dower in said Slaves. In tender consideration thereof and for as much as your Orators & Oratrices are without Remedy at Law & properly relievable in a Court of Equity and to the End that said John may be compelled by a Decree of this Worshipful Court to pay your Orators & Oratrices their proportionable Parts of the appraised value of said Slaves & your Oratrix Mary Floyd her Dower therein May it please your Worships to grant to your Orators & Oatrices his Majesty's most gracious Writ of Subpoena to the said John Floyd to be directed commanding him under a certain Pain & Penalty therein to be limited and expressed at a Certain Day to be and appear before your Worships in Chancery then and there to stand to and abide such other & further Order & Decree as your Worships shall judge agreeable to Equity & good Conscience and your Orators and Oratrices shall pray
Jas. Taylor Pro Plt

The answer of John Floyd Heir at Law of John Floyd decd to the Bill of complaint of Mary Floyd, Thomas Stringer and Anne his wife, Abel Garrison and Margaret his wife, James, Berry, William, Matthew, Benjamin, Elizabeth & Samuel Floyd. This Respondant now and at all Times hereafter saving & reserving to himself all and all manner of Benefit of Exception to the manifold Imperfections & Untruths in the Complainants Bill of Complaint contained for answer thereto or to so much thereof as he is advised is material or necessary for him to make answer unto, he answers & says That true it is that his Father John Floyd late of Northampton County departed this Life Intestate leaving the said Slaves which were since appraised according to Law under the Administration of the complaint Mary Floyd & him the Respondant. But denies all manner of Fraud or Intention of defrauding the Complainants of their Parts of the appraised Value of said Slaves or the Widow the said Mary Floyd of her Dower. But for as much as a Distribution made among the Infants could not be valid without a Decree in Chancery for that Purpose This Respondant has not heretofore mad any Distribution of the appraised Value of said Slaves But is now ready & willing to Stand to & abide such Order or Decree repeating the Premises as your Worships shall judge agreeable to Equity & good Conscience. wherefore this Respondant prays to be hence dismissed with his Costs much wrongfully sustained by means of the said Bill of Complaint
John Floyd

Sources:

Mary Floyd &c vs John Floyd, 1780-006. Local Government Records Collection, Northampton County Records. The Library of Virginia, Richmond, Virginia. Accessed 7 June, 2009. <http://www.lva.virginia.gov/whatwehave/local/chancery/index.htm>

© Copyright 2009-2012 by Gail M. Walczyk