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The State of Alabama
Franklin County S.S. Be it remembered that heretofore to
wit on the [ blank] day of [blank] was filed in the Circut Court
Sitting in Chancery for the County and State aforesaid , a bill
of Complaint in the name of William S Hoskins, Complainant,
against John W Jones Isaac Winston & Jacob Haigh Executors
of Arthur Jones deceased, and others Respondents, in the
words and figures following to wit.
The bill of Complaints of William S Hoskins a Citizen of
Marengo County Alabama. Complainant , and John W Jones
Isaac Winston and Jacob Haigh Executors of the last will and
testament of Arthur Jones deceased, and other defendents,
To the honorable the Judge of the fourth Judicial Circuit in
and for the County of Franklin, and State of Alabama, in
Chancery Sitting, Humbly Complaining Showeth unto your
Honor, your Orator William S Hoskins, that in the year 1828,
Nancy Hoskins. Widow of Samuel Hoskins, and mother of
Complainant, was possessed among others property of five
Negro Slaves namely Sarah and her two Children,
Swift and Martha, Haywood, Meranda, that said Widow
being then about to intermarry with Arthur Jones. now
deceased, did on the 20th November 1828. with a view of
providing for your Orator out of said property, make
to your Orator a deed of gift to said Several negroes &
alliened them to your Orator , that on the same day, and as
a part of the same transaction the said Nancy made an
Agreement under Seal with your Orator, in which reciting
that said Nancy had made to your Orator Said of gift, your
Orator agrees that Said negroes, woman Sarah and her two
children Swift and Martha, Should remain in said
Nancys possession during her life time, after her death to
return to your Orator, with all their increase, which said
agreement was proven and recorded on the 2d day of
March 1829. All which will more fully appear on reference

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