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Domini seventeen hundred and ninety come here again the parties
aforesaid by their Attornies aforesaid; and the said Elisha Lackland
by his Attorney aforesaid declares in the plea aforesaid against the
aforesaid Lakin Dorsey in manner and form following to wit:
Washington County, to wit, Lakin Dorsey late of the County of Washington

was attached to answer Elisha Lackland of a plea of
trespass upon the case and soforth. Whereupon the said Elisha by
John Thomson Mason his Attorney complains that whereas on the
tenth day of November in the year one thousand seven hundred
and eighty nine at the County of Washington aforesaid a certain
conversation was had and moved between the said Lakin and him
the said Elisha of and concerning the purchasing of a certain negro
man named Will, by him the said Elisha of him the said Lakin
which said Negro he the said Lakin then and there had in
possession, and upon the conversation aforesaid the said Lakin
then and there falsely, fradulently and deceitfully asserety and
affirmed to the said Elisha, that the aforesaid Negro man named
Will then and there in the possession of the said Lakin was the
proper true and Lawfull slave of him the said Lakin, which
said Assertion and affirmation of him the said Lakin by him
then and there so made he the said Elisha believing to be true,
he the said Elisha afterwards, to wit, the same day and year first
aforesaid at the County aforesaid bought of the said Lakin the
said Negro man named Will for a great sum of money to wit for
the sum of one hundred pounds Current money to the said Lakin
by him the said Elisha then and there in hand paid; and thereupon
the said Lakin did actually sell and deliver the said negro man
named Will to the said Elisha as and for a Slave during the life
of him the said Will, when in truth and in fact the said Negro
man named Will at the said time of the said assertion and
affirmation of the said Lakin as aforesaid made, and at the
time of selling him and delivering in manner aforesaid was not
a Slave but was a freeman, to wit, at the County of Washington
aforesaid: and so the said Elisha with that the said Lakin
him