Wayne County NcArchives Court.....Woodrow Grady Petition, John Dickinson & 1920
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File contributed for use in USGenWeb Archives by:
Connie Ardrey n/a December 17, 2008, 3:50 pm

Source: Nc Archives
Written: 1920

North Carolina
Wayne County

In-Re-John C. Dickinson and Woodrow Grady

To the Honorable William R. Allen, one of the Justices of the Supreme Court of 
North Carolina

Your Petitioner Peter Coley, respectfully shows to the Court

First: That John C. Dickinson, aged eight years, and Woodrow Grady, aged six 
years are the infant children of Hattie Greenfield.

Second: That the said mother of said infants abandoned the care and keeping of 
said infants to the custody, care, keeping and maintenance of your petitioner 
who has cared for said infants for more than three years providing them with 
food, clothes, and keeping them at school

Third: That the mother of said infants is related to the wife of your 
petitioner who aids in the care of said infants with the solicitude of a 
kinswoman, and the children are well cared for and kept at school and all 
their necessary wants are well provided

Fourth: That the mother of said infants has become a woman of ill repute and 
is not a proper person to have the custody of said infants, and the petitioner 
has never surrendered the custody of said infants to their said mother

Fifth: That the said Hattie Greenfield, went to the school where we had sent 
the said infants and took possession of them and refuses to surrender them to 
your petitioner

Sixth: That the said restraint is illegal for that said Hattie Greenfield, at 
the time of giving said infants into the care and custody of your petitioner 
more than three years ago, stated to the petitioner that she abandoned all 
claim to the custody of said infants; that the legality of said restraint has 
not been already ajudged upon a prior writ of habeas corpus to the knowledge 
or belief of your petitioner

Wherefore your petitioner prays your honor to grant the writ of habeas corpus 
to be directed to the Sheriff of said County, requiring him to bring before 
your honor the body of John C. Dickinson and Woodrow Grady, with the cause of 
their restraint by said Hattie Greenfield may be inquired into and relief may 
be afforded to your petitioner

Wm. O.B. Robinson
Attorney for petitioner

Peter Coley, being duly sworn deposes and says that the foregoing petition is 
true of his own knowledge except as to those matters therein stated upon 
information and belief and as to those he believes it to be true

Sworn to and subscribed before me
this 6th day of January, 1920

Peter Coley (Signed)

H.A. Simmons
Deputy Clerk Superior Court 
Wayne County

Source: NC Archives
Wayne County Miscellaneous Records
CR.103.928.10


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