To the Worshipful Court of Franklin County in Chancery sitting humbly complaining here unto your Worship your orator Palmer Parson & Abel Parson that some time in the year 1783 a certain Thomas Damos of Bedford County sold to Ann Preston, the widow and relict of Moses Preston, dec'd. of said county, a tract of land containing by estimation 194 acres for the sum of L28, that the said Ann Preston had then living by her late husband, six children, to wit: Moses Preston, John Preston, Jesse Preston, Anna Preston who afterwards intermarried with William Smith, Elizabeth - Preston who afterwards intermarried with William Taylor and Sally Preston who afterward intermarried with William Boles, that the said Ann Preston, after the said purchase intermarried with William Robertson, Sr., of Franklin County and had by him three children, infants under the age of 21 years of age at the time of her death which took place about the year (no date given) -. That after the death of the said Ann Robertson (formerly), Ann Preston, the said William Robertson, Sr., who was then only tenant by the courtesy & together with John Preston, William Smith, William Boles and Jesse Preston, conveyed the said land by deed in the year 1804 to Moses Preston one of the heirs of Ann Robertson (formerly Ann Preston), the other heirs William Taylor & Elizabeth his wife refusing to convey their portion of the said land and neither the wives of the said William Smith nor William Boles relinquished their dower in the same. That in consequence of the said conveyance the three children which the said Ann Robertson had by William Robertson and who were equally her heirs with her former six children are excluded from any portion in the said land and deprived of their legal rights, which said deed of conveyance from Robertson & others to Preston is duly admitted to record in this court. That Moses Preston conveyed the whole 1ot of land to your orator who was then ignorant of his defective title to the same in the year 1814 for the sum of $500, three hundred of which was paid off at the time of the purchase by your orator and this court gave to Moses Preston for the remaining two hundred which said bond was traded to the Abram Taylor, dec'd., late of this county. Your orator further states that (illegible) Administrator & Administratix of the said Abram Taylor, dec'd. has instituted suit on your orators on the said bond $84 of which has been paid to the sd. adm't & adm'tx on the common law side of the court which suit now pleads? upon this office judgement docket. All which action and doings are contrary to Equity and good conscience and in as much as your orator was mindful of the premises and only relieved in a court by equity when matters of this sort are cognizable. To the end therefore that the said William Robertson, Sr., John Preston, William Smith and Anna his wife, William Taylor, William Boles and Sally his wife, Jesse Preston, Moses Preston, Littleberry Robertson, Francis Watts and Lydia his wife, formerly Lydia Robertson and Milly Robertson may be made defendants to this bill, that they answer all and singular the allegations herein contained on oath fully and - illegible word - and may it please your Worship to (illegible due to ink smear) judgement of law until this matter can be fully heard in Equity and grant such other & further relief or in equity may seem fair & finally may it please your worship to grant the - - - - - - - - -- of - - - - commonly & as in duty bond your orator will ever pray. Robt. Cook Sworn to in Court by Palmer & Abel Pearson 8th March 1828. C. Tate Contributed by Angus P. Robinson **************************************************************** USGENWEB NOTICE: These electronic pages may NOT be reproduced in any format for profit or presentation by any other organization or persons. Persons or organizations desiring to use this material, must obtain the written consent of the contributor, or the legal representative of the submitter, and contact the listed USGenWeb archivist with proof of this consent. Files may be printed or copied for personal use only. ****************************************************************