LITIGATION: Jeremiah and Margaret SIMS, 1836: Orange County, Virginia Contributed for use in USGenWeb Archives by Scott Simpson http://va.genealogy.50megs.com/ ***************************************************************** USGENWEB ARCHIVES 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. The submitter has given permission to the USGenWeb Archives to store the file permanently for free access. http://www.usgwarchives.net ***************************************************************** Bill of complaint; William S. Walker and Mary his wife against Margaret Sims; Orange County Chancery Causes; Reel #575; Index #1836-004; Library of Virginia [Transcriber's note: The Jeremiah and Margaret SIMS mentioned here are apparently the Jeremiah SIMS and Margaret TAYLOR who married in Orange County, Virginia, on January 15, 1789 (Marriages of Orange County Virginia 1747-1810 (1959), by Catherine L. Knorr, page 79). This Jeremiah is probably the Jeremiah SIMS who is mentioned as a son of the testator in the will of one William SIMS (Orange County, Virginia, Will Book 4, page 387). The transcriber is a descendant of William SIMS, but not of Jeremiah SIMS.] To the honorable Richard H. Field Judge of the Circuit Superior Court of Law & chancery for the County of Orange Humbly complaining shew unto the Court your Orator & Oratrix William S. Walker & Mary his wife late Mary Taylor administratix of James Taylor jr. decd., that in the year 1827 at the September term of the Superior Court of Law for Orange, your Oratrix as administratrix of James Taylor jr. decd. her former husband recovered against Margaret Sims two several Judgments amounting to about $313.60 and interest & costs as will more fully appear by a certified copy of said Judgments herewith exhibited marked A. & B; that subsequent thereto an intermarriage took place between your Orator & Oratrix, and the said judgments, having abated by the intermarriage of the said Mary plt. therein with your Orator, were duly served by writs of scire facias, herewith exhibited, marked C & D. in the name of your Orator & Oratrix against the said Margaret Sims, whereon your Orator & Oratrix had judgments for the full amount of principal interest & costs (which will more fully appear by copies of said Judgments herewith exhibiteower interest of the said Margaret in her husband's estate, but nonetheless the said Margaret not regarding the same, by deed dated the 3rd of September 1833 and admitted to record in the clerk's office of the County Court of Orange on the 3rd Sept. 1833, conveyed to John Woolfolk all her interest in the estate real & personal of the said Jeremiah, in trust for the payment of a certain debt therein mentioned to William Sims, as will more fully appear by a copy of said deed herewith exhibited marked E. Your Orator & Oratrix insist that the said deed as to their judgments aforesaid is null & void, so far at least as it purports to convey the interest of the said Margaret in the real estate of the said Jeremiah. Your Orator & oratrix further shew that the said Jeremiah left at his death the following children, heirs & distributees of his estate, to wit, Elizabeth who intermarried with Joseph Kirtly, Lucretia who intermarried with James Oliver, Nancy who intermarried with Jefferson Jarrell, William Sims, beforemay be right & proper, until the said Dower be allotted, and account to this court for the rents & profits thereof; and that a sale may be had of the trust subject aforesaid, at least of so much thereof as may be bound by the judgments aforesaid, and of all the interest whatsoever of the said Margaret in the sd. Jeremiah's estate, for the purpose of satisfying the said judgments against her; and that such other & further & personal relief may be granted as may be right & proper in the premises, may it please the court to grant the commonwealth's writ of subpoena &c and your Orator & Oratrix will ever pray &c Slaughter & Shackelford pq.