Rebecca Hobbs v. Thomas Magruder & Washington Robey. Supplemental Complaint

 

To the Honorable The Chief Judge and Associate Judges of the Circuit Court for Washington County Dist. of Columbia.

Humbly complaining, shows unto your Honors, Rebecca Hobbs your oratrix, that your oratrix did on or about the 11th day of February in the year of our Lord one thousand eight hundred and thirty four, exhibit exhibit her original bill of complaint in this Honourable Court, against Thomas Magruder & Washington Robey and others thereby stating as therein is particularly stated, praying you your Honors to grant an Injunction or order commanding the said Thomas Magruder and Washington Robey and each of them, their aiders and abettors and all persons whatsoever, not to remove your Oratrix from the Jurisdiction of your Honors Court, until her case be heard and that your Honors do give all other orders & relief that yr oratorio may be entitled to &c

As [unclear] and by the said bill of complaint [unclear] remaining, as of record in this Honourable Court ([unclear] being thereto had) may and will appear: and your oratrix farther shows unto your Honors, that the said Defendants have been served with process of supona, but have not put in their answers thereto. And your oratrix further shew until your Honors, by way of supplement, that she was the slave of Margaret Stocket late of Ann Arundell County in the state of Maryland, deceased and that by the will of the said Margaret, your oratrix was left free on the contingency of a certain Eliza Ann Daughter of said Margaret, dieing without leaving any child legally begotten of her body, and that the said   Eliza Ann has since intermarried with a certain Jones who that they have sold your orator as a slave for life to the Defendants or to one of them with the intention to defraud and [unclear] your oratrix of her freedom should she become so intitled, by placing her in strange parts where she will would not from her situation have it in her power to make good and va available her rights, should she become so entitled and that for so doing contrary to the Laws of Maryland, in such case made and provided, your oratrix is entitled to her freedom and neither the said Defendants or any other person i ca has a right to her as a slave, but that she is a free woman, and that said Defendants have attempted to carry her off to the state of Mississippi as contrary contrary to Law and in violation of yr oratrix's rights and further that in despite and defiance of the Injunction issued in her case, and further yr oratrix states that In no case can she be removed, and that by the Laws in such cases made and provided, should she not be entitled to her freedom as aforesaid, neither the said Defendants or any other person have a right to detain her as her a slave, but that is such case such and she is to be taken and sold by order of the Court according to the statute of Maryland. To the end therefore that the said Defendants may answer all and every the matters and things herein before charged by   way of supplement; and that your oratrix may place such other and the same relief, as by the original bill is prayed against the said Defendants, and that the said Defendants may be restrained by the Injunction or other orders of this court, from interfering in any manner with your oratrix or molesting her in any way and that your orator may remain in custody of the Marshal of the District of Columbia [unclear] such security as your Honors may direct and which your orator is ready and willing to give for her forthcoming to ensure that the Judgment of your Honors Court in the suit of Law already [unclear] for her freedom against the said Defendants &c. And your oratrix prays for general relief and for all and every order and decree that the equity and justice of the law may require and as in duty bound &c.

Wm Brent Solr[?] for Complainants Feby 22nd 1835

Washington County, Dis. of Columbia, to wit

On this 24th day of February 1835 personally appears before the subscriber a justice of the Peace for the County aforesaid Rebecca Hobbs and made oath on the holy evangels of Almighty God that the matters and things set for and stated within the foregoing answer are true as stated, when stated of   her own knowledge and when as of the knowledge and information of others, she believes the same to be true.

Henry West J.P.

152.

Hobbs vs Magruder & Robey

Supl Bill

Filed 3d March 1834.