Chloe Ann Marter v. Elizabeth Neale. Demurrer


Negroe Chloe v Elizabeth Neale.

On the trial of this Suit evidence was offered to the Jury to prove that the plf Chloe had been was born in the State of Maryland and was the property of one Sarah Neale. that on the said Sarah's death the plf was under the will allotted to William Neale one of the sons of the said Sarah as part of his dividend of the said estate. that when the said allotment was made the said William Neale was not in the Country and has not since returned to it. that the said William has not sold or disposed of the plf. that the plt was hired to one Mrs Hoskins by Elizabeth Neale wife of Fielder Neale, a son of the said Sarah Neale & by his permission in the year 1814 in the month of February. and and remained in the service of the said Mrs Hoskins about thirteen months in the Town of Alexandria Evidence was further offered to prove that the plf had been brought into Virginia Alexandria and to one Hanson Moreland in the year 1811, by one Zachariah Neale son of the said Sarah and had remained in the employment of said Moreland in Alexandria about eighteen months.


evidence was further offered to prove that the said Sarah Neale had departed this life between the 8th of January 1810 & the 2nd January 1812

to which evidence defdt demurs & it is argued that the demmurer shall be hereafter drawn up in form. and that the precise time of Sarah Neales death may be [illegible] on an affidavit of the part. plf joins in demmurer

R. J. Taylor Defdts atty
A Fitzhugh pff atty