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Elizabeth Head, Raymond and John M. Head vs James M. Head Sr. et al, 7 January 1857, Sumner Co., TN, Lawsuits #9821

To the Hon. B.L. Ridly chancellor ? sitting at Gallatin Sumner County.

The bill of complaint of Elizabeth Head, and Raymond & John M. Head Executors of H Head and citizens of Sumner County against James M Head Sr., William A Lauderdale & wife Penelope, Beverly Head, Jessee H Johnson, David(?) Chenault & wife Martha E, John W.H. Johnson, May(?) Penelope Head citizens of Sumner County and Pascal Head, Tavenah Head, Alfred Head, Yeaminordas(?) Johnson, Horace Johnson, Leonidas F. Johnson & James R Johnson non-residents of Tennessee and Sumner County.... ? L. Robinson a citizen of Davidson(?) County, James M Brown & wife Mary E & Nimrod B Johnson citizens of Wilson County, Horace Head, James Henry Head, John Head, George Head, Lucy Head and an infant name not known children & survivors of H Head and citizens of Obion County.

Humbly complaining your Orators and Oratrix would there with your Honor that H. Head departed this life in the year Having a will, which was admitted to probate by the county court of Sumner and your Orators Raymond & J M Head were qualified as Executors. A Copy of said will, will be filed on the hearing of the cause. After payment of the accts, all the property of the testator was is bequeath to his wife, the consort(?) Elizabeth and at her death to be divided among the children and grandchildren, after accounting for sundry advancements. These fact will more fully appear by the will. The executors proceeded to sell under the order of the circuit court sundry places, for the payment of the accts of the estate. There was still a balance of some $300 due James W Head and by our arrangement with the tenant for life for the payment of the interest, the Executors concluded not to sell another slave, for the present. But since said sales, a slave ...?... belonging to the estate became unruly and ran off and could not be controlled. He was lodged in jail and the Executors thought, with the ...?...of the tenant for life, that it would be advisable to sell said boy and pay the balance due James W Head and invest the balance in the purchase of a woman the wife of another salve belonging to the estate. They accordingly sold said boy for $1075, his full value, to R.J. Lyle(?) and have paid said debt on Head and invested $650 in the purchase of said woman Jane & her two children. The woman & children cost $1300 but the defendant Lauderdale agreed to become a joint purchaser, as he had control of the other negroes; and he paid $650 and the title to the negroes is taken to him and the estate jointly. This is a very advantageous arrangement for the estate. The premises considered ...?...that the parties mentioned in the ...?...who are all the legatees under the will be made defendants to the bill. Let professions(?) & publications be made and a guardian ad litum be appointed for James H, John, Lucy, George & Penelope Head & the infant name not known children of Horace Head and John W H & James R & Nimrod B Johnson all of whom are minor and upon the hearing of the cause by ...?... ratify said sale of Anderson and rest the title in the purchases Lyle and also the payment of said acct and the investment of the $650. And grant such other relief as the reactive(?) of the case may require and to the court may deem ment(?) and as in ...?... they will ever pay.

Head & Leus(?) Jols(?)

This day came JM Head before me and made oath that the defendants mentioned in the caption as non-residents, are not inhabitants of Tennessee, and that the constructs of the foregoing bill are true to the best of his knowledge & belief. JM Head

Sworn to before me Jan 7th 1857. WH Blackmore AM

I acknowledge myself complete security in the foregoing bill for all costs that may occur from the filing of the bill this Jan 7th 1857.

James J. Turner (seal)

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