NETTLES v STAFFORD


Zebulon Nettles & wife
	}
vs 	}	Original Bill
	}
John Stafford et als

Filed 24th December 185?
		Botts

To the Honorable Bromfield L. Ridlby Chancellor of the p_____Divis
ion  Presiding at Gainesboro, Tennessee.
	The Bill of Complaint of Zebulon Nettlers and his wife Nancy
Nettles against John Stafford Polly Anderson, William R.
____ Thoms H. Butler administrator of Bailey Butler deceased
Kinner Gudvdron of Josias M. and Thomas Q. Stafford
William Gore all citizens of Jackson County Tennessee

	Your orator & oratrix would Respectfully state
unto Your Honor that about the year 1833 John Stafford
Senior departed this life leaving considerable property both
Real & personal which was provisionally disposed of by
a certain proper writing purporting to be his last will
and testament (which is here filed a true Copy Marked B)
to his wife Anna Stafford and his five lawful Children
and Heirs to wit Polly Anderson who was then ;wife of Baily
Butler Nancy Nettles James M. Stafford Thomas L. Stafford
_____  Adaline Stafford.   william R. Tenner is now the
______Guardian of said Thomas Q and James M. Stafford.
He also gave a portion of his said estate to a certain John
Stafford who complainants charge or aver is an illegitimate
child of the said John Stafford deceased not Born in
Lawful wedlock.  The same John Stafford give and 
bequeathed by said proper writing above to his daughter Ada
-line Stafford their negroes after the death of his wife and
after Polly Butler now Polly anderson had choosed a
certain negro from the Remainder of the negroes which
was not disposed of to the other Heirs of John Stafford Survivor

Complainants further state that Complainant Nancy Nettle
is the wife of t Zebulon Nettles and the daughter law-ful heir of said John Stafford deceased and that
only the small sum of twenty dollars was give to
them while this illegitimate child got a full portion of
said estate. Said John Stafford divested that what 
negroes and property should be left after the death of 
his wife anna Stafford should be divided when
sold between his six Children naming John Stafford

naming the Rest who complainants again Charge is an
illegitimate child not Born in Lawful wedlock but
born some year or two before said John & Anna
Stafford were married.

Complainants further charge that John Stafford senior
died in the year 1833.  That Adaline Stafford to whom was
given the three negroes after the death of said Anna Staf
ford his wife departed this life intestate and without your??
about in year 1837 and afterwards about the year 1848
Anna Stafford the wife of said John Stafford deceased
departed this life intestate and William Gore the defendant
was legally appointed administrator of all and singular ___?
goods chattels &? c of the said Anna Stafford and has proceeded to administration said estate.  Said anna Stafford died
seized and prospered ? of Considerable property both Real and
personal among the property belonging to him was _____
negroes to wit Gim Jerry??  Tell?? Jo Houston s____
Andy which was sold by deft Gore together with
perishable property to the amount of about three or
four hundred dollars as they are informed to believe
which should rightfully be divided among those
properly entitled to the same as lawful Heirs of said
Anna Stafford = Among the negroes sold by said William
Gore was th_____ and the increase then of being two which
was given to Adaline Stafford which complainants
one advised and believes properly belong to anna
Stafford his intestate as next of kin to the said Adaline
Stafford his daughter who died before him to said
Anna Complainants are advised and believe and
so charge  that this property should be divided a
mong the lawful Heirs of the said Anna Stafford
Complainants further charge that Complainant Nancy
Nettles is the lawful daughter and Heir at Law of the
said Anna Stafford deceased and is entitled to one dis
tribution part of his estate and the other defendants
to this bill is entitled to the rest with the exception of
Deft John Stafford who complainants again charge is
an illegitimate child of the said John & Anna Stafford
and they are informed & believe that he sold his interest
in said Anna Staffords estate to a certain Bailey Butler
who is now dead and his wife since his death moreover
again to a certain Anderson and is now Defendant
to this Bill by the name of Polly Anderson claiming the
interest of John Stafford in the estate os said Anna
Stafford deceased by virtue of a sale from defendant
John Stafford  Complainants aver that the sale
of said negroes and property amounted to upwards
of three thousand dollars which is now in the hands
of Deft Gore who will probably pay over one
s____ claimed by Deft John Stafford to Deft Polly Anderson
__________________________________their property   ???---
______________ry of ___________--sale will all be due in Janua
ry next and as they are informed and believe Deft Gore
regards said sale to said Butler as valid and that
John Stafford had a good title to our share of his
mothers estate by act of apunbly??? and will pay over 
the same to Deft Polly Anderson the right to do which
complainants deny.

	The previous considered Complainants pray to this
end that the parties whose names are mentioned in
the Caption of this bill be made defendants that prosp
-ise?? that each and every one of them make full
_____?? perfect answers in each and  every ____
term in this Bill contained as if especially intere??
quted them to.  That by a change of your Honorable
Court William Gore the Administrator of said Anna
Stafford deceased be perpetually conjoined and
restrained??  from paying over or in any wise
distributing any part of said estate to the Defendant
John Stafford his heirs or assigns
That he be ordered to pay over the same to the
lawful Heirs and Distributees of the said Anna
Stafford Deceased to the exclusion of Deft John
Stafford and his assigned who had full notice
of the illegitimacy of said Deft John Stafford and
purchased with full notice of this fact  That
an account be taken and complainants
substituted to all the rights and equity which
properly belongs to th;em and they pray from
such other pr_______ & general Relief as to Law
and Equity belong an to which the premises
m;ay entitle them as in duty bound they will
even pray.
			Washburn & Spinlock
		 		Solicitors  ______