LAWSUIT Part One
James Hord vs William Richards
Administrator of the estate of Simon Miller

 
 

Simon Miller was the father in law of both men.  James Hord's wife,  Mary Susan Miller was a daughter of Simon's first marriage and  Lydia Miller, a daughter of his second marriage.
The marriage of James Hord to Mary Susan  is outlined in the depositions in this lawsuit. The content of the depositions and the places that they were taken are of interest to the researcher, in that, they show relationships to the family, the location of the family and  the distances covered from Virginia to Kentucky to get the depositions.

This is quite lengthy and is copied in it's entirety as much as is possible. The entire case was not available to us, however, it is assumed that the final deposition of this case was not in favor of  James or his heirs, among whom were his sons in law, Thomas Brooks and James Withers.

We have found evidence that this suit continued into the late 1820's after our Thomas Brooks was in Missouri.
[See Hord information page for James Hord will, etc.]

JAMES HORD  born January 28, 1736 in King George County, Virginia, died  before September 23, 1803 in
Culpeper County, Virginia was the son of  Thomas Hord and Jane Miller.. [1st cousins].   He married Mary Susan
Miller who was also his first cousin, about 1759/60.  She was the daughter of Simon Miller III and his first wife
Isabella Miller, who were also cousins.  These two families were intermingled through several generations.  The
spelling will differ from one document to the next, however, most spellings seem to be Hord, not Hoard. Often, the
spelling of Hoard is in the various county records that have been copied from the original document  they were the
parents of four children:  See Hord appendix for ancestry of James Hord
 1. James Hord
 2. Ann Hord who married James Withers
 3. Jane Hord married Thomas Brooks/Brookes
 4. Frances who married a Slaughter.

James Hord sued the estate of his father in law, Simon Milller for a portion of the estate he claims he was promised
at the time of his marriage to the daughter of Simon Miller. A long drawn out lawsuit followed the initial suit.
After the death of James Hord in 1803, this suit is taken up by the heirs named in the will and continues over
another twenty odd years.   This starts with the  Bill of Compaint  against the Miller estate, William Richards,
administrator. It is copied as nearly as the original as possible.



Bill of Complaint  James Hord Plaintiff  vs  William Richards Defendant
Hord vs Miller/Richards Lawsuit Chancery  Court, Fredericksburg, Virginia
To The Worshipful Court in Spotsylvania in Chancery “Siting”.
 Humbly complaining “Sheweth” unto your Worships your orator James Hord that some short time before
he intermarried with Mary daughter of Simon Miller the daughter of Simon Miller the said Simon Miller promised
and agreed that if your orator did marry the said Mary that he the said Simon would give him, immediately, two
likely  negroes and at his death would give him as much as any child he had, to which promise he called Aron
Bledsoe, Moses Bledsoe and James Cunningham as witnesses, and your orator further states that the said marriage
did take effect  and the said Simon Miller hath departed this life about in the month of November 1799.
That about the time of his death he was seized in fee of about 2600 acres of land in the County of Culpeper   and
Stafford with many valuable improvements-thereon, and also possessed of about forty five or more slaves, a
Quantity of money and a Bond of William Richards for between three and four hundred pounds all of which he has
given  to William Richards who intermarried with one of his daughters Lydia.  He hath also given to the said
Richards the price of a mare sold by the said Richards for twelve to fifteen thousand weight of tobacco and various
other things  and has appointed the said Richards the executor  who hath taken on himself the Execution of the
will that the said Simon Miller at the tine of his death left four children, to wit, Simon, Mary who intermarried
with your orator, Nellie who  intermarried with Thomas Strother, and Lydia who intermarried with William
Richards. That your orator hath applied to the said William Richards in a friendly way and requested him to carry
into execution the said promise but he hath refused which is contary to equity. In consideration whereof and in as
much as your orator is without remedy but in  a Court of Equity, may it please your Worships to “compell” the said
William Richards , who he prays may be made Defendant to thid bill, to make a full and perfect answer thereto,
and that you will decree  that he shall preform the promise of the said Simon  by praying and delivering to your
orator as much of the estate which was of the said Simon Miller as will be equal to the portion of the most favored
child, and that yuo will grant unto your Orator much further relief as to your worships  shall seem agreeable to
Equity and Conscience, and your Orator shall ever  pray.


The answer of William Ruchards to the Bill of Complaint of James Hord:
The Defendent now and at all times hereafter saving and reserving to himself all manner of benefit of exception to
the manifest errors, “Incertainties” and insufficiencies  in the said Bill of Complaint  Contained for answer  thereto
or unto  so much there of as the Def”t [defendent] is advised in material and necessary in the law for him to make
answer unto he answereth and saith that he knows nothing about the promise of hte saiid SimonMiller to the said
Complainant referred to in his  Bill, nor did he ever hear of it until’ since the death of the said Simon Miller and
that when he did hear of it he was more especially surprised because art the time the Complainant  was engaging
in contesting the will f the said Simon Miller in Stafford County Court and which he afterwards prosecuted in the
Fredericksburg District Court as will he made to appear to this Worshipful Court, a contest which was quite
unnessary in the Opinion of the Defendent, if the Complainant was really entitled to set up the promise he now for
the first time urges-- The Defendent acknowledges that the said Complaintant did marry the daughter [Mary] of
the said Simon Miller by whom he got a young negro woman at the time of his marriage out of abuot eight or nine
slaves which the said Miller possessed after deducting fourr which he gave to his son Simon Miller, in cpmpliance
with his bond which is hereto annexed as part of this answer- from which Young slave the said Complainant and
his children are now in possession of Twenty odd slaves- The  Defendent acknowledges that the sais Simon Miller
did make the last will and testement which is spoken of in the Complainant’s Bill and thereby did appoint the
Def’t Executor  and that he has taken  upon himself the Execution thereof, that the said Simon Miller at the tme of
his death was in possession of   [blan space] slaves, as will appear by reference to a copy of the inventroy of this
estate hereto annexed as a part of this answer, to which the Def’t also refers for the amount of the Estarte of which
The said Simon Miller was possessed except his land on which he lived containing about two hundred acres  after
deducting one hundred acres  which was claimed by an entry of a Certain Fallace and  Dowell  which the
Defendent afterwards purchased for L 100, which he paid for himself and has the Deed of Conveyance made to the
said Simon Miller, believeing that the said Miller would leave it with the rest of his estate to the wife of the
Defendent, as he had frequently promised and as will appear he certainly intended seventeen years ago by a will
Executed by him which is hereto annexed, as a part of this answer.
That  long before the death of the said Simon Miller upwards of seventeen years ago all the slaves except those
before mentioned, which the Df’t had of the said  Simon Miller were delivered to him by the said Simon Miller to
be and held for the benefit of his wife and children as their own, and that the Lands derived from the said Simon
Miller by the Def’t has been from time to time placed on the Commissioners of Tax Books in the name of the
Defendant  as the request of the said Simon, as will appear by reference to Certificates from the said Books hereto
annexed and other testimony to be advanced in this case. That it is true that the said Simon Siller did on Some
occasions” interfer” with the said property but nevertheless’ it was always  understood that it was for the benefit of
the Def’t and his family, that with respect to the Bond that is mentioned in the Complainant’s Bill, the Def’t
acknowledges that the said Simon Miller was in possession of such a bond of the Defendents, which was given to
the said Simon Miller to “shew” what he could accumulate, [which he was desirous of knowing] as is “evidented”
by his giving the bond back, to the wife of the Def’t, some time before he died. That when it is considered that the
Def’t attended to all the concerns of the saiid Simon Miller for upwards of twenty five years past until his death,
and that he gave a considerable portion of his estate to his children from which at this time they are in possession
of very  valuable stock of  negroes without the trouble or pains  which the Def’t was, without accounting for his
predilection for the wife of the Def’t and her  family,  It will not appear remarkable that he should have left  her
the estate bequeathed her by his last will and Testament, The Defendant having answered all the allegations in the
said Complainant’s bill, which he revised in material in the Law for him to make answer unto he prays to be hence
dismissed with his reasonable costs in the Law in this  behalf most wrongly Sustained.
May 28th 1802


Depositions were taken  from this point in time  at various places in Virginia
and also taken in  Kentucky  regarding this lawsuit.

29 May 1802
Deposition of Simon Miller, Jr. taken at the house of William Young in the County  of Spotsylvania
Pursuant to a commission directed from the County Court of Spotsylvania we have proceeded to take the
Deposition of Simon Miller in a suit depending in the said County Court in which James Hord is Plt. and  William
Richards, executor of Simon Miller, dec’d is Def’t., at the house of William Young-Notice being first given and
proved, the parties being present.
This deponent of lawful age being first duly sworn deposeth and saith that the day previous to the marriage of the
Plt. with Molly the daughter of the said S’d Simon dec’d- the Plt. left the house of the s’d Simon in consequence of
some disturbance in the family and the s’d Simon dec’d followed  the said  plaintiff and  brought him back and the
said Plt. was married to his daughter the next day. That this deponent never heard his father say that the negroes
Scylla and Mingo should be the property of the Plt. and wife, or that he had given them to them, but this was the
General Opinion of the Neighborhood. Currently talk’d of and never contradicted by the said Simon dec’d in this
Deponent’s presence that the said Aron Bledsoe had frequently told this Deponent and others that the s’d Simon
dec’d had on the day of the said marriage given the Plt. two negroes and a promise of an equal share of his Estate
on his death. That the Intelligence was circulated generally from one to another through the neighborhood, that the
Plt.  at the time of his marriage was a young man dependent  on his the s’d Plt’s father, and had no property to
support a wife.
That the Plt. lived for several months after his marriage in the said Simon’s family  and there was no displeasure
existing between the s’d Plt. and s’d Simon stood on good terms with him as the  Sons in Law who came
afterwards, and this Deponent further says that the Negroe wench Scylla, st the time of the Plt. receiving them
from the s’d  Simon had no child and had not for some  years after.
Question by the Dft: How long was it since you first heard of any  marriage  promise and who did you  ever  hear
speak of it?
Answer: From the first time of hearing of such a thing was from eighteen to twenty years ago, and I never heard it
from any person but Aaron Bledsoe, or such persons he had told it to.
Question by the Dft: Was not Aaron Bledsoe on the day before the marriage in a beastly State of Intoxication?
Answer: He was on the day before’ the marriage very drunk and I missed him and went in search of him, and
found him fallen in between two stakes and would most certainly died had I not released him.
Question by the Plt: Was Mr. Aaron Bledsoe drunk on the day of the marriage and was he not sober on the
morning after?
Answer: No quite sober and further this deponent saith not   .Signed by Simon Miller
  Given under our hands and seals this 29th May 1802   Killis Hord and W. B. Wallace



 
 

26th September 1803
Superior Court of Chancery- “holden” at the Capital, in the City  of Richmond, the 26th day of September 1803,
James Hord, Thomas Brooks and James Withers, executors and devisees of James Hord   Plaintiffs  and William
Richards  Defendant.
On motion of the defendant, by “counsil”, the court, this twenty sixth day of September in the year of our Lord one
thousand eighteen hundred and three, on consideration of the bill and answer, ordereth that the injunction awarded
the plaintiffs to inhibit the defendant from carrying off, selling, or removing any timber or other tree, standing,
growing  or belonging in and upon the two thousand six hundred acres of land lying in the counties of Culpeper
and Stafford, devised by Simon Miller to the defendant, and from selling or disposing of or removing out of the
limits of the commonwealth any of the slaves which were of the property of the said Simon Miller at the time of his
death and devised aforesaid, to be dissolved as it is accordingly hereby dissolved.



5th of October 1803. Superior Court.
On motion of the plaintiff, by his “counsil” and for reasons appearing to the court, the order made in this cause on
the 26th day of September last is set aside.

06 March 1804- deposition of Bennett Noe.
The deposition of Bennett Noe taken in a suit depending in the High  Court of Chancery between the executors of
James Hord, deceased  Complainants and William Richards, Defendant.
The deponent being first sworn, saith about Twenty Four years ago, William Richards settled on the land, at that
time owned by Simon Miller in the County of Culpeper, near the point of the Fork of the Rappahannock.
That in a few years after the said Richards took possession of the said land, he commenced building grist and saw
mills  on the same and made very costly improvements in erecting houses, enclosing and clearing land, etc. That
this Deponent was on terms of friendly intimacy with Simon Miller, deceased, and had frequent conversations with
him  relative to his estate, his son in law, and their several movements in regard to him the said  Simon Miller.  He
repeatedly told this Deponent that William Richards pleased him so much by his superior  industry and good
conduct, and behaved toward him with so much respect, that he,   the said Simon Miller should consider himself
bound by every principle of Justice and Affection to give to the said Richards and his children a large proportion of
his estate.
That he, the said Simon Miller had already given , to the said Richards the land on which he then lived as
aforesaid and hoped to see the said Richards improve the same, by erecting thereon, mills, etc. That the Deponent
had frequently heard the said Simon Miller declare that he had given to the said Richards all the slaves he had in
his possession, and that the said Simon Miller had no “farther” Trouble  in regard to the payment of Taxes, etc.,
for that he had fixed his Matter concerning the whole management of the balance of his estate in the Hands of the
said Richards, who had agreed to supply him  the said Miller with every necessary provision to the support of
himself and his wife during their lives. That the said Richards and family conducted  himself as the complete
owner of the several slaves which he received of the said Miller in his lifetime.
 

[Questions by the Defendant; William Richards].
Question 1. Do you  know the current annual value of the saw mills erected by the said Richards on the land
aforesaid?
Answer.  I think that for the last fifteen years the “nett” proceeds of the saw mills could not be less than Three
Hundred Pounds per Annum.
Question 2. Has not the said Richards “layd” out a large Capital in horses, “waggons”, etc. to keep the said saw
mills at work?
Answer. He has at this time three teams of horses that were employed in drawing Timber to and from the saw mills
before the Writ of Stay was to sustain him fro mcutting timber.
Question 3. Are the said teams now unemployed?
Answer. They are very often and when employed their profits or earnings scarcely quit the Expense of their
equipment.
Question 4. Were you  acquainted with James Hord who intermarried with Mary Miller, daughter of the said
Simon Miller?
Answer. I  know JamesHord very well and was often at his house.
Question 5. Did yuo ever hear him or anyother person say any Thing respecting Simon Miller having made a
promise  on the Marriage of the said Hord to give the said Hord anyparticular portion of his the said Miller’s
estate?
Answer. I  never did. I  have frequently heard the said Hord say that he had received  of the said Simon Miller  all
that the said Hord expected from him the said Miller.
Question 6. Did the said Hord ever supervise or overlook the Estate of the said Simon Miller?
Answer. I have often heard the said Simon Miller say that the said Hord would have ruined him if he the said
Miller had continued his estate under the conduct of the said Hord and the said Hord  repeatly told me that he had
had a grievous time in the service of the said Miller and that he, the said Hord would not again sustain the
unpleasant and disagreeable attacks  and scoldings of the said Miller for all of his, the said Miller’s estate.
Question 7. Has not the said Richards erected a costly bridge across the River Rappahannock in order to accomade
and promote the interests of the said mills?
Answer.  The said Richards has  erected  a Bridge across the said river which cost him upwards of Two Thousand
Dollars which Bridge would not be of much consequence if the SawMills should be shut down or stopped for the
want of timber.

Questions by the plaintiffs.
Question 1. For whose benefit were those improvements of which yuo have spoken?
Answer. Foer the Benefit of Captain Richards
Question 2.  Are you acquainted with the land and the property of Simon Miller in his lifetime and now in the
possession of William Richards?
Answer. I am because I lived on part of the land  which I                of William Richards, during the lifetime of  the
said Miller.
Queston 3. Do you know of the said William Richards having cut large quantities of timber on that land, sawed
into “scantling” and plank and sold it?
Answer. He certainly has.
Question 4. Did he not continue to cut and sell the same from the death of Mr. Miller until enjoined by the
Chancery.
Answer.  He did.
Question 5. Have you any idea of the value of the timber, which he has cut and sold, say as nearly as you can to
what value?
Answer. I cannot say with certainty, but suppose the value to be about 1600#’s- before the death of Mr. Miller.
Question 6. Was not the timber growing on this land- what constituted it’s greatest value- will not  the land be of
small value if the timber is taken  off ?
Answer. If the timber is taken off the land would be of little value.
Question 7.  Do yuo know of Mr. Richards having sold any of the negroes which were formerly the property of the
said Simon Miller, to answer his own purposes?
Answer. I know he has sold negroes which were formerly the property of the said Simon Miller, to raise money for
the said Miller’s own benefit.
Question 8. Did you ever hear him, William Richards, declare that he would sell the whole of Miller’s negroes or
words to that effect?
Answer. I  never did.
Question 9. Do you know the names of the negroes sold by Capt. Richards, if so, name them.
Answer. Their names were Berry, Daphne and her two children, Fielding, Austin, Dicy and child, Nolen and
Thornton.
Question 10. Did not Capt.Richards some years ago sell a negro man named George? To whom did this negro
belong?
Answer. He did sell a negro and I believe he belonged to Capt.Richards.
Question 11.  Do you not recollect hearing Mr. Miller say that he had directed Capt. Richards to make sale of the
said negro for the purpose of assisting him to pay for the land bought of _________?
Answer. I do not recollect hearing Mr. Miller say so- nor do I know that he was sold for the purpose above
mentioned.
And “farther” the deponent saith not.
The above deopsition was duly taken ans subscribed in our presence for a Commissioner from the high court of
Chancery for the Richmond District. The plaintiffs and defendent  being present. Given under our hands and seals
the 6th March 1804.     Signed by   R. F. Hooe and Nathan’l Fox  [no place given].



13th March 1804
Deposition of John Strode
Pursuant to a Commission from the High Court of Chancery for the District of Richmond, bearing date of the 9th
day of this month to in directed requiring us to examine witnesses in a suit in C.Courrt depending. Wherein the
Executors of JamemsHord, dec’d, are the plaintiffs and William Richards,  defendent, we met this 13th day of
March at the house of Wm. Leonard Barnes, Innkeeper in the County of Culpeper, the testator being present, we
proceeded to take the deposition of John Strode, aged about Seventy years, who being first duly swornm deposeth
and saith:
That he has been acquainted  with  defendent Richards for Thirty Five past years and knows that during all which
time, he has supopeted uniformly a fair  unblemished character.
Interrogated by the denfendent’s council.
First.  Do you  know who it was  that the defendent Richards married?
Answer. Yes,  she was the youngest daughter by a second wife of Simon Miller a very aged  wealthy and reputable
man of the County of Culpeper.
2nd. Did Simon Miller approve of the intermarriage of his daughter with  the Defendent and repose trust and
confidence in him and treat him with faternal affection?
Answer. I believe that Mr. Miller did not at the time first approve of the marriage, and that chiefly because the
Defendant Richards was no so wealthy as he wuld have wished for his Daughter, but the S. Defendant soon became
conspicuous for his prudence activity Industry and economy as well as the marked tenderness  and affectionate
attention to his wife; inso much, the said Mr. Miller in consideration of  His good conduct  took into favor and
reposed I believe every trust and confidence in His fidelity and abilities; and which for Mr. Miller appeared to be a
most happy and fortunate circumstance, as he was declining in life , and many things to transact and settle and do
with divers people  and no other firend or relation qualified as the Defendant, or be willing to encounter the task.
The Defendant took upon hisself to all appearances very professionlly      illegible    inportant trust; which he
discharged as this Deponankt believwes very faithfully, much to the satisfaction of the D’s father in law Miller.
3rd. Do you recollect at what time Mr. Miller gave the land and slaves now in dispute to the Defendant?
Answer. I believe it was about the year 1780 that hie went into possession of them, of the manners or conditions on
which he became “possest” of them I never did hear from Mr. Miller himself, but his wife, the late Mrs. Miller
informed me this deponant in the year  following that her Husband had given  Wm. Richards the land we were
then on, meaning where he now lives and a certain number of slaves in consequence of his kind good behavior to
his wife, her Husband  and Himself- and this way a matter very generally  known spoke of and understood among
the friends  relations and acquaintances of the parties, as a consideration for the great care and attention which the
Defendant on all occasions paid  the Mr. Miller’s interest and to his person and to HIs Lady who were both very
old and in a manner destitute of any other cordial and affectionate Relief.
4th. How much land and how many slaves do yuo suppose Mr. Miller on the conditions above mentioned gave to
the Defendant?
Answer. I suppose about 800  acres of land and about Twenty slaves of different ages and descriptions.
5th. What quality was that land, and at what time were the improvements thereon?
Answer. The land is thin as to soil, but it has advantages of water for erecting mills; but has little or no
improvements thereon worth mentioning.
6th. What do yu think it was worth per acre in that unimproved state?
Answer. Mr. Miller just before that time had offered 100 acres of the best there including water for the purpose, not
in money, bu tin work,; but the  undertaker failed to do the work within thew disputed time, in consequence, that
bargain was off; the balance of the land except for Timber was at best of  small value, perhaps about Eight
Shillings per acres or not quite so much.
7th. Who piad the taxes of said land and slaves?
Answer. The Defendant Richards and that always in his own name, and not that of Mr. Miller’s, at least for the
last Forteen or Fifteen years.
8th. Do you believe that the defendant Richards was on the whole any “gainer” by accepting the said land and
slaves under the foregoing conditions?
Answer. I do believe to a man of the Defendant’s enterprise and activity  had at that time been unemcumber’d of
the care and attention which he seemed bound to pay to Mr. Miller and his Lady in their helpless state on account
of his having  to accepted the land and slaves, he might and in the opinion of this deponanrt certainly would at this
time by his industry acquired not only more equal proportion of the estate in question but certainly abundantly
more; and this deponant does further fully believe that on the above terms the Defendant would have accepted of
the P’ estates. If it were not for the further  consideration of paying respect to the aged parents for his Lady,
gratifying and pleasing  Her, by the comfort, care tenderly and attenton he on all occasions  discovered to them,
which was at this deponant’s firmely believes and remembers in that cordial and affectionate manner which
lenghtened out their days and made them easier and happier. Much less has he in the opinion of this deponant
gone to make such impressive improvments as he has, on that very poor land.  [End of this Deposition]


March 27th, 1804   Superior Court
On the motion of the defendant by “counsil” the court, this twenty seventh day of March, 1804, after considering
the bill, answer, and exhibits and examination of witnessess, and hearing counsel in opposition to the motion,
ordereth the injunction awarded to the Plaintiffs to  inhibit the defendant from carrying.......same wording as
above..........[?]  be disolved as to four fifths of the land, as it hereby accordingly disolved; and the court
“appointeth” Robert Slaughter, John Thorn and William Gray, or any two of the  commissioners for th epurpose of
laying  of the four fifths of th esaid land; liberty is reserved to the defendant to repeal the motion for a further
disolution of the injunction at the next term.
The remainder of this action was not found.



September 10, 1807   Superior Court
This cause was heard on this bill, answer, exhibits and examination of witnesses and argued by counsel, on
consideration whereof the Court “adjudgeth and decreeth” that the bill of the plaintiff be dismissed as it is
accordinly dismissed and that the pay to the defendant the cost by him in his defense.
September 11, 1807  Superior Court
The plaintiffs by counsel  prayed an appeal from the decree prounounced in th cause on yesterday which is allowed
on their entering into  bond with  sufficient  security in the Clerk’s Office of this county in the penalty of Two
Hundred Dollars during the present term for the prosecution thereof.



June 19, 1813.
Thomas Brookes, William Brookes, Alexander Brookes, James Brookes and Robert Brookes, heirs of Thomas
Brooks, James Hord, surviving executor of James Hord ankd James Withers as Plaintiffs against William Richards,
executor of of Simon Miller, dec’d, defendant.
Agreeable to a decree of the Court of Appeals Certificate by the Clek in these words “Virginia to wit” at a court of
Appeals held at the Capital in Richmond this eleventh day of March 1813, ThomasBrookes, William Brookes,
Alexander Brookes, James Brookes and Robert Brookes, James Hord surviving  “ excor’ ”  of  James Hord, dec’d,
and James Withers “appets” against William Miller  “ excor’ ”  of Simon Miller dec’d “appec” and James Hord,
dec’d, and Thomas Brooks, William Brookes, Alexamder Brooks, James Brookes and Robert Brookes, heirs of
Thomas Brooks who was a devisee of the said James Hord deceased “appets” against William Richards, “aaec”
upon revived appeals, from decrees pronounced by the Superior Cuort of Chancey held in Richmond the tenth day
of September 1807 in two suits, on onke of which, Thomas Brooks and James Hord, “ excors’ “ of James Hord and
James Withers were Plaintiffs, and apellee in the first suit was defendant, and in the other,  James Hord, Thomas
Brooks and James Withers  “ excors’ “ and devisees of James Hord, dec’d  were plaintiffs, and the apellee in the
second suit wasdefendant. For reasons appearing to the COurt, the decrees entered in these causes on yesterday are
set aside whereupon came the parties, by their counsel, and the court havingmaturely considered the transcripts of
the record of the decrees aforesaid, and the arguments of counsel is of opinion that the marriage promise in the
Bills mentioned, being sufficiently  proved by the testimony , and not being shown to have been abandoned in the
part of the said James Hord, dec’d, the apellants are entitled to recover one fifthe, or a child’s part, of all of the
estate, real and personal, to which the said Simon Miller, was  entitled at the time of his death, including what may
have been held by any person or persons claiming as volunteers under him; and that  an account thereof ought to
be taken, under the direction  of the Court of Chancery; including in the same, the lands, negores and other
property given by the said Simon Miller to the appellee or to any of his other children, the said James Hord, dec’d
being included at their  respective values at the time, the same being severally made, that standard of value being
applicable to the lands given, under the peculiar circumstances of this case and including also the bond of  the
appellee to the said Simon Miller, in the deposition of Killis Hord mentioned unless the same shall be shown to
have been paid, or otherwise, sastisfactorily discharged; and that one fifth part thereof ought to be decreed to the
applellants, includsing the advancements of land and negroes to the said James Hord dec’d, as proved by the
testimony, but whereas it is alleged by the appellee, that he was a bona fide purchaser of the eight hundred acres of
land in the proceedings mentioned, by having been induced by the said Simon Miller and his family, and to render
to him  and them, various and important services, and that he has in consequence thereof made  thereon  vakuable
and extensive improvements, and that the appellee was a purchaser of other land ankd certain slaves of the said
Simon Miller;it hterefore shall be lawfull for the said Court of Chancery to enquire into the facxt of such purchases
respectively,and whether the same were bona fide and for a fair consideration, and if it shall thereupon be found
that such purchases were made by the appellee as aforesaid, the property so found to have been purchased shall not
be estimated as a part of the estate of the said Simon Miller, deceased; but in the event tht the contrary  shall be
found to be the case, and that no purchases have been made as aforesaid not any bona fide gift thereof; in the
lifetime of the said Simon Miller, decd, then and in that case the appellee


3rd day of October 1817- Commonwealth of Virginia to the Marshal’ of the Superior Court of Chancery for the
Fredericksburg District-
Greetings:  You are hereby  commanded to summon Thomas Humphreys, executor of  William Richards, deceased,
to appear in the Town of Fredericksburg, at the Clerk’s Office of the Superior Court of Chancery, to be directed by
law to be holden in said town, on the first Monday in January next, to “shew” cause, ............................

MARKHAM vs MARKHAM  LAWSUIT:
This suit concerned  several slaves  that were  gifts to the daughters of Simon Miller, specifically, Alice
Markham, who died  1775. Although it is part of a different law suit, it deals with depositions of the same people
involved  in the Hord vs Miller/Richards suit and  was going on at the same time.

23 August 1806- Deposition of Mary Hord, aged about 69- at the house of John West in Stafford County, Va.-
“A daughter of  the late Simon Miller of Stafford County, Va.” and “Whole sister  of the mother” of  William and
Lewis Markham. She said her father gave a negro to each of his son in laws upon their marriage.
In 1786 Mr. Thomas  Strother  who married on the deponant’s sisters was about to go to Kentucky and he asked
Mr. Miller if his gift to him was without resercvations and Simon Miller  acknowleged  the slave was a gift.

23 August 1806- Deposition of James Hord- aged 35- at the home of John West- stated “ about 20 years ago when
Mr. Thomas Strother decided to move to Kentucky, Mr. Simon Miller told him that he [Miller] had no claim to the
negro given him. That Mr. Miller had given each of his married daughters a nego when they married”, viz: Mrs.
Strother, Mrs. Hord and Mrs. Markham.

21 November 1807- deposition of Eliza Richards- aged 53- a daughter of Simon Miller, deceased, late of Stafford
County, Va. She stated that “ she was under the impression that the descendants of the slave given  by Simon
Miller to John Markham upon his intermarriage with Alice, daughter of Simon Miller, were to go to the children
of the said Alice upon the death of John Markham and that John Markham had indicated to her that this was his
pleasure and intention”.

21 November 1807- Deposition of James Richards- aged 32. Taken at the house of John West in Stafford County,
Va.  He states at the time that John Markham sold the slaves , Mr. Simon Miller, the father in law of John
Markham, “ was a very old man and never left his own house”; however, Mr. Miller heard about the sale of the
slaves and took John Markham to task about it. Markham smoothed it over, and  Mr. Miller   never  knew  the
differencce. [ slaves in question would have issue from the slaves given to Alice Miller , wife of John Markham, as
a wedding gift from Simon Miller to his daughter ].

08 October 1808 the deposition of PeterConway, taken in Fauquier County,Va. who describes himself as a brother
in law  of John Markham, dec’d..
Question: Do you recollect that it was reported that Mrs.Alice Markham was in a state of prgancy when she
married to the said John Markham, dec’d.
Answer:  I do not remember that it was reported at the time of her marriage, but I believe it was reported after her
child was born that it came before the usual time but how long before I cannot say.

09 May 1811 in the County of Stafford, the deposition of Mrs. Jane Markham, widow, aged 55 and upwards.  She
married John Markham in  April  1781.
 
 
 
 
 
 
 
 
 
 
 
 

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