Daniel and Behethlan Bird join their trustee Smith Simpkins in seeking the recovery of slaves. The petitioners report that Whitfield Brooks executed a deed of trust in 1845, whereby eighteen slaves were conveyed to the said Simpkins “in trust to and for the use benefit and behoof of your orator Daniel Bird and his wife your oratrix Behethlan Bird during their joint lives.” The Birds explain that, when their son Daniel B. Bird married, they felt “a proper interest in his welfare and desiring to aid him all that they could, proposed to let him and did let him have upon loan” certain slaves. The petitioners aver that “the terms of the said loan were well known” and that they had made “similar loans of the services of other slaves ... to other of their children.” Citing that the said Daniel B. has died, the petitioners charge that James Jones, administrator of his estate, refuses to return the slaves to the petitioner. Simpkins and the Birds ask the court to order Jones to return the slaves and to pay a "reasonable compensation for the services of said slaves" since the time they came into his possession.
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Repository: Florida State Archives, Tallahassee, Florida
