The petitioners state that John Bate, Catherine's late husband, conveyed all her property into a trust for her exclusive use and named Richard B. Mitchel as trustee while they were living in Maryland. The petitioners cite that of the forty-three slaves listed in the deed, some were sold, some were brought to Kentucky in 1832, and some ran away. They request "that said Mitchel be removed as Trustee under said deed," and they "pray that each and all of said defendants be enjoined from selling or in anywise disposing of any of the slaves named in said deed or the children or Grandchildren of either of them until the further order of this court." In an amended petition, Wilson and Buckner state that Matthew Garrison is holding various slaves as his property. The petitioners seek a restraining order to prevent Garrison from disposing of the slaves and name him as a defendant to the original and amended bills.
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Repository: Kentucky Division of Libraries and Archives, Frankfort, Kentucky