In 1826, Mary R. Massie made a marriage contract with Joseph R. Leake. Massie had inherited property from her father in 1817, and the contract put the property into a trust so that "it should not be liable for the debts of the said Joseph S. Leake." Mary's mother Susanna Massie administered the trust until her death in 1835 and Mary charges that she and her property have been "at the mercy of her said husband & his rapacious creditors" since her trustee's death. In 1838, Joseph Leake sold two of her slaves, Kitty and her son James, to John A. Dailey. Dailey refuses to return the slaves, despite being told the details of the trust. Fearing that Dailey will take said slaves “beyond the borders of this state,” Mary seeks an injunction to stop him from removing them. She also asks that a new trustee be appointed, that the slaves be placed with a receiver, and that Dailey be compelled to pay hire on the slaves for the time he has possessed them.
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Repository: Noxubee County Courthouse, Macon, Mississippi