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To the Honorable Bromfield L. Riley one of the chancellors for the
State of Tennessee at Carthage presiding.

The Bill of complaint of Benjamin
Arendell, Administrator for Mrs. Lizza Gilliam deceased
Elizabeth Arendell, Abram Davis and wife Zilla, Rebecca
Cooper, John A. Lyons and wife Matilda, Martha
Flowers, all citizens of Smith County, Tennessee against
Harris Gilliam and William Gilliam,
Heirs whose names are unknown, all citizens of
the State of Arkansas.

{Humbly} complaining your Orators
and Oratrixes would respectfully show you Honor that
in the month of August 1852 Mrs. Lizza Gilliam
departed this life intestate in Smith County Tennessee
and that at the November term 1852 of the{ Worship-
ful County Court of Smith County} your Orator
Benj. Arendall was duly qualifed as the Admin-
istrator of her estate. They further show your
Honor that she left as her request that her legal heirs at home
her children, Zilla who married Abram Davis,
Rebecca who married John Cooper [who is now dead],
Elizabeth who married Benj' Arendell, Matilda who
married John A. Lyons, Martha who married
William Flowers [who is now dead]. Harris Gill-
iam and William Gillum who is now
dead--[seven in number and all but two of whom
now reside in Smith County.] They further show
your Honor that their mother the said Lizza
Gilliam did sign and promise of the follow-
ing negros, towit, one negro woman named Ceclia
age about 35 years-a girl named Patience age 11
years Primus a boy about 8 years & Mary
a girl about 2 years which was all her
property with the expection of some little few
articles of household furniture of but little if any
value. They further show your Honor that
the estate was indebt to a small amount
an that there is no means by which to pay said
debt, except the negro's, and that said negro's
are so situated that a division of them between
heirs is entirely impractable.

Your orators would further most re-
spectfully show Your Honor that more than
twenty years ago their brothers left the county (and went to Arkansas) and
took no care or interest in the support of their
mother was poor and unable to support herself
without assistance and that for mine either
the last five years of her life she was entirely
helpless and unable in anyway provide for
herself--that her negro's were of such a
character as to be of no value and your orators
for a great many years have been at much trouble
and expensive in maintaining and supporting this
mother, who has been repeatedly heard to declare
before her death that she intended your
orators should have all her property at
her death, but they show Your Honor that
she was called away without making a will
and they are forced to apply to Your
Honor to do them that justice which their
mother intended should be done

Your orators and oratrixes further shows
your Honor that said negro's are worth
twelve or fifteen hundred dollars
and that said Harris Gilliam is a
citizen of Arkansas and are informed
that the said William Gilliam has departed
this life in Arkansas to which state he [was]
many years ago and has left two or three
heirs whose names are unknown.

The [premises* considered] your orators
and oratrixes pray your Honor to order publication
to be made making said non residents defendants to the
will and upon the hearing they pray your Honor
[wil order] a sale of said negro's and an allow-
ance of twelve hundred dollars to your orators
out of the proceeds of the sale after paying the debts
and expenses of their suit and grant unto your
orators and oratrixes all such other and general
relief as they are in equity entitled and as in duty
[bound they well can pay.]


Transcribed By Judy Bell & Diane Surtees

Transcriber Note: [premised] it means --now that we have
told you our side--something like, outlined or annotated.

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