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Locality Shenandoah Co
Index Number 1789-006
Original Case Number NONE
Plaintiffs P1: SOLOMON COMBS
Defendants D1: GILBERT COMBS
Surnames COMBS
Wills NONE
Plat? NO
Scanned Images YES (65 Pages)

Page 1

Cover Sheet

Solomon Combs vs Gilbert Combs Chancery Causes Shenandoah Co

Page 2



Bill in Chany

Nov 1n. 17844 attd for _____?
May Court 1785
Ans is as filed & Contd
August 1785 Rept?
May 1786 Contd for
Return of depos.
June Contd on form
Rule. July Suma
Aug. 1786 Same
~ Sept Same
Nov Contd on former
Jany 1787 Same
Feby Same ~
March 1787 Contd
April Contd ~
May ____? ___? for ____?
Set for hearing
Augt Court 1789 _____? for
Deft and appl on prayer of Compt

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To the worshipful the Court of Shanando
in Chancery now sitting humbly com
-plaining therewith to your worships your
orator Solomon Combs that your orators
grandfather Robert Combs deceased did in
his life time sometime about the year
make an agreement with your orator that
if he would leave his Father and come and
live with him and render him services ne
=ceƒsary to age & take care of him that he would
at his desease give him the tract of land
in which the your orator’s Grandfather
then lived containing acres upon
which agreement your orator went to live with
his aforesaid grandfather and behaving him
self in the most dutiful and respectfull
manner did render him the sireius neceƒsary
_____? taking the greatest care of him for
the span of year. during all
which time the old gentleman was very
well pleased with your orator and often
expressed his satisfaction and renewed his
promise of giving him the land well knowing
that the laboring I had undergone in his fervice
and for his use were equal to value of the land
for which your orator never charged any price
or was received any satisfaction but expected the

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complesion of the bargain aforesaid in due time
the deft to this bill
But a certain Gilbert Combs ^ coming from
the Jersies and quartering? upon the old gentleman
when age had rendered him extremely feeble
in body and mind found means to create a
difference between your orator and the old
Gentleman or rather to make his grandfather
angry with your orator (for your orator would
never diffe doffer with his aged parent and
yr orator
procured your orators dismiƒsion after ^ in was
driven off the poor old Gentleman suffered
exceedingly being in his latter day eaten yet
alive by the maggots for want of necefary care
when so infeebled he could not help him self
in this miserable condition the day before
the old gentlemans death he was raised tho
in the act
they expected he would expire ^ to sign an
instrument of writing to convey the land
so faithfully earned by your orator to the
defendant Gilbert Combs that sofar from
being able to act or act or think for himself the
pen was stuck into his hand now and only
least he should expire before it was perfected
this was your orator deprived of his land which
so justly should have been his as for this irritated
contrivaner? could deprive him all which
actings and doings are contrary to equity and

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good conscience and for as much as your orator
is redemless by the strict laws of the Comm law
and only and properly relaivable by in this---
Court of equity when all matters of fraud
is inquired into and fore as much as the sd
Gilbert Combs the defendant to and with others
confidirating the promises afores aid transacting?
whom your orator pray when discovered may
be made deft to this his bill of complaint wth
apt words to charge them & to the end therefore
that the said Gilbert Combs may upon his
corporal oath true and perfect answers make
to all and singular the promises as fully as if
the same even here in again repeated and in=
=terragated and the _______________ ___ by
adverse of this worship Court to surrender
up the Fradulent conveyance as beforesaid
obtained and that the land he decreed your
orator according to the contract wth his
Grand father and that the
heir at law who you orator pray may be
made a defend ant to this his bill of Complaint
for that purpose may be com pelled to convey
the same_
May it please your worships to
grant unto your orator the Commonwealth map?
gracious writs of _____? to the sd Gilbert Combs
directed commanding etc. Copd June 1787
Rooks for Compft

Page 6

Shanando County ___?
May Court 1785
Sworn to in Open Court
Test JWilliams CISC

Page 7

The Answer of Gilbert Combs Defendant to the
Bill of Complaint of Soloman Combs

This defendant saving and
reserving to himself now and at all times
hereafter, all and all manner of advan
tage of exception to the manifold un:
certainties untruths and imperfections in
the complainants said Bill of Complaint
contained: for answer thereto, or to so much
thereof as this defendant is advised is
material or neceƒsary for him to answer
unto he answereth and saith that he
knows not of any such agreement between
the said complainant and his grandfather
Robert Combs as in his Bill is set forth
on the contrary he has heard and expects
to prove that the said Complainant lived
with his grandfather as a Cropper and
received a share of the Crops raised on
the Plantation as a reward for his
Services, this Defendant devices, that he
iniated any difference between the said
Complainant and his grandfather or that
he procured his dismiƒsion, on the contrary
he has been informed and believes that
circumstances was entirely owing to the
unnatural and cruel treatment of the
said Complainant which rendered that
Life grievances, which age alone would
have rendered burdensome. This defendant
further answering saith that in the Month
of December one thousand seven hundred

Page 8

and eighty_ he left the State of New Jersey the
place of his birth and residence to go to Carolina
that on his way he was informed of a meƒsage
sent to Thomas and Martha Combs this defendts
Parents by the said Robert Combs who was
this defendants grandfather informing that
if they would send one of their sons to take
care of him in his old age, he the said
Robert Combs would settle on him the Estate
which he had reserved for his daughter
Martha Combs aƒsigning as a reason the very
undutiful and unnatural treatment of the
said Complainant this defendant then
proceeded to his said Grandfathers house
where he arrived on or about the 21st of the
said month of December. He found the old
gentleman in a situation truly pitiable.
He expressed great joy on this defendants
arrival aƒsured him of the truth of the
meƒsage he had heard, informed him in
very affecting terms of the brutal behavior
of the complainant and correctly solicited
this defendant to lay aside the prosecution of
his journey and to remain with and take
care of him in his ------- declining
age promising to make this defendant ample
recompence if his Estate both real and
personal were sufficient to recompence him
this defendant more influenced by the ties of
nature than the prospect of enjoying the
Estate undertook the charge and behaved
with filial duty and attention toward the
old gentleman to the day of his death_
This defendant further answering saith that
same true in the month of April following
the said Robert Combs was seised with

Page 9

a disease which in the end proved mortal
that apprehensive of the conveyances he was
desirous of completing his contract with this
defendant and desired him to collect some
Neighbors to Witneƒs a deed for that purpose?
which deed was executed on the 27 of the said
month of April in the presence of Ferguson
Cron John Denton and others. the deed was
drawn by this defendant and mentioned that
in consideration of natural affection be con
veyed to this defendant all his Estate real
and personal the said Robert Combs was
at the time in a torn state of xxxx body
but in his perfect senses_ This defendant
showed said deed to a lawier, who conceived
it to be informal_ and at the desire of this
defendant drew another for the Land in question
was executed on the first of June thereafter and
which has sence been proved and recorded
the said Robert Combs was at that time very
feeble, but retained his proper senses, and
fully understood what he had done
And this defendant denies all and all
manners of C unlawful combination and
Confidenacy? in the Complainants Bill charged
there is
against him, without that ^ any other matter
or thing in the Complainants said Bill of
complaint contained material or effectual
for this complanant defendant to make
answer unto, and not herein and hereby ^
answered unto. confeƒsed or avoided travared?
or denied is true to the knowledge and belief
of this defendant. All which matters &
things this defendant is ready to aver
maintain and prove, as this Honorable
Court shall award and humbly prays to
be hence dismiƒsed with his unreasonable
Costs and charges in this behalf most wrongfully

White for Deft Copied June 1787

Page 10


Page 11

The answer of Job Combs to a bill of complaint
exhibited against him & others by Solomon
Combs sayth that he confeƒses that a
bargain For an arbitrator?? between the complainant
and Robert Combs as in the bill set forth
that the complainant left this defendant
with the leave of this defendant and
lived with his grandfather as in the bill
set forth and this defendant acknowledges
the facts in the bill set forth as are true
and is ready to execute the deed prayd
for if it be the desire of the worshipfull
Court and this defendant pray to be
Dismiƒsed Etc.

August the 26th 1785 Copied June 1787
Sworn to before me
John Anderson

Page 12




Page 13

The Commonwealth of Virginia to Abraham &
George Keller & Abm M. Roy of Shanando County Gent
Greeting. We Command you Know ya that we trust
ing to your fidelity & Provident Circumspection
in deligently Examing Sylvens Odell as Wit
neƒs as well in behalf of Gilbert Combs Deft
as in behalf of Zir Combs & the Plf. we command you
that at such certain days & Places as you or any
two of you shall appoint you aƒsemble yourselves
together & then & there deligently examine upon
the holy Evangelist of Almighty God touching
such things as shall be then & there objected by
either of the Parties aforesaid & When you have
received his Examination that you send & certify
us thereof in our County Court of Shanando
Distinctly & Plainly under Your hands
& seals in enclosed sending there thee this writ
witneƒs Thos. Marshall Clerk of our Cl Court
at the Courthouse This 28th day of Augt 1784
& the 9th Year of the Commonwealth
Thos. Marshall

Page 14




Page 15

The Commonwealth of Virginia to Abraham
Keller & Abraham Mc Roy & George Keller Gent
Greeting. Know ye that we trusting to your fedi_
lity & Provident Circumspection in deligently
examining such witneƒses as may come before
you for that purpose as well in behalf of Gil-
bert Combs Deft as in Solomon Combs Plft

We Command you that at such certain days two
at Places & Places as you or any ^ of you shall appoint
you aƒsemble youselves together when & where di
ligently Examine upon the holy Evangelist of
Almighty God touching such things as shall
be then & there objected by either of ish sureter??
aforesaid & when you have and when you have
Received their Examination that you send
& Certify us thereof in our County Court of Sha
nando distinctly & plainly under your hands
& seals enclosed sending then there this with
witneƒs Tho. Marshall Clerk of our sd
Court at the Courthouse this 28th day of Augt
1786 & the 9th Year of the Commonwealth
Thos. Marshall

Page 16




Page 17

The Commonwealth of Virginia To
Gentlemen Greeting
Know ye that we trusting to your fedility and Provident &
circumspection in deligently examining of Joseph
Combs, Thomas Roberts and Susanna Roberts
of the State
of New Jersey as witneƒses well in behalf of Gilbert
Defendant as in behalf of Solomon Combs Pltf
we Command you at such Certain dais and places
as you or any two of you shall appoint you aƒsemble
your selves to gether and then and there deligintly
examine upon the holy Evangelists of Almighty God
touching such things as shall be then and there objected
by either of the parties aforesaid and when you have
received this examination that you send and
certify us thereof in our County Court of Shanando
distinctly and Plainly under your hands & Seals
inclosed sending then there this writ witneƒs John
Clerk of our said Court at the Courthouse
This twenty fifth day of August 1785 and the tenth_
Year of the Commonwealth John Williams

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to take

(Source: Solomon Combs vs Gilbert Combs, I.D. 1789-001, Library of Virginia Archives, Chancery Court Index: County Name, original images from case file, abstracted, transcribed, and submitted by Myra Britt for Combs &c)

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