1869 Estate Settlement of Alfred Baldwin
Transcribed and published from original by Myrtle Bridges
State of North Carolina, County of Richmond in Probate Court. Petition to make real estate assets for the 
payment of debts. Jesse A. Baldwin & Frank T. Baldwin Admins. of Alfred Baldwin, deceasd, Plaintiffs, vs. 
Rebecca A. Hines, Clementine L. McNair, D. A. Bruton , and Selina H. Bruton, Robert H. Hamer, and wife 
Delina H., Dicy J. Baldwin and Sarah J. Baldwin, Preston M. Baldwin, Daniel B. Baldwin, minors.  
The plaintiffs complaining allege: 

1. That Alfred Baldwin  died in the County of Richmond, in August 1869, intestate, and, sometime thereafter, 
during the same year, letters of administration on his estate were duly issued to the Plaintiffs, Jesse A. 
Baldwin & Frank T. Baldwin, who thereupon took charge of said estate, and proceeded to administer the same.
2. The persons entitled to said estate, are Rebecca A. Hines, in Richmond County, and Post-Office at 
Covington; Clementine L. McNair, who resides in said County, with Post-Office at Rockingham; D. A. Bruton 
and wife Selina H., who lives in said County, with Post-Office at Covington; Robert H. Hamer & wife Delina, 
and Dicy J. Baldwin, who live in Marlborough Co., SC, with P. O. Bennettsville; Sarah J. Baldwin, Preston M. 
Baldwin & Daniel B. Baldwin of Richmond Co., with P.O. at Rockingham, and the plffs, Jesse A. Baldwin & Frank 
T. Baldwin.
3. That all of the said persons are of full age, except Sarah J., Preston M. and Daniel B. Baldwin, who are 
the children of Daniel W. Baldwin, deceased, who was a son of the intestate, and said three minors have no 
guardian, and reside with their mother, who is now the wife of James H. Robinson.
4. That the personal estate which came into the hands of the said administrators, primarily liable for the 
payment of debts and costs of administration, amounted to about the sum of seventeen hundred dollars, which 
has been entirely consumed in the payment of debts and costs of administration; and debts are still outstanding
against the estate amounting to about three thousand dollars, for the payment of which it will be necessary 
to resort to a sale of the real estate.
5. That the intestate left the following real estate, all in Richmond County, which descended to his heirs 
above named, subject to the payment of debts, and to the dower of his widow: The tract of land on which he
lived, consisting of about 1,050 acres, on which the dower of his widow was laid; a tract of 80 acres on 
the waters of Mountain Creek, adjoining the lands of Rebecca A. Hines, D. A. Bruton, and others, known as 
Bostick land; and an equitable one-fifth interest in a tract of 244 acres lying on Little Mountain Creek, 
bought by Alfred Baldwin and Jesse A. Baldwin from Britton Hart.
Wherefore the plaintiffs ask the Court for a decree empowering them to sell the said lands, upon such terms 
as the Court may think fit, and apply the proceeds to the pay-ment of the debts existing against the estate, 
and the further charge of administration, and that Benjamin W. Covington be appointed guardian ad litem of 
the infant defendants, and that a summons and a copy of this petition be served upon each of the defendants 
who reside in this State, unless they shall accept notice thereof, and be served by publication the defendants 
who reside out of state. J. A. Baldwin & F. T. Baldwin.  Sworn to and subscribed before me this 31st day of 
Jan'y, A. D. 1877 D. Stewart CSC.

I do hereby certify that the foregoing is a true copy of the original petition in this cause filed in this 
office. Witness my hand and official seal, Feby. 1877.  D. Stewart C.S.C. and F. Sandford, Depy.

North Carolina, Richmond County, Probate Court Nov. 10th 1879.  Petition to make real estate assets. Jesse 
A. Baldwin & F. T. Baldwin Admins. of Alfred Baldwin dec'd vs. Rebecca A. Hines & others.

After due notice to parties I this day proceeded to take an account of the administration of the estate of 
Alfred Baldwin dec'd by the plaintiffs - they with their counsel 
R. A. Johnson, Esq. and John W. Cole, Esq. counsel for defendants being present. Jesse A. Baldwin, being 
duly sworn says: We sold the personal property of our intestate on a credit of six months and charged 
ourselves with the whole amount bid on said property and accounted for the same. The amount of sales of 
said property is $1662.50.  We collected $2.50 of M. Clark and 50 cents of Bob Garret, $15 County claims, 
and found cash on hand $43. This was all the collections made by us. There are no debts other mentioned in 
our inventory which were collected, or could have been collected by us. Most of these were small, out of 
date and the parties were insolvent and are still insolvent. We brought suit on some of them but could not 
do anything. Most of the debts were of as much as ten years standing and many of the parties have gone away 
and we have been unable after trying to find there whereabouts.  On the 30th Sept. 1875 we filed an annual 
statement showing disbursements made by us amounting to $2322.57.  We credited ourselves with no commissions 
on receipts and disbursements in this account.  Since that date we have paid out the following sums.  

Taxes, $51.69. On Joseph Capel's note $72.40. The note not being paid in full, it is yet in Capel's hands. 
John A. Long costs to be applied as we might direct, $25. W. R. Pankey and Mary B. Pankey, $150. I do not 
recollect of any other cash money paid out by us since 30th September 1875. (Defendant excepts to testimony 
as to all matters transactions or communications between Jesse A. Baldwin affiant and F. T. Baldwin and Alfred 
Baldwin upon which to base a claim against the estate of Alfred Baldwin or to Jesse A. Baldwin proving an 
account against the estate of Alfred Baldwin in his own favor)  The debts outstanding against the estate 
of our intestate are as follows.

J. A. Baldwin paid L. W. McLaurin tax July 8, 1864, $15, paid J. A. Long 20th Sept 1864 $33.72, paid L. W. 
McLaurin Dec'r 31, 1863, $6., paid B. R. Webb 16th Mar. 1861, $42., paid G. B. Bingham 19th May 1860, $16.18, 
paid N. J. Covington 11th Dec. 1855, $6.07, paid J. H. Chappell 20th Jany 1858, $15., paid for boarding 2 
families of Negroes in 1864 & 1865, $155. I propose to prove the material facts in regard to the above claim 
by record evidence and the evidence of other persons.  

J. A. Baldwin paid Tom Swift's note of A. Baldwin, 1865, $68.80. I paid the amount in good money by a note 
I had on Swift given before the War. This debt was contract-ed by Alfred Baldwin in 1860.

J. A. Baldwin paid A. Baldwin, of which I have memo, 1855, $100, and another for $26. Paid A. Baldwin for N. 
Pankey, $215, paid John Webb $39, paid Mrs. Pankey $224, paid  Jane Crouch $5.95, paid N. Baldwin $33, paid 
A. Baldwin $96.80

Cause adjourned until tomorrow morning.  Tues. Nov. 11th 1879. Hearing this cause resumed according to 
adjournment. Receipt of Tom Swift filed for payment made to him for A. Baldwin by J. A. Baldwin

I paid for A. Baldwin also to Tom Garret in about 1860, $20, John Webb about 1861 or 1862, $187, Sam Crouch, 
1859, $25, Isaac Ewing, 1860, $18, Angus McDuffie, 1861, $90, Martin Pankey about 1855, $255. I paid to A. 
Baldwin Feby 1st 1861, $1339.34. I paid to A. Baldwin 1864 & 1864 taxes $1405. I paid A. Baldwin 1863 & 1864 
taxes for Chappel wards, $294, and from 1850 to 1859 inclusive for Chappell wards, $55.80.

Alfred Baldwin took out of our store to amount of $804.48 (half mine) $402.24.  J. A. Baldwin paid an 
attorney fee of $10.

The following are claims due F. T. Baldwin by A. Baldwin for vouchers or statement of which see envelopes.  
June 3rd 1868 paid for corn for A. Baldwin freight, $51.10, Note for J. A. Baldwin July 17th 1860, $100, 
note of A. Baldwin dated 21st Feby 1865, $90.34. These notes were given in renewal of an old note payable 
in good money. Revenue tax paid by J. F. Baldwin for A. Baldwin, May 24, 1867, $60.93. Taxes paid by F. T. 
Baldwin June 6th 1863, $280, and for 1864, $150, for work on mill, '65-6-7-8-9, $1442.90. Expenses of 
administration see vouchers, $19.20

The following are debts due other parties than ourselves.  Amount due Polly Chappel, now Mrs. Pankey, former 
ward as records will show, $275., note payable to Stephen Pankey 5th Jany 1861, $523.55, Gardner Bennet, 
1860, $15., Doctor's bill 1869, Nov. 22, subject to a credit of about $4, $32. (Signed) J. A. Baldwin. Sworn 
to and sub-scribed before me Nov. 11th 1879. D. Stewart CSC.

Hearing this cause is adjourned until 24th Nov. 1879. Continued to 29th, December 1879 by consent. The hearing 
of this cause resumed, the plaintiffs being present with their counsel, Messers R. A. Johnson & John D. Shaw. 
The defendants being present also with their counsel Messers Cole & Legrand. The plaintiffs offer in evidence 
the following vouchers. 

Receipt of John Shortridge, Shff. $114.22, dated May 10th 1871 (objected to)
Receipt of J. A. Long, Clk. for $3.10, Sept 25th 1869 (objected to)
Receipt of R. Bowden, auctioneer, $162., dated Nov. 15th,1869
Receipt of J. A. Long, clerk's fees, $1.55, dated Nov. 2, 1869
Receipt of R. S. Ledbetter, taxes, $117.68, dated Dec. 4, 1869
Receipt of W. D. Ussery , coffin, $150, dated Jany 1, 1870
Receipt of J. A. Long, clerk's fees, $3.15, dated Jany 28, 1870
Receipt of T. S. Ashe , Atty, $28.50, dated Nov 3, 1870
Receipt of R. S. Ledbetter, taxes, 4th Mar. 1870, $22.85 (objected to)
Receipt of Steele & Walker, Attys, 10th May 1871, $10.
Receipt of D. Stewart, Clk, Jany 1st 1872, $3.40
Receipt of S. T. Cooper , taxes, April 1st 1872, $34.29 (objected to)
Receipt of B. F. Simmons, Atty, $5.
Receipt of T. S. Ashe, Atty, dated 9th Nov 1872, $10.
Receipt of J. E. Capel dated 8th Dec 1872, $170.95
Receipt of John Snead dated Jany 4, 1873, $22.75
Receipt of S. T. Cooper, taxes, Oct 22, 1873, $15.76 (objected to)
Receipt of Parks Chappel note, Dec 22, 1870, $62.14
Receipt of Parks Chappel note, Dec 20, 1871, $25.00
Receipt of Parks Chappel note, Oct 15, 1873, $62.10
Receipt of S. T. Cooper, taxes, Oct 22, 1873, $17.19 (objected to)
Receipt of D. A. Covington note July 1st 1873, $1368.90
Receipt of S. T. Cooper, taxes 15th Apr, 1874, $16.50 (objected to)
Receipt of Z. F. Long , Shff, taxes, Apr 1875, $17.34 (objected to)
Receipt of Morris Chappell note, Jany 1st 1871, $48.15
Receipt of Morris Chappell note, Jany 24th 1871, $70.00 
Receipt of Capel & Parsons note, 21st Sept 1870, $6.20
Receipt of T. S. Ashe, Atty, Dec 14, 1871, $22.00
Receipt of F. T. Baldwin June 13, 1868, $51.10 (objected to)
Receipt of F. T. Baldwin note, Feby 21, 1865, $90.34
Receipt of J. A. & A. Baldwin note dated July 12th 1860, $100. (objected to)
Receipt of D. Stewart, Clk, Nov 1st 1879, $10 (objected to)
Receipt of Z. F. Long, no date, for $4.20
Receipt of F. Sandford dated Feby 3, 1878, $5. (objected to)
Receipt of A. C. Morrow, Rev. Col., May 24, 1867, $60.93 (objected to)
Receipt of A. Baldwin, Mar 16, 1861, $42.86 (objected to)
Receipt of  Thomas Swift , Jany 1st 1862, $68.08 (objected to)
Order of A. Baldwin dated Jany 23, 1858, $15.00 (objected to)

The defendants object to the allowing as vouchers any orders or due bills of Alfred Baldwin for the reason 
that there is no evidence that they were ever paid by J. A. Baldwin, and being of old date the presumption 
arises that even if they were paid as he is administrator of A. Baldwin that they came into his hands with 
his other papers and they are not relevant testimony.

Receipt of  Z. F. Long, taxes, Mar 6th 1878, $15.13 (objected to)
Receipt of W. R. & Mary B. Pankey dated Jany 7, 1876, $150. (Objected to on the ground that receipt is not 
in handwriting of signers.)
Receipt of  Steele & Johnson dated 12 Jun 1879, $10.
Receipt of J. A. Long dated May 11, 1876, $25. (objected to)
Receipt of J. R. Webb dated Dec 29, 1863, $87.
Receipt of J. R. Webb dated Dec 29, 1864, $100.
Receipt of T. Garret dated Dec 1860, $20.
Receipt of J. E. Capel dated Dec 16, 1872, $99.71
Receipt of J. E. Capel dated Jany 1st 1870, $25.50 
Receipt of L. W. McLaurin, taxes, Jany 18, 1864, $15.00 (objected to)

The plaintiffs exhibit the following claims against the estate of intestate which are unpaid. Account of  
A. H. Canedo dated 22 June 1869. Note signed by John N. McNair with A. Baldwin, security for $15., dated 7 
Mar 1859, credit $7. Nov. 17, 1859.

Jesse A. Baldwin & Franklin T. Baldwin, Administrators of Alfred Baldwin, dec'd, Plaintiffs against Rebecca 
A. Hines, C. L. McNair, D. A. Bruton & wife Celina, R. H. Hansen & Delina his wife, Dicy J. Baldwin and 
Preston M. Baldwin and Daniel B. Baldwin & Daniel B. Baldwin who are minors, and defend by Benjamin W. 
Covington their Guardian Ad Litem, Defendants.

B. W. Covington, Guardian Ad Litem for Preston M. Baldwin and Daniel B. Baldwin minor defendants herein 
answering says; 
1. That he admits the 1st & 2nd  articles of the complaint.
2. That he admits that Preston M. and Daniel B. Baldwin are minors and reside with their mother, but 
alleges that Sarah J. Baldwin since intermarried with A. H. Reynolds is over 21 years of age and resides 
with her husband aforesaid.
3. That he is not sufficiently informed as to the facts in regard to this allegation to either admit or 
deny the same, and holds plaintiffs to strict proof thereof.
4. That he is informed that Alfred Baldwin in his lifetime, during this last sickness signed sealed and 
delivered to Plaintiff, Jesse A. Baldwin to be delivered to his wards, the said Preston M. and Daniel B. 
Baldwin, a deed conveying to each of them 100 of the 1,050 acre tract of land described in the petition, 
which he is informed the said Jesse A. Baldwin has never delivered to them, but he demands that if it shall 
be necessary to sell any of the lands described in the petition to pay Alfred Baldwin's debts that the other 
lands not conveyed be sold for that purpose. And he alleges that Alfred Baldwin retained at the time of 
executing this deed other property fully sufficient to satisfy all his indebtedness, as he is informed.  
(Signed) B. W. Covington.

State of North Carolina, County of Richmond.  Personally appeared before me B. W. Covington, Guardian Ad 
Litem for Preston M. and Daniel B. Baldwin who being duly sworn says that the matters and facts set forth 
and stated as of his own knowledge in the foregoing answer are true, and that those stated on information 
he believes to be true.  (Signed) B. W. Covington.  Sworn to and subscribed before me this 24th Nov. 1879. 
D. Stewart, Clerk Superior Court.

J. A Baldwin being introduced testifies:  Millie & children were kept by myself during the latter part of 
1864 and all of 1865.  They belonged to B. Chappell's heirs and were let out to the lowest bidders by my 
father who was guardian. Also Fran and her children. The lowest bid for Millie and her children was $415., 
and for Fran and her children was $1150. A memorandum in handwriting of A. Baldwin as to the matters above 
stated proved by J. A. Baldwin, who swears he knows the handwriting of A. Baldwin, is offered in evidence. 
The defendants object to J. A. Baldwin proving any transaction between himself and his father, A. Baldwin.  
Also to the memorandum being received as evidence even if the handwriting of A. Baldwin is proved.  

I found this memorandum filed away among the papers of A. Baldwin after his death.  The original amount of 
a note held by Stephen Pankey against J. A. & A. Baldwin was  $403. With interest from 20th July 1860.  This 
note is not paid except the credits taken down before.  The receipt of Thos. Swift was for a note of same 
amount held by me that I surrendered to Swift.
A memorandum which I found among the papers of A. Baldwin after his death I offer in evidence as to these 
facts.  (Objected by defendants upon the grounds that there is no evidence that this amount was not paid 
referenced to J. A. Baldwin by A. Baldwin, except his own testimony which is objected to as incompetent.)
(Objected to)
I paid A. Baldwin's taxes in 1864.  I received $150. In the latter part of 1863 or early part of 1864 from 
F. T. Baldwin and applied it in payment of A. Baldwins's taxes.
(Objected to)
Baldwin was very much afflicted during the latter years of his life.  I attended to a good deal of his 
business for him during these years.

I know that F. T. Baldwin in 1869 did a good deal of work on A. Baldwin's mill for him and before his death.  
It was a considerable job.  I cannot say what it was worth.  F. T. Baldwin was in the army in 1865.  Admitted 
my best impressions as to what I have heard my father A. Baldwin say concerning a note signed by him and 
payable to F. T. Baldwin for $90.34 dated 21st Feby 1865. In that he said it was a balance of an old note 
dated before the War after deducting $150. for the hire of a Negro in 1864.  I do not know this of my own 
knowledge.  I have heard Frank complain of this in the presence of my father. He said he did not think his 
father did him right. J. A. Baldwin.

Sworn to and subscribed before me Dec. 29th 1879. Adjourned till tomorrow morning at 9½ o'clock. Tues. Dec. 
30th 1879.  J. A. Baldwin cross examined.  I do not recollect of having collected anything more as 
administrator of A. Baldwin than that stated in my examination in chief. My father did not have any notes 
against Samuel Crouch.  None such ever came into my hands. I collected no money of Sam'l Crouch as 
administrator. I had some notes against Sam'l Crouch in my possession which were payable to J. A. & A. 
Baldwin. I do not know how many nor the amount.  I surrendered one of those notes in exchange for a note 
on myself. I don't know the amount of this note. The principal was about $20. I don't recollect the date 
of this note. I got another note also in exchange for the note on Crouch. This note was against Sarah. The 
first note, I think was payable to Reddick Bowden . I don't recollect that I got another note due by myself
 to Reddick Bowden in exchange for the Crouch note. J. A. Baldwin. Sworn to and subscribed before me December 
 30th 1879.  D. Stewart CSC.

Cause adjourned to Jany 19th 1880, continued by consent to Jan 31st, 1880, continued by consent to March 
2nd 1880. J. A. Baldwin & F. T. Baldwin, Administrators of A. Baldwin, dec'd, Plaintiffs vs. R. A. Hines 
and Alexander Bruton, Defendants.

To the Superior Court of Richmond County, an appeal having taken in this action by the Defendants, R. A. 
Hines and Alexander Bruton in pursuance of notice given at the time of trial.  I do hereby certify and 
return that the following proceedings were had by and before me in said action.  On the 7th July 1880 at 
the request of the plaintiffs I issued a summons in their favor and against the defendants, which is herewith 
sent.  Said summons was, on the return day thereof returned before me at my office, and at the same time and 
place the parties appeared.  And upon the request and consent of both the plaintiffs and defendants the cause 
was continued until the 8th day of July 1880; at which time the parties appeared before me.  

The plaintiffs complained that they held the defendants note due 6 months after date with interest from date 
the 8th day of December 1869 for $120 with the following credits thereon, one credit on 23rd May, 1873 for 
$82.87 and second on 8th July 1880 for $27.75.  The defendants claim that upon some consideration in the 
settlement of Alfred Baldwin's estate that they were not to be held responsible  to the plaintiffs for the 
balance due on the aforesaid note. Both parties introduced evidence upon the claims so made by them, and 
after hearing their proofs and obligations, I rendered a judgement in favor of the plaintiffs and against 
the defendants on the 8th day of July 1880 for $60.09 and the further sum of $2.10 costs.  There is also a 
fee of $1 due me for making the return of this appeal.  I send herewith the note and summons belonging to 
the cause. Dated this 22nd Nov. 1880. (signed) W. F. Brookshire, J.P.

North Carolina, Richmond County. Petition for Partition. D. L. Reynolds & wife D. B. Reynolds & A. H. 
Reynolds, Guardian of D. B. Reynolds, A. H. Reynolds & wife S. J. Reynolds, H. H. Robinson & wife A. E. 
Robinson, Petitioners vs. Frank T. Baldwin, Robert Hamer & wife Dillie, Alex Bruton & wife Selina, Clemmie 
McNair, Rebecca Hines, Disa Baldwin, James Ingram, Mary Baldwin, David Bruton & wife Emeline, Lily Baldwin, 
Rebecca Baldwin, Jane Baldwin, Mary Bell Baldwin, Alfred Baldwin & Armon Baldwin, Defendants.

The petitioners above named allege:-
1. That Alfred Baldwin died intestate in the year 1869 seized and possessed of a tract of land in the 
Richmond Co., adjoining the lands of J. M. Hines, Harris Sadberry and others, containing about twelve 
hundred acres, all of which is now in the possession of the defendant James Ingram, except the dower of 
Clementine Baldwin, widow of said Alfred Baldwin, which is in her possession.
2. That said Alfred Baldwin died seized and possessed also of a certain other tract of land, which is in 
the hands of the defendant Baldwin, in said County purchased by him from Britton Hart by deed of conveyance 
registered in registers office in said County in Bk. 4, Pg.103, being the same purchased by said Hart from 
George Thomas by deed for a full and complete description of which reference is hereby made to said deeds.
3. That the said Alfred Baldwin left him surviving Clementine Baldwin his widow, and the following children 
and heirs-at-law, to wit: Jesse A. Baldwin, Frank T. Baldwin, Dillie Hamer, wife of Robert Hamer, Selina 
Bruton wife of Alex Bruton, Clementine McNair, widow of John McNair, Rebecca Hines, widow of Malle Hines, 
P. M. Baldwin, Disa Baldwin, D. B. Reynolds wife of D. L. Reynolds, and S. J. Reynolds wife of A. H. Reynolds.
4. That the said land descended to the said heirs as tenants in common.
5. That Daniel Baldwin, father of the female petitioners, D.B. & S.J. Reynolds, and a son of said Alfred 
Baldwin, died intestate in the year 1863, leaving him surviving the female petitioners, A.E. Robinson, since 
intermarried with J.H. Robinson and the said P.M. Baldwin, D. B. Reynolds and S. J. Reynolds, his only children
and heirs-at-law.
6. That the said P. M. Baldwin died intestate in the year 1882 leaving him surviving the said D. B. Reynolds 
and S. J. Reynolds, his sisters and only heirs-at-law.
7. That the said Jesse A. Baldwin died intestate in the year 1881, leaving him surviving the said Mary 
Baldwin, his widow, and the said Emeline Bruton, wife of David Bruton, Lily Baldwin, Rebecca Baldwin, Jane 
Baldwin, Alfred Baldwin, Mary Bell Baldwin, Armon Baldwin, his children and heirs-at-law.
8. That in the year 1871, the dower of said Clementine Baldwin, widow of Alfred Baldwin was duly allotted 
and set apart to her out of the said land, as may be shown by reference to the report of the jury , summoned 
for that purpose which report duly approved is now on file in Clerk's Office, in said County. The metes and 
bounds of said dower are fully set out in a paper writing hereto annexed, marked "Exhibit A" and asked to be 
taken as a part of this complaint. [Dower contained 301 acres ] 
9. That the female Petitioners, D. B. Reynolds and S. J. Reynolds, as the only representatives and heirs-at-
law of their father, said Daniel Baldwin and of their brother, the said P. M. Baldwin are entitled to 
one-eighth of said land.
10. That at the death of said Alfred Baldwin, the defendant Frank Baldwin was entitled to one-eighth 
of said land, Dillie Hamer to one-eighth, Selina Bruton to one-eighth, Clemmie McNair to one-eighth, Disa 
Baldwin to one-eighth, Rebecca Hines to one-eighth, and the said children of Jesse A. Baldwin to one-eighth; 
that they or their assignees are now entitled as herein set forth.
11. That the Defendants, Robert Hamer and Dillie Hamer are residents of the State of South Carolina, 
and that the Defendants, Rebecca Baldwin, Jane Baldwin, Mary Bell Baldwin, Alfred Baldwin & Armon Baldwin 
are infants without guardian as the petitioners are informed and believe.
12. That the Defendant, James Ingram, has purchased the interest of some of the said children in said 
lands as they are informed and believe.
13. Petitioners desire partition of lands, that they may enjoy their share in severalty.  

Wherefore the petitioners pray that they may have actual partition of said land under order of the Court, 
and for general relief.  Burwell, Walker & Tillett, Attys. for Pets.

D. L. Reynolds being duly sworn says that the foregoing petition and the facts therein set forth are true 
except those matters stated on information and belief, and as to them he believes them to be true.  
(signed) D. L. Reynolds.  Sworn to and subscribed before me on this 9th day Oct. 1883. S. T. Cooper, N.P.

North Carolina, Richmond County in Superior Court. Fall Term 1883. D. L. Reynolds & wife D. B. Reynolds, 
A. H. Reynolds & wife S. J. Reynolds, Plaintiffs, vs. Frank T. Baldwin, Robert Hamer & wife Dillie, Alex 
Bruton & wife Selina, Rebecca Hines, Clementine McNair, Disa Baldwin, Mary Baldwin, David Bruton & wife 
Emiline, Clementine Baldwin, Lily Baldwin, Rebecca Baldwin, Jane Baldwin, Alfred Baldwin Mary Bell Baldwin, 
& Armon Baldwin, the said Rebecca Jane, Mary Bell, Alfred & Armon being minors who defend by Guardian ad litem, A. L. McDonald and James Ingram, Defendants

The plaintiffs above-named complaining allege:-
1. That one Alfred Baldwin, late of the County of Richmond, during his lifetime was seized in fee of a 
tract of land in the said County bounded and described as follows. (description) containing 325 acres, 
more or less.
2. That on the 18th day of August 1869 the said Alfred Baldwin and wife Clementine H. duly executed to 
the fem. Plaintiffs, Sarah Jane Reynolds & Amelia Bell Reynolds, alias D. B. Reynolds and to their brother 
P. M. Baldwin a deed in fee, conveying said tract of land to them in fee simple. That P. M. Baldwin died 
on the 16th day of Dec. 1882 and the fem. plaintiffs are his only heirs-at-law, and are now owners of said 
3. That the said deed came into the possession of the Defendant, Frank T. Baldwin, and that while he was 
in the possession thereof and before the commencement of this action, the plaintiffs demanded the possession 
thereof from him, with which demand he refused to comply.
4. That the defendants, above named, other than the Defendants, James Ingram and Clementine Baldwin, are 
the heirs-at-law of the said Alfred Baldwin, and the Defendant Clementine Baldwin is the widow of the said 
Alfred Baldwin.
5. That the said James Ingram is in possession of the said tract described in the first article of this 
6. That he unlawfully withholds the possession of said land from the plaintiffs.
7. That as they are informed and believe, Ingram claims title to said land under some of the heirs of 
said Alfred Baldwin.
8. That the deed referred to in the 2nd  article of this complaint has never been proved or registered.
9. That the said Alfred Baldwin married the said Clementine Baldwin and acquired the said land before the 
year 1866.

Wherefore the plaintiffs demand judgement. (1) That the plaintiffs be declared to be the owners of said land 
in fee simple. (2) That said Frank T. Baldwin be compelled by 
a decree of this court to deliver the possession of said deed to the plaintiffs or that the plaintiffs have 
the possession thereof. (3) For the possession of said land. (4) For two thousand dollars damages for the
unlawful withholding and for the costs of the action.  (5) For such other and further relief as to the 
Court may seem right and proper. (Signed)  Frank McNeill, Burwell, Walker & Tillett, Attorneys for Plaintiffs.

Answer of guardian ad litem:  The Defendant, A. L. McDonald, Guardian ad litem for Rebecca Baldwin, Jane 
Baldwin, Mary Bell Baldwin, Alfred Baldwin, and Armon Baldwin minor Defendants, answering the complaint 
says that he has no knowledge or information sufficient to form a belief as to the truth of the articles 
set forth in plaintiff's complaint. Filed Sept. 13, 1886 by Z. F. Long, CSC & W. F. Long, D.C.

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