Treasure Chest Thursday~Bill of Complaint - The Children of William B. Eddins, Deceased Against His Second Wife, Mary and the Administrator of the Estate

This is a lengthy document and only a small portion of the transcribed document is presented within. William B. Eddins, my 4th Great Grandfather, was twice married, first to Nancy LNU, the mother of all his children and then about 1819 he married Mary LNU. 

William and Nancy had 9 children:

• Williamson Eddins
• Richard Eddins
• Gilly Eddins
• Alice Eddins
• William Riley Eddins
• Temperance Eddins
• Margaret Eddins
• Mary Jane ‘Jenny’ Eddins
• Esther ‘Espsey’ Eddins

 
"Wm Sellars & Wife & Others) Bill of
vs ) Complaint
Mary Edings James Knott )
Admor. of Wm Edings
South Carolina )
Cheraw District) To the Honorable the Judges of the said state Humbly complaining shew unto your Honors your orators and oratrixes William Sellers and Gilly his wife William Edings Richard Edings Riley Edings James Raley and Espsey his wife Moses Knight and Tempe his wife Roland Sellars and Margaret his wife and Emanuel Adams and Aley his wife that William Edings being a widower sometime in the year of our lord one thousand Eight hundred and made proposals of Marriage to Mary she then bein a widow and as they were both ad­vanced in years and no issue likely to arise from the Marriage It Was mutually agreed that the mother of them by virtue of the said marriage should acquire at any time afterwards any right title or interest In the estate of which the other was then seized and possessed that the said Mary shortly afterwards consummated the said marriage agreement which your orators and oratrixes aver he would not have done without having had the said agreement reduced to writing and signed by the said Mary & himself if the said Mary had not given him the most solumn pledges and assurances that she would faithfully on her part perform the said agreement And your orators and oratrixes further shew unto your Honors that the said William departed this life sometime in the year one thousand and Eight hundred and twenty two intestate leaving his said widow your orators William Edings Richard Edings and Riley Edings and your oratrixes Aly Adams Gilley Sellars Espsey Raley Tempe Knight and Margaret Sellars and Jenny Knotts the wife of James Knotts his sons and daughters surviving him & who are your orators and oratrixes are advised his heirs at law and your orators and oratrixes further shew unto your Honors that the said William Edings at the time of his death was seized and possessed of a plantation or tract of land containing about Eleven hundred acres Eleven Negroes & a large stock of provisions horses cattle hogs sheep and plantations tools that settlers of administration on the Estate of the said intestate was granted by the ordinary of Chesterfield district to James Knotts who possessed himself of the Estate of his intestate and has sold all the stock of provisions and all the personal Estate Except the negroes who were hired out during the present year by the said James and your orators and oratrixes further shew unto your honor that they are desirous of possessing and enjoying In severalty their respective shares of the Estate of the said William Edings and have applied to this said Mary to have her relinquish all claims on the said Estate and to the said James Knotts to have him account for his administration and suffer the Estate in his hands to be divided All which reasonable requests they have refused to comply with in tender consideration where of and because your orators and oratrixes have no Adequate relief at common law to the End that the said defendants may fully true and perfect answers make to all and singular the premises that the said James Knotts may be compelled to account that your orators and oratrixes may have a writ to divide the said Estate among those who by law are entitled to the same and such other relief as the nature of their case may require may it please your Honor to grant them a writ of subpoena directed to the said Mary Edings and James Knotts requiring them to appear before your Honors in the court of Equity for Cheraw District to ansure to the premises and to a bide and perform such decree as your Honor shall see fit to make & they will ever pray
                                                                                       Evans Cross sol

William B. Eddins died about November 1822 leaving his second wife, Mary, and all his children surviving him.
 
“William departed this life sometime in the year one thousand and Eight hundred and twenty two intestate”

This statement can be found in the above document and is highlighted in red. Also, the minutes of the Deep Creek Church contains a statement on his death. From the Anson County Genealogy Society Newsletter, dated Spring, 2005.
William was attending in 1810 according to the minutes and he died in
November of 1822 between the 1st and the third Sunday of the month. The
church met at the Gulledge Meeting House on the first Sunday in November, 1822 and William was not among those meeting and no mention was made of his death. But, the church met at Deep Creek the Saturday before the third Sunday in November, 1822; and it was reported that William had died.

The first date within this 7 page Bill of Complaint is 29th Novr 1823. The Bill of Complaint was definitely active in the years 1823 and 1824. 
 
The essence of this “Bill of Complaint” was that:
1. William Edings at the time of his death was seized and possessed of a plantation or tract of land containing about Eleven hundred acres Eleven Negroes & a large stock of provisions horses cattle hogs sheep and plantations tools…
2. That the administrator, James Knotts, has possessed the estate, sold off the assets and that they are desirous of possessing and enjoying In severalty their respective shares of the Estate, which up to this point have been denied them.
3. have applied to this said Mary to have her relinquish all claims on the said Estate and to the said James Knotts to have him account for his administration and suffer the Estate in his hands to be divided All…
 
 
 
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[1] This document was originally discovered and transcribed in 1985 by Burton Ray Knotts a great, great grandson of James Knotts and (Mary) Jane ‘Jenny’ Edings.