To the Hon. John W. Burton, Chancellor presiding at Winchester Tennessee:
Your petitioners H.W. Partin a citizen of Franklin Co., Tennessee, and Samuel Baker a citizen of the state of Alabama, would respectfully show unto your honor
that on the 16th of December 1880 they filed in your Honor's court their original bill against George Baker and others, for the purpose, among other things, of having certain lands in Franklin Co., Tennessee sold for partition.
Under said bill was sold a tract of land for partition of 147 1/2 acres more or less, situated in Franklin Co. Tennessee, adjoining the lands of George Thomas on the east--bounded on the North and West by H.W. Partin, and on the south by the lands of John Wilder. This land belonged to Abner Baker who died in said county in the month of November 1880 intestate and without issue.
The complaints and defendants in said bill, are the brothers and sisters, and half brothers and sisters of said Abner Baker, deceased, except said H.W. Partin who owned then the undivided interest by purchase of William Baker Jr., J.J. Baker and H.P. Baker, who were full brothers of said Abner Baker deceased.
Petitioner now show your honor that in November 1880 said William Baker Sr. died intestate in Franklin Co., Tennessee, the owner of sixteen acres of land lying in civil district no. 9 of said county and lies on the southwest corner of the above described 147 1/2 acre tract. Through a mistake it stated in said bill that he had nothing at his death, and it was overlooked by inadvertence to have said sixteen acres embraced in said bill for partition by sale. The widow of said William Baker Sr., Pherbe Baker died intestate a short time after his death, in said county, intestate.
All of their heirs at law are set out in said bill, and were before the court in said cause of Samuel Baker and H.W. Partin and George Baker and others is still pending in this court.
Petitioners further show your honor that they to-gether with the defendants named in the caption of said bill and the owners of said land, and that they are entitled to the same as follows adjoining the lands of George Thomas on the east, on the North and West bounded by the lands of John Wilder and continuing one hundred forty seven acres and one half more or less, the deed to which will be filed on or before the hearing of this case as Exhibit 'A' to this bill.
Said William Baker Sr. the ancestor, left a widow whose name is Pherebe Baker a citizen of Franklin County Tennessee and she with certain of said minor, are now in possession of said tract of land and she is now claiming dower out of said tract of land and a homestead in the same, as the widow of aforesaid William Baker Sr. decd. Said Pherebe Baker is the second wife of said William Baker Sr. decd. and the mother of the 2nd set of children of said Baker as named in the caption.
Complainants further show that they together with the defendants as named in the caption are the intestate and leaving complainant Samuel Baker and defendants to this bill as stated, Except George Taylor and George Wileman, together with H.P. Baker, J.J. Baker and William Baker as his children and heirs at law. he had nothing at his death, having died intestate. One week afterward, Abner Baker died, never having married and leaving no heirs and intestate, both said William Baker and Abner Baker having died in Franklin Co., TN in the month of November 1880.
Abner Baker was the son of said William Baker and left the parties herein before named as his brothers and sisters and half brothers and sisters. Except Complt. H.W. Partin who is the owner of the undivided interest by purchase of William Baker Jr., J.J. Baker and H.P. Baker. who are full brothers of said Abner Baker deceased. At the death of said Abner Baker he was legal owner of a tract of land situated in the 9th civil district of Franklin County Tennessee and bounded as
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Sources: Vera Baker Barnes; Estate settlement of William Baker; census records
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