Bill of Complaint by Evalina Goodin

To the honorable the judge of the 15^th Judicial district, Your Orator Evalina Gooden admr and widow of Benjamin Gooden decd and Benjamin Gooden an infant and son of said Benjamin Goodin decd humbly complaining therewith unto your honor that the p_____ [can't read] Benjamin Goodin in his life time purchased of Alexander Gooden a tract of land containing 50 acres on Greasy Creek in Knox County for and at the price of $150 and paid him the purchase money, the said land has been surveyed by virtue of a Kentucky land office warrant No. 1789 on the 3^rd day of October 1827 and was conveyed by deed to the therin decd ancerton [?] on the 16^th day of May 1825. A certified copy of the warrant and survey and the ______deed of conveyance are here filed and made exhibits in this cause Your Orators state that Alexr Goodin represented that a patent had issue and it was so believed until after the decease of Benj Goodin and since that time she has ascertained that no patent ever has issue on the survey, and the said Alexr Goodin has refused and failed to perfect the title to the [assigned] tract of land.

They further state that some time during the last year the said A. Goodin caused another survey to be made on the land in the name of his son Hezekiah Goodin and now gives it out in speeches that he intends to hold the land under the last survey. They state the survey was fraudulently made in the name of Hezekiah for the purpose of preventing them from holding the land when no truth Alexr Goodin is the real & bonefied _______ [smudged, can't read] and Hezekiah only holds the claim in trust for his father.

They therefore pray that Hezekiah and Alexr Goodin be made defendants hereto and that Alexander Goodin be compelled to perfect his title and make them a conveyance according to the provision of the original deed and that the sd Hezekiah and Alexr be restrained from selling assigning or conveying their interest to the sd land to any person until the emanation [examiniation?] of the patent and untill [sic] your Orators can be heard in equity and in the event of the Goodin heirs are able to make a good and complete title that he the sd Alexr be decreed to refund the purchase money, and on final hearing for such other and further relief as to equity belong [?] and the virtue of their case require.

Evaline Goodin

Benjamin Goodin

Goodin v Goodin } In chy: By agreement of the parties the following decree is pronounced in this cause, 1^st It is decreed that the defts on or before the 1^st day of the next time of the court convey to the complts by deed with clause of Special Warrantee all their right and title to the land in the Complts Bill mentioned...

The above papers filed 2/12/1829.

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The court papers included a copy of the original survey for Alexander Goodin assignee of Christopher Horn, per Kentucky Land Office Warrant No. 1789 and dated 8/21/1817 for 50 acres��on Greasy Creek...Joseph Goodins upper corner of a survey on said Creek....

Christopher Horn and Hezekiah Goodin were Housekeepers and Chain men

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Separate Answer of Alexander Goodin

The separate answer of Alexander Goodin to a Bill in chy exibited [sic] against him and son Ezekiah in the Knox Circuit Court by E. Goodin plt

This respondent for answer saith, that is true he sold the land to the said [blank] in his lifetime for the sum of $150 in Commonwealth paper, the worth only $ [blank] in silver in the dollar, and the said [blank] took possession of the same about the first of [blank] and has th same has been in the occupancy of the same ever since, and undistured in the possession of the same and has never been disturbed in the possession or the title of the same in pursuance of his contract he made a regular conveyance for the same duly recorded in the County Court of Knox,��...This respondent denies all fraud in the sale of the land. This respondent admits the appropriation of the land by his son Ezekiel � He denies that the appropriation of his son was for his benefit in any way whatever either directly or indirectly � that the same is not held in trust for him � he denies any fraud or combination in the appropriation of his sons appropriation. This respondent believes that until it is established that his son holds the second survey for his benefit or that fraud a combination is established between them, that this Court has not jurisdiction of this case, and he therefore excepts to the jurisdiction of the same. He denies every alligation [sic] in this Complts. Bill not here admited [sic] or denied � he likewise denies the right of the Compt. Evelina to sue in this case. This respondant having answered as fair as he is advised prays to be discharged with his proper costs.

Smith for Goodin

Note 1: Copied with the exact same spelling, etc. The blank spots may have been water damage.

Notes 2: The Alexander Goodin in this chancery case is not the same Alexander Goodin that married Jane Hardin, and the Hezekiah Goodin is not the same as who married Elizabeth Arthur and lived his entire adult life in Knox Co.

This Alexander Goodin, born circa 1784 in Tennessee, may have been a son of the old Thomas Goodin Sr. He and his family (including son Hezekiah and probable son-in-law Reuben Arthur) removed to Owen Co., Indiana by the mid 1830s. Alexander Goodin can be found in the 1850 Owen Co., Indiana census but is deceased by 20 April 1852 when letters of administration are granted on his estate. Alexander's son Hezekiah was born circa 1804 and married Manerva Bigger in Owen Co., Indiana.