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To Col. Brown or any other officer having jurisdiction of the case,
The undersigned respectfully represents that he is a freedman; that he resides in the county of King and Queen, State of Virginia, that he occupies a house with his wife on the farm of Rev. Isaac Diggs his former owner; that some 16 or 17 years ago he had for his wife a woman by the name of Mary Ann then the property of Joseph Eubank an idiot, that about two years after he took the said woman Mary Ann for his wife they had born to them a boy by the name of John Randall, that on about the 1st day of January 185 his wife and her child the said John Randall were sold under a decree of the Circuit Court of King and Queen at public sale and one James A. Goalder became the purchaser of the said boy and his mother, that he continued to visit his wife for several years there after until the birth of another child, that being convinced from the circumstances of the case and complexion and description of the child that he was not the father, he abandoned the said woman but not withstanding he always acknowledged the boy John Randall as his child, that some time there after the said Goalder sold the said woman and he has not seen or heard of her since; but the said Goalder retained the said boy John Randall and kept him in his possession and claimed him as his property up to the fall of Richmond and since has retained him in his possession.  About the 1st of last month (January 1866) the undersigned applied to the said Goalder to surrender to him the said boy John Randall which he refused to do; that on the 6th day of January last, he applied to Lt. Scott the Prov. Marshall located at Tappahannock Essex Co. Va., having also jurisdiction over the County of King & Queen and at that time holding his court at Stevensville in the said county of King & Queen to have the boy delivered to him, that

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