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Bureau Refugees, Freedmen & Abandoned Lands,
Hd. Qrs. Asst. Comr, State of Va,
Richmond VA, March 8th, 1866

Maj. Gen. O.O. Howard,
General,
I have the honor to forward herewith, for the approval of the Commissioner, a proposed Order for turning over, under such supervision as seems necessary, the criminal cases heretofore tried by Bureau Courts and Military Commission.
Owing to the large number of unsettled cases, growing out of the "labor question" during the last year, it is not deemed advisable to turn over to the State Courts, the civil business at present.
Very Respectfully
Your Obt. Servt,
(signed) O. Brown
Col. & Asst. Commissioner

Official
Max Woodhull
A.A.G.