The document below gives the complaint of James C. Epps the administrator of his father Lawrence’s estate who died intestate. The court had order that the land of Lawrence Epps deceased should be sold to settle the debts against his estate. James pointed out that the farm was in such poor condition that it could not even be rented much less sold for reasonable value. Therefore James C Epps moved onto the land and began to restore it to good farming condition at considerable out of pocket expense. It was his desire to recover this expense from the sale of the land before the remainder was divided between the heirs. The court was to ascertain proof of his expenses so an equitable settlement could be made between all heirs.

Filed February 1st 1868 before R. Farquhason Clerk & Master Chancery Court of Lincoln County
To The Honorable John P. Steele Chancellor and presiding at Fayetteville, Lincoln County, Tennessee.
The amended Bill of James C. Epps to a Bill heretofore filed The Honorable Court

Your Complainant James C. Epps a citizen of Lincoln County, Tennessee would show unto your Honor. That Lawrence Epps, late of said County and State, departed this life about the month of June 1861, Intestate, leaving him surviving no widow, but the following children and grandchildren–Hu M. who resides in Lincoln County, Tennessee, Margaret J. who intermarried with Thos. Cummings, who died before intestate, she residing in said County of Lincoln, but not made a Defendant, Gilbert, who resides in Mississippi, James C. your Complainant, Hepsey, who married William Panter, she having died about 15 year ago, leaving following children–Elizabeth who intermarried with John Cole, Malinda who intermarried with ______ name not known, John who died leaving one child, a minor, whose name is unknown, Larry, Mahala who intermarried with Wesley Causby, Nancy, Margaret, a minor and Mary Painter, a minor, all residing in Arkansas, Mahala who intermarried with James Pruitt, she having died about 30 years ago, leaving two children, to wit, Mary who intermarried with B. F. Harkins, who resides in Lincoln County, Tennessee, and Larry, who died in 1865, leaving two children Mary and Sarah Pruitt, minors, residing in Bedford County, Tennessee and have no regular guardian, known to Complainant.
Pleasant Epps, who died about 15 years ago, leaving one child, Wm. Epps of full age, residing in said County of Lincoln, but he is not made a Defendant. Intestate had another son who removed to Texas and has not been heard from in 15 years, and supposed to be dead–he left no children surviving.
The foregoing are the only children and grandchildren and heirs at law of said intestate, known to Complainant.
Complainant would now show unto your Honor, as shown in Bill of which this is an amendment That he was duly qualified as Admr. of intestate as set forth in said original Bill.
Your Complainant would show That said Bill was filed for the sale of a tract of land. The boundaries of which Tract of land are minutly set forth in said original Bill and for the payment of debts of intestate, and for a distribution of the remainder of the proceeds of said lands to the several heirs entitled to the same.
In addition to the facts set forth in said Original Bill, Complainant would show unto your Honor. That in the year 1864 your Complainant as admr. of said intestate endeavored to rent said Tract of Land, but owning to the unsettled state of the County he failed to rent the same. That in the year 1865 the said Tract of Land being very much abused. The fences destroyed, and the dwelling and out houses being in a dilapidated condition. Complainant moved on said place, and has remained on the same up to the present time.
Complainant would now show unto your Honor. That he has made valuable improvements on said place. That at great trouble and expense he has built a kitchen, repaired the dwelling houses and stables and has repaired and rebuilt fences that were destroyed during the late war. in fact Complainant has, out of his own means and labor, placed said Tract of Land in good farming condition, which before was in a situation that rendered it entirely useless.
Complainant would show unto your Honor that his expenditures, improvements and labor on said place would amount to between Three Hundred and Four Hundred Dollars.
The premises considered Complainant prays that all the foregoing children, grandchildren and husbands of living female consorts be made parties, except said Margaret J. Cummings and Wm. Epps. That publication be made for the nonresident Defendants, and all necessary process used to bring all the resident Defendants before the Court. That they be required to answer J C, that guardian ad Litem be appointed to answer for the minor Defendants who are without regular guardians as far as Complainant knows. And at the hearing of the cause may it please your Honor to order that proof be taken to ascertain the amount and value of improvements placed on said Tract of Land by Complainant and Complainant prays that the same be allowed to him whatever amount the court may deem. And for such other and further relief as the nature of the case may require and as in duty bounds your Complainant will ever pray
Bright and Bright
Solicitor for Complainant

Comments by Lawrence W Epps clarifying the names of heirs above and the exclusion of two heirs from the law suit:
James C Epps the claimant in the suit excluded Margaret his sister as a defendant because she had given her rights to her father’s land to him in exchange for James paying off a debt her now deceased husband owed in Petersburg at the time they were moving to Arkansas. The reason Wm. Epps above was excluded from the law suit was that on Dec. 1864 he sold his rights as an heir of his grandfather to James C Epps Sr. for $80.

1. Hugh M Epps son of Lawrence.
2. Margaret J daughter of Lawrence wife of Thos. Cummings deceased before June 1861.
3. Gilbert son who lives in Mississippi in 1868.
4. James C. administrator of Lawrence’s estate and oldest son.
4. Elizabeth Cole grandchild and daughter of deceased Hepsey Epps Painter
5. Malinda grandchild and daughter of Hepsey and William Painter
6. John grandchild and son of Hepsy and William Painter
6. Unknown child of grandson John above deceased son of Hepsey and William.
7. Larry (Lawrence) grandson and child of Hepsey and William Painter
8. Mahala granddaughter and child of Hepsey and William Painter
9 Nancy granddaughter and child of Hepsey and William Painter
10. Margaret granddaughter and child of Hepsey and William Painter
11. Mary granddaughter and child of Hepsey and William Painter
12. Mary Harkins or Hankins daughter Lawrence’s daughter Mahala and James Pruitt or Prewitt.
13. Mary Pruitt a minor and daughter of deceased Larry the son of Mahala and James Pruitt. .
14. Sarah Pruitt a minor daughter of Larry above. .