Page 16

money thereof the amount paid the amount still due
the suit brought and the judgement obtained for the
residue as the same and respectfully set forth in said
bill of Complaint this defendant believes the same
to be true but this defendant does not know the same
of his own knowledge and for greater certainty
requires strict proof thereof & begs have to refer to the
judgements executions notes accounts & other
papers refered to when produced aproved. But
this defendant denies that at the time of the
execution of said deed of trust all of the debts
mentioned in said bill were owing by said Meyer or
that said deed of trust was executed with a view
to secure to them all of their respective demands but
overs that sundry of these debts were contracted
afterwards as will appear in part by the
Complainants cover showing & in part from other evidence
and this defendant insists that the debts contracted
by said Meyer before the execution of said
instrument (among which is the sum of $2000, due this
defendant before the execution of said instrument
& intended to be secured by it) are first entitled
to be paid out of said trust property. and this
defendant pross said Complainants may be
held to strict proof of their claims against said
Meyer more especially as to the time when contracted

This defendant admits the date execution and
content of said deed of trust are correctly set
forth in the bill

This defendant admits that he
received the deed of trust from said Meyer & has
had it in his possession ever since but in no
other way did he ever accept said trust - he never
has had the property in said deed described in
his possession nor has has he received any of the
rents and profits of the same & he denies those
charges contained in the bill - Respondent intended
to have accepted & carried out & executed the
trust but for the difficulty about the land which
is mentioned in said bill the account of which is
hereby admitted - the purchaser of said land
promising to reconvey it but failed to do so - he
denies that he received said trust property into his
possession and denies that he has received the