Page 17

rents & profits or products of the labour & servicing of the
same & converted or disposed of the same to his own use

He admits that he has not made sale of any of said trust
proerty not has he paid any of the creditors of said Meyers out
of the effects of said estate for the simple reason that
none have come into his hands.

Respondant utterly denies that he has fraudulently
or otherwise placed said Slaves on one of his own
plantations or that he is working or fraudulently
disposing of said Slaves amoung Slaves of his own or
that he is fraudulently disposing and converting the labour
of said Slaves to his own use & benefits. But to the
contrary thereof respondent saith he has let the said Meyers
have the use of One of his plantations where said Negroes
are under the sole charge & control of said Meyer himself
who received and is entitled to the proceeds of their labour
& crops made over which this respondent & from which
he has never received any benefit & all of which crops
are lisable for his debts & contracts. Respondent
denies that he ever said to the Complainants that if they
behaved themselves well they might be paid in twenty
years otherwise they would get nothing, this respondent
on the contrary has never desired to prevent said trust
property from being disposed of of otherwise thereto pay
the just debts of said Meyer. he has never done any
thing to prevent it & is now desirous and willing that
the same should be sold and the proceeds append to
the payment of the same. Respondent himself would
have long since acted and sold the property for that
purpose but for the difficulty in respect to the land
above spoken of. Respondent believes that
the property is sufficient to pay all said Meyers debts
if the land is sold also but not without.

Respondent alleges that One of the debts due by said
Meyer at the time of the execution of said deed & One
which it was inteneded to secure was a debt for the sum
of $2000 & upwards due respondent by various notes of
hand of said Meyer for money advanced and executions
paid by respondent & judgements assigned to him which
are still due.

Also that since that time said, Meyer has
became indebted to respondent to the amount of $500
or there abouts which is still due.

Respondent admits all that in said bill is alledged