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from this Respondent the judgements obtained
the amounts cost and interest the execution issued the
return made by the Sheriff the grounds &
considerations of said debts and judgments - the
purchase the purchse of land by this Respondent from
George Williams, the security ship of said Drane
for the purchase money, thereof, the amount
paid, the amount still due, the suit brought
and the judgement obtained for the residue as
the same are respectively set forth in said Bill
of Complaint, this Respondent believes the same to
be true but for grater certainty begs leave to refer
to the judgements executions notes accounts and other
papers refered to when produced and proved.

As to the claim of the said Drane this
Respondent claims a credit for the sum of Eighty Eight
81/1/2/100 dollars paid by this respondent to said
Drane as will appear from his receipt hereto
attached marked (Exhibit A) & prayed to be
taken as part of this answer.

And this Defendant submits whether the
debts contracted by this Respondent before the
execution of said instrument (among which is the sum
of $2000 due to the Defendant Richard B
Harrison before the execution of said instrument and
intended to be secured by it) ought not first to
be paid out of said trust property, and this
Respondent prays that the said Complainants may,
with a view to that matter, be held to strict proof
of their claims, and more especially as to the time
when the same were contracted.

This Respondent admits the date execution and contents
of said deed of trust are correctly set forth in the
Bill.

This Respondent admits that he delivered the said
deed of trust to the defendant Richard B Harrison
and believes that he has ever since had the same
in his possession, but in no other way did he ever
accept said Trust that said Harrison has never
had any of said property in his possession nor
hs he ever received any of the rents & profits of
the same and those allegations in which the same
are alledged he denies. Respondent believes that
the said Harrison would have accepted said

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