Page 22

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Land above spoken of - Respondent believes
that the said property is sufficient to pay all of
this Respondents debts if the Land is sold also but
not unless it is sold. Respondent further answering says
that one of the debts due by this respondent at the time of the
execution of said Deed & one which it was intented to secure
thereby was was a debt for the sum of $2000 & upwards
due said Richard B Harrison by various notes of hand of
this Respondent for money advanced & executions
paid by said Harrison & judgements assigned to him
which are still due. Also that since that time this
Respondent has became indebted to said Harrison to the
amount of $500 or thereabouts which is still due.

Respondent admits all that on said Bill is alledged &
contained respecting the levying of the execution upon said
Land - the sale and purchase of the same by said Sheriff
& concurs in the prayer that said sale may be set aside.
Respondent admits that he knew of the judgment &
execution which was levied on said land but he denies
that previous to said sale of said lands or at any
time before or afterwards the said Harrison had in
this power & custody all the personal property of this
Respondent under or by virtue of said Deed of trust
& avers that he knew nothing of the levy or sale of
said lands under the said judgment & execution
until several months after the sale & consequently could
not have prevented it. Respondent utterly denies
that he has combined or confederated with said
Harrison or has in conjunction with him attempted to
hinder or delay the complainants from the
recovery or collection of any part of their debts and
this Respondent proceeding to answer the interrogatory
part of said Bill saith that he cannot recollect
precisely the amount & the time when due of the claims
of each of his creditors nor can he certainly recollect
at this time who are all of his creditors as he has
no memorandum or statement of the same before him
by which the same could be precisely ascertained.
But that he hereto attaches a statement marked
Exhibit B, which contains as near as he now can
recollect the names of his creditors the amounts &
when due which statement he prays may be taken
& considered as a part of this answer.

Respondent states that at the time of the excecution

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