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of said Deed there were sundry Executions in the hands
of the Sheriff against this Respondent By virtue of which
there of the negroes mentioned in said Deed of Trust
Viz Jin, Gustine, & Frank were sold by the Sheriff
and two other men slaves, Viz, Prince & Burrell were sold,
under a mortgage to one Grun Rives & John May Pierce
executed before the Deed of trust.

And this Respondent further answering prays that
as there will be more than enough to pay all his debts if
the said lands he condemmed to the satisfaction of his
debts Your Honor would Order that the proceeds arising
from the sale of the land be first applied to the same &
then only so much of the negro property sold as may be
necessary to discharge the residue. And this Defendant
denies all and all manner of unlawful combination
& confederacy - without this that there is any other matter
or thing in said complainants Bill of complaint
contained material or necessary for this defendant to make answer
unto & not herein or hereby will & sufficiently answered
confessed traversed & avoided or denied is true to the
knowledge and belief at this Defendant - all which
matters & things this Defendant is ready * willing to aver
maintain * prove as this Honorable Court shall direct
and humbly prays to be hence dismissed with his
resonable costs and charges in this behalf wrongfully sustained.

Edwards Lapsley & Humber
Solicitors for Deft Meyer

Recd. of W R Meyer Eighty Eight 87 half/100 Dollars on
account of money advanced for him this 20the March 1841
W Drane

R B Harrison 2500.00
Zachariah A Edwards $164 due 31st March 1840 with Int.
Bej Mock 107.25 due 16th Oct 1840 with Int.
George Williams or Walter Drane 710. due 1st Jan 1840 with Int.
J W Mundy 631.80 due 19 July 1840 with Int.
Mundy & Judge 125. due 31st March 1840 with Int.
Greenwood Rochelle & Co 390.09 due 1st Jan 1840 with Int.
Greenwood & Rochelle 102.80 due 1st Jan 1840 with Int.
Greenwood & Rochelle 57.81 due 1st Jan 1840 with Int.
J W D Hall 500 due 1st Jan 1842 with Int.
Green Underwood 300 due 1st Jan 1840 with Int.