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to this defendant that said sale was illegal fraudulent
or unjust, nor has he or any one else a right to do so as
he believes. This defendant further says that he
may have heard or understood that said Meyer had
made a transfer of his property to said R B Harrison,
but knowing that no such assignment could
prejudice being of prior judgments and executions, he took
but little thought upon that subject if any at all
and he now insists that said pretended deed or
assignment not having been shown to him he cannot be
charged with any notice of the same whatever, that the
core entry of a copy upon the Clerks books of a paper
to which there is no witness, and without any proof
that the original is genuine is no notice to any One.
This defendant did not know who composed the
creditors pretended to be secured by said deed - nor
the amounts claimed by them, he never was
informed that Complainants claimed under said deed,
He knows nothing of the frauds alleged against the
other defendants, he never had any wish or concern
in hindering or delaying the creditors of Meyers-
He does not know whether there is property enough
to pay the debts of Meyers without this land or not -
And this defendant further says , that he is informed
by said Meyer and fully believes the fact, that said
May before the sold said lands to this defendant
offered them to said Meyer for the amount he gave
for said lands as aforesaid, and that said Meyer
did not choose to avail himself of the offer & wholly
neglected to make the purchase, that said May was
willing and anxious to sell the said lands to said
Meyer, and gave him a fair and bona fide refusal
of the same before he offered them to defendant &
before he sold to him as aforesaid.

Defendant says that the judgment and execution
in favor of Roper Reese & Co was for dollars
besides costs & interest & prays to have the transcript
of the judgements & executions in the said cases thereto
annexed and marked exhibit (CC) made a part of
this answer. This respondent says that said
complainants ought not to have or maintain said suit aginst
him, because the said bill of Complaint and the
matters therein contained are not sufficient in equity to
sustain the same, he therefore demurs to the same, and