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the said William R Meyer being owner of a large Real
and personal estate with a view your Orators suppose
and believe the more effectually to secure them the
payment of their respective demands all of which is above
charged and setforth were due and owing respectively
to your Orators previous to the 1st day of April 1840.
he the said William R Meyer on the said 1st day
1840 in consideration of the said debts so owe and
owing by the said William R Meyer and for the
further consideration of One dollar to him in hand
paid by Richard B Harrison of Dallas County and
State aforesaid under the hand and seal of him
the said William R Meyer and there & there executed a
certain Deed of trust of all his property and
effects of whatever kind to the said Richard B
Harrison for the purpose of paying all the just
debts of him the said William R Meyer, a copy
of which said Deed is herewith fixed marked
Exhibit (A) which your said Orators pray may be
taken as part and parcel of this their bill of
Complaint, and that they may have have to refer
thereto so often as it may be necessay.
Your Orators charge that in and to the said
Deed it is yes ovided chat the said Richard B
Harrison shall hold the property described in the said
Deed for a description of which your Orators
pray a reference to the said Deed in Trust and
upon the conditions that the said Richard B
Harrison should take possession of the said property
and that as soon as the same could consistently with
the interest of the creditors of the said William R
Meyer, that he the said Richard B Harrison should
expose the said property to sale and appropriate the
proceeds of the said sale or so much thereof as might
be necessary to the payment of the debts due by the said
William R Meyer on his own equally and rateably
without any distinction or prefference. Your Orators
now charge that the said Richard B Harrison
accepted the trust and took the possession of the property
immediately ofter the execution of trust and as
aforesaid - that he has either received the product
arising from the labor and services of the Slaves
and other property named in the said trust Deed
ever since the execution thereof and has converted
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