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Trust & carried out & executed the same but for the difficulty about the land which is mentioned in said Bill - the account of which therein is hereby admitted. the puchaser of said land promising to reconvey it but failed to do so. This Respondent denies that said Richard B Harrison ever received said Trust property into his possession and also denies that he has received the rents and profits or products of the labor & services of the same & converted or disposed of the same to his own use.
Respondent admits that the said Harrison has not made sale of the said Trust property, and that said Harrison has not, out of said effects, paid any of the creditors of Respondent - for the reason that he has never had any of Respondents effects to dispose of in that or any other way. Respondent utterly denies that said Harrison has fraudulently or otherwise placed said Slaves on one of his (Harrisons) plantations, or that Harrison is working or fraudulently disposing of said Slaves, among Slaves of his own or that he is fraudulently disposing and converting the labor of said Slaves to his (the said Harrison) own use & benefit, but on the contrary Respondent says that the said Defendant Harrison has permitted this Respondent to have the use of One of his plantations when the said negroes are under the sole charge and control of this Respondent himself who now receives and always has received the produce of their labour & the crops made, over which the said Harrison never has had any control or derived any benefit or profit from the same, and all of which crops have been and now an subject to the payment of this Respondents debts & contracts.
This Respondent knowing nothing about what the said Harrison may have said to the creditors of this Respondent about the payment of their debt as stated in said Bill but that the said Harrison in his conduct to this Respondent has never manifested the slightest disposition to dispose of the said Trust property in any way except to pay the just debts of this Respondent that he knows of nothing that he has done to prevent it that he is now willing to have the same sold & applied to the same & would, as he believes long since have acted & sold the same but for the difficulty in respect to the
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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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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.
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T H Addison 300 due 1st Jan 1840 with Int. Est H Chuborough 920 due 1st Jan 1839 with Int. Est H Chuborough 210 due 1st Jan 1840 with Int. Charles T Bickley 80 due 1st Jan 1842 with Int.
The State of Alabama Dallas County] {Personally appeared before me William W Gagle an acting Justice of the Peace in and for said County the above named William R Meyer, who being duly sworn on Oath saith that the matters & things set forth in the foregoing answer as of his own knowledge are true and those matters & things setforth as on information or belief he believes to be true Sworn to & Subscribed before me this 21st day of December A D 1841 WW Gagle J.Peace. D.C.} [W R Meyer
The State of Alabama
Chancery Court at Cahahawba The answer of Alfred Harrison one of the Defendants to the bill of complaint of Zachariah Edwards and Others. The said defendant saving and reserving to himself all manner of benefit of exceptions to the many errors in said Complainants bill, for answer and demurrer to said bill, or to such parts thereof as he is advised it is material for him for him to answer, answering says that he admits that said lands were sold under executions, one in favor of Benjamin Harrison use & c and another in favor of Rigely Harrison & Blair both upon judgements against William R Meyer One of the defendants rendered in the County Court of Lowndes County on the tenth of February 1840 the former for $112.00 & Costs, the latter $190.00 & Costs - that said lands were sold on the first Monday in August 1840 the last sake day before the return of the executions, at the Court House Door, upon full notise and in every respect according to law, to one William S May for the sum of six hundred and sixty dollars, which amount was claimed and duly applied to an execution, before the day of sale, delivered into the Sheriffs Office, of an older date, founded upon a Judgement,
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dated first of October 1838 of Lowndes Circuit Court in favor of Roper Reese & Co against said Meyer. This defendant admits that he was Sheriff of said County and made the conveyance to said May, he being the highest bidder and that marked as Exhibit (AA) which he prays to make a part of his answer etc. This defendant say positively that the sale was perfectly fair and legal so far as he knows or believes, he knows of no fraud or unfairness whatever in the sale. Admits that the land is worth more than that sum, but the sacrifice was not greater than frequently occurred at Sheriffs sales at the same place, but this defendant did not desire the sacrifice nor did he in any manner cause it, if it is to be so considered. This defendant positively denies every charge in said bill of his being concerned in the purchase of said land by said May at said sale - he avery positively the said May did not buy said land ofr him, that he did not authorise it in any manner either by word or deed, that there was no such thing thought of by this respondent, and he never had the most remote idea of purchasing said lands or any interest in them until some months afterwards, and so far as the complainants charge that the sale on this ground is void or voidable the same is untrue and unjust - Respondent admits that afterwards about the 1st of March 1841 it became his interest to purchase said lands. and not doubting for a moment the title of said May, he took a convey and bearing said date, fully secured by covenants of title, which may be more fully seen by reference to Exhibit (BB) This Respondent further answering says that the charge in said bill that said William R Meyer had not notice of the buy and sale of said lands under said Executions is wholly false, on the contrary said Meyer actually pointed out or named the land himself to be levied upon, and was personally cognigant of the whole matter and so also was his said trustee R B Harrison, through whose instrumentality the said Execution of Roper Reese & Co was placed in the Sheriffs hands to cover the proceeds of the sale as above stated, which this defendant then and now deems amply sufficient under the law.
And the respondent further says that said Meyer has not at anytime objected to or in any manner pretended