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17. } Cause against Said Respondent, John W Jones, Isaac Winston
Jacob Haigh, George W Carroll, And others by William S
Hoskins, Complaint &c, This Respondent now And at all
times Saving and reserving to himself All Advantage &
exception that of right he might have to the want of equity
mistatements, And in correct possitions positions in the
Complaintants bill, for Answer to So much And Such parts
thereof As he is advised it is material for him to make Answer
unto, Answers and Says as follows, And Admits nothing except
what he may be understood expressly to Admit, He Says it is
true, he is as mentioned one of the Children And heirs of the
late Arthur Jones decd, And that the others as mentioned to
have been the Children And heirs, and married as charged
Are Such, except the wife of Wm J Adair, who departed this
life before the death of Arthur Jones, who died in the fall of
1836. This Respondent insists first that he ought not to have
been made respondent to the bill in this Cause, And that
So far as the rights of the parties Are Concerned, it would
have been So efficient to have made Jacob Haigh and John
W Jones, who are the acting Executors of the last will And
testament of Said Arthur As mentioned to have
been made, And proven in the bill, And which Said
Executor had at the filing of the _v ^Said bill possession And Control
of the negroes Complained of, And who wholly represented
Said Arthur Jones, in the Administration of his estate,
Wherefore he prays that Said bill As to this respondent may
be abated And dismissed, As fully And to all intents, As if
the Same matters had been Specially plead &c, Your Respondent
further Answering admits that is is true Said Mother
of Complainants, And father of Respondent Married
And that the Father of Respondents received along with his
Said wife the negroes Charged, And that the Negro
Woman had two Children during the life of Said Arthur
Jones, and while in his possession by virtue of Said