Page 19

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[Following text is upside down relative to the top of the page.]
Marriage, And Are the Same Negroes Named in the bill As
Such, but this Respondent denies So far as he Knows or believes
that his Father ever had Any Knowledge before his marriage
or after his marriage of the Conveyance of the negroes mentioned
from Complainants mother to Complainant, And Verily believes
his father never Knew of Any Such transactions, nor that
Complainant had Conveyed a life estate to his mother, A
Knowledge of which on the part of Complainants Father So far
As this Respondent Knows or believes is denied, And Strict
proof to these points Called for, According to the rules of Chancy,
he also According to the best of his Knowledge And belief
denies that his Father ever assented or agreed to Such
Conveyances, after his Said marriage with Said Widow
Hoskins, And he insists that as he is advised and believes
the whole transaction in the Conveyance of Said Negroes
from the Complainants mother to Complainant, And
then back from him to her for her life, was all on the
very eve of her marriage between her and your
Respondents Father, And without Said Arthurs Knowledge
And was a fraud practiced upon Said Arthur, And
intended for the benefits of Said Complainant, if indeed
Such Conveyances took place at the dates, and as mentioned
in the bill, none of which however is admitted but Strict
proof required and Called for your Respondent further
insists that as he is advised And verily believes And So
Charges that his Father So far from having assented to
Such Conveyance of Said negroes before his marriage was
informed by Some means or other that a Conveyance was
denied to be made by the then Widow Hoskins, of Said
Negroes to Complainant, And his assent asked, And
that he then Asnwered And refused to assent thereto, And
Said that under Such Circumstances he would decline
Marrying All together, And that thereupon the desired
And Contemplated Conveyance of Said Negroes to

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