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Complainant by his Mother appearantly Abandoned, And
if Carried into effect at All, Was done Secretly, And in
fraud of the Contemplated marriage between Said Widow
Hoskins And Said Arthur Jones, Respondent insists that
the whole transaction appears And is the more fraudulent
And outrageous to good principles And fair dealings where
it is Known and born in mind As the facts of the Case Are
that Said Mother of Complainant took in And about three
or four times as much from the estate of Said Arthur by
her distributive Share thereof as She brought with her
at her marriage to Said Arthur, even then if She were
the Sole owner of all the negroes here in dispute, And
that two when both the parties towit Said Arthur and
his Said wife were both quite old, And all their children
raised at or about the time of their marriage, And he
denies all fraud, And Combination&c, this Respondent
having fully Answered prays to be hence dismissed
with his Costs about his defense in this behalf expended -
W Cooper So^l for Respt, } Wylie B Jones

Affidavit } The State of Alabama } This day Came Wylie B Jones to me
& Answer of } Franklin County } well Known And made this his
W B Jones. } affidavit before Me a Justice of the peace of Said County, that
the foregoing Answer as alledged of his Knowledge or positively
is true, And all other matters as of his belief or on the
information of others he verily believes to be true,
Sworn to and Subscribed by offaint
this 14^- January 1837 } W. B Jones.
Test my hand & Seal Colin Bishop [Seal] J.P.

Answer } The State of Alabama } To the Honorable the Judge of the 4^- Judicial
^of Jno W Jones } Franklin County towit } Circuit of the State of Alabama in chancery
Sitting for the County of Franklin, the Answer of John W Jones for