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289
Cross Interrogatories, herein inclosed, Given under my hand
And Seal this 27~ day of January 1837.
Colin Bishop [Seal] Justice of the Peace,
Opened by order of Court 18 April 1837
W Lucas Clerk pr Hugh Dickson Jr.
Answer of } The State of Alabama } Circuit Court, To the Honorable the Judge of
Isaac Winston } Franklin County } The 4~ Judicial Circuit of Said State in Chancery
Sitting for Franklin County, Isaac Winston Responding to the bill
of Complaint filed in this Court against himself, Nancy Jones
Jacob Haigh, John W Jones, Wylie B Jones, and George W Carroll
And Said John W Jones And Jacob Haigh As trustees for Sarah W
Washington All heirs And Legatees of Arthur Jones, their Father
decd. This Respondent Saving and reserving all and all benefit
of exceptions which may or Can be had to the bill of Complaint for
want of equity, the making of improper parties, mistakes And
errors &c, Answering insists that he ought not to have been made
a party. Respondent to this bill, because he Says he takes whatever
he may take at all as a legatee by the will of Arthur Jones And
that Said Arthur left a will And testament as mentioned
And that this Respondent has never taken out letters testa=
=mentary or Probate on Said Will, nor does he act as executor
thereof, and that Jacob Haigh and John W Jones Are the Sole
Acting Executors on Said Will, And the Sole representatives as
Such of the personal estate of Said Arthur Jones. Wherefore
he insistts, that the Bill in this behalf Should be dismissed as to this
respondent, and that he have all the advantage as though he
had expressly plead the fact here in Abatement, so otherwise &c,
And by way and for further Answer in this behalf, as it may
be right &c, Respondent admits he is An heir at Law or legatee
of Said Arthur Jones dec.d And that his wife is one of the
daughters of Said Arthur Jones. He Admits the will as alledged
the marriage of Said Arthur and Nancy Jones or Ann Jones
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