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290
[Following text is upside down relative to the top.]
as She is Some Times Called, And the death of Said Arthur, And that
Arthur Jones during his marrital nights or Convention of Said
Nancy Jones, had the negroes in dispute from his marriage
from their respective births afterwards until his death, and as he
believes and Charges Said Nancy for Some time Anterior And
up to her marriage with Said Arthur had the three oldest thereof
And exercised ownership over the Same, and after her Said Marriage
which took place about the [blank] day of [blank] Said Arthur Jones
wed And Controled and exercised acts of ownership over the
Same as his own untramelled property, this Respondent insists
that So far as he has ever had any Knowledge or belief on the
Subject or evidence to form an opinion on the Subject of whether
Said Arthur ever Knew or Suspected Such Conveyances to exist as
are Charged to have been made from Said Nancy to Compl=
=ainant, and then by him back again to her, as Exhibits A.
and B, Such Knowledge or Suspicion never existed, on the part
of Said Arthur, nor on the part of this Respondent until Since
the death of Said Arthur, And to the best of his information and
belief, the Said Conveyance to the Said William S Hoskins, is it was
made at the time Stated was in direct and gross fraud of the
rights and exceptions of Said Arthur, Your Respondent asks for
Strict proof of Knowledge of Said Conveyances on the part of Said
Arthur, as well as proof of the Conveyance itself, neither of which
is admitted, but the reverse thereof insisted on &c, Your
Respondent insists as a fact which would go to Contradict the
idea that Such Conveyances were made with Consent or Knowledge
of Said Arthur, or that he ever had any Knowledge thereof, that
by his Will and testament, he mentions nothing Specially of
those Negroes, as the property of Any other person than himself, And
in his Will he gives on fifth of his personal estate to his Said
Wife Nancy, not having had any Children by her, and having
been married to her but a few years in their mutual old
age, and he also gave her dower or portion of his dwelling
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