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husband Arthur Jones was addressing her, but as will as She now recollects there was no Agreement to many existing between them, And fearing he might be indeed to believe the Said Negroes Sarah, Swift, And Martha, would in the event of their Marriage belong absolutely to him, Respondent appraised him of her intention to give them to her Son Complainant, to which Jones readily assented, And Accompanied his assent with this request, "Whatever you intend to give William, give it to him now" Accordingly Respondent executed Said Settlement As above Set forth, to All of which her deceased husband Arthur Jones not only readily assented but with which he expressed himself even pleased, Some weeks or months afterwards Respondent And Said Arthur Jones were Married, Respondent admits that Said Negroes were taken into possession by Arthur Jones, after the Marriage, but never in any of their frequent Conversations did he Claim Any greater interest therein than respondents life estate, by Virtue of the agreement under Seal referred to in Complainants bill As Exhibit B, And Admits that he frequently observed to her that in the event She Should die before him Said negroes together with their increase Should immediately be delivered over to Complainant, Respondent admits that Said negroes have increased to the number of Six, And are by name as mentioned in Complainants bill, that her Said husband departed this life on the 24~ Oct 1836 testabe, and by his will appointed for his Executors as named, in Complainants bill, She also Admits that exhibit C, as Set forth in Said bill is She believes A Copy of his will, that John W Jones And Jacob Haigh Are the acting executors, And that Said Negroes, have been offered for Sale as mentioned in Complainants bill, Respondent in further Answering States that she has had a Conversation with her Co defendant George W Carroll, Since the death of
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[Following text is upside down, read from the bottom to the top.] her deceased husband, in which the Said Carroll told her that Arthur Jones in his life time, Said that Said Negroes after the death of Respondent would go to Complainant, Respondent would again State, that Said Settlement was made upon Complainant with the full Knowledge of her deceased husband Arthur Jones, with his approbation, And at his request, that he never during his life time pretended to have Any greater interest in Said Slaves by virtue of his Marriage with respondent, than her life estate, under Said Settlement, Respondent admits that under the will of her deceased husband She Can Claim And has An interest in Said Slaves As a Legatee, if her decleared husband had any, And her proportion of Said interest As her husband may have acquired by his Marriage with her, Respondent denies all fraud or Combination with her Co defendents or Any other person in reference to this matter, And having fully Answered as She is advised All the material allegations of Said bill of Complaint, prays hence to be dismissed with her reasonable Costs, Nancy Jones,
Addifdavits to } The State of Alanama } This day Came Nancy Jones before me answer of } Franklin County } James Hodges An acting Justice of the Nancy Jones } peace in And for the County aforesaid, who after being first duly Sworn Saith that All the Answers in the foregoing is true in fact as Alledged to the best of her Knowledge And belief, Sworn to & Subscribed, Given under my hand & Seal this 10~ } Nancy Jones ~ day of January 1837. Attest J Hogges J P [Seal]
Answer of } The State of Alabama } To the Honorable the Judge of the 4~ Wylie B Jones, } Franklin County Viz } Judicial Circuit Court of Said State in Chancery Sitting for Said County, the Answer of Wylie B Jones One of the Respondents to the bill of Complaint filed in this
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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
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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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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 Sol 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