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collected by Douglass and paid by him during his agency with
complainant it will be seen that not one dollar had been paid
to defendants account nor any credits placed on it . Complainant
did then propose a division of accounts and that he would give
new bonds & as set forth in his bill of complaint.He was then
promptly told by Respondant that no division could be made nor no
new Bond could be taken until he would redeem his arbitration
Bond then laying are forfieted. That when he would repay
Respondant the amount paid him for the use the firm , out of his own
funds and thereby redeem his arbitration bond then a division
of the affairs of the firm could be made in the manner
complainant had proposed. Complainant would not agree to pay
any thing but still in go for a division Mr. Douglass thereby
become dissatisfied and declined the agency and retired to
his own business having the books notes and effect of the firm
where he received them, then complainant no longer urged for
a division nor asked for a succcessor to mr.douglass in regard to
what complainant has stated and so changed in the 3rd page of
his Bill of complaint respecting the amount of money then to be
collected and the amount of money then to be paid by the firm is not
true although complainant had at that time copies of all the
accounts then to collect and al all moneys then compared as far as
ascertained by Douglass who handed to him at or about the time
he Douglass declined the agency. respondant here begs the
Honorable Court to pause and emphatically notice the foul charge
made with the fourth page of Complainants Bill viz of Stealing
or what is still worce of robing the dead of his just rights.
Respondant is there charge by Complainant with
appropiating the money collected by Respondant out of the Books or effects
of the firm to his own Individual business and asked to render
an account of the profits of the same when it has been shewn
by Complainant himself and so stated in the 2nd page of his
Bill of complainnt that he then up to that time viz; at the time
the Selima award has been made by three Gentlemen of
undoubted character and integrity acting as Arbitrators