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that all the received or Collected had been applied to the payments of
the debt of firm. Yet Complainant is able to carry his large fancy [???]
goods business on the criditing System without one dollar of Capital
to begin with and no friends or Connections to call on for that amount
Respondant denies that the firm of McLaughlin Read & Simpson did
ever lease a lot of ground from or belonging to the Estate of E.M.
Bolle decd. Respondant denies that the firm of McLaughlin Read
& Simpson ever did build or cause to be built or erected a cotton ware
house for the receiving of Cotton or Storage. Respondant denies
receiving any kind relating to a cotton ware house from James Douglas
as the property of McLaughlin Read & Simpson. Respondant denies
any right that Complainant has to demand and expoce of such
Individual property. Respondant here calls on Complainant to shew
what interest he has in that property , and how that interest was
obtained. Respondant calls on Complainant to shew what right
title or claim the firm of McLaughlin Read & Simpson had to that
leasehold and ware house and how they obtained it, by contract
Bond, Book account or in any other way. Respondant admits
that a verbal claim was made to that property and urged by
complainant on his word & Honor before the Arbitrators whilst setting
the concerns of the firm, but that claim was rejected by them.
Respondant admits that amongst the papers of the firm left with
respondant by James Douglass special agent for the late firm of
McLaughlin Read & Simpson when he Douglass declined the agency
was the four promiz notes of Complainants as discribed and
set forth in his bill of Complaint the three first named notes were
given for goods and real estate purchased by Complainant out of
the effects of the firm when selling at auction; the fourth and last
named note for 259. 64/100 was given by Complainant for the
purpose of refunding back when paid into the Common stock of the firm.
That specific Amount which Complainant had claims drawn from
the funds of the firm, over and above the eequalised private accounts
of the other partners on the Books of the firm. Respondant does not
claim any distinct individual interest in either of these notes but
Respondant acting as agent and assignee for the firm claims the
right, and feels it is his duty to sue for and collect all these notes
for the use of the firm as well from Complainant as from any other