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and Betts, being indebted to a considerable amount to his
codefendants Jackson, Brown & Brannon, besides divers other
persons and also to Complainant as hereinbefore stated and
charged, and with intent to hinder and delay his said
creditors and whose suits were then pending, of which
intent his codefendant Gunn at the time of accepting
the conveyance next hereinafter mentioned was cognisant,
by his deed, bearing date the day & year last aforesaid
a copy of which marked B. is herewith shown and
prayed to be taken as part of this Bill, conveyed to
said Gunn the property therein specified, and which
property, beside the small pittance of his effects left
(in seeming deference to public sentiment) for complainants
use, embraced the entire Estate and property of defendant
Betts; and so defendant Gunn well knew when he
accepted said conveyance: And knew that defendant Betts
was then largely indebted, and that suits for a large
amount were then pending against him.

(7) 13th Complainant further charges that at or
about he time said last conveyance was made
defendant Betts with a like motive as induced the first. Executed
another conveyance of the greater part and as
Complainant believes and charges of the Entire balance of his
Estate to other uses than for the benefit of his creditors
And if for this pretended benefit said creditors have
been suffered to remain ignorant of its provisions nor
have any of them (as complainant believes and charges)
assented to Either of said conveyances; said last
conveyance was delivered to and is kept by defendant
Gunn who is both trustee & beneficiary therein; and hath
not been recorded or shown to Complainant & she is unable
therefore more definitely to state its contents, save that
complainant further believes & charges that said last
conveyance assumes to give the remainder in said Slaves to said
Gunn or some other person after Complainants death and
perhaps sooner.

14th At the time of the time of the Execution of said
several conveyances from Betts to Gunn defendant Gunn
knew and before then had heard that Complainant
claimed said slaves as her seperate property.