Page 41

the entire property of said Defendant Betts,- Denies that
he knew that Defendant Betts was largely indebted at
the time he accepted said deed- on the contrary,
respondent saith. that the said Defendant Betts informed
respondent before the Execution of said deed & before
respondent entered into the contract to accept said deed
that he believed the sum of one thousand Dollars would
pay every debt which was then due by him or
which he owed- That he had known and respected
his Co-defendant fro many years as a high minded
honorable man and which he now believes true and
confided in the statements made by him fully &
entered into said contract in full confidence of those
statements that at the time he accepted said
deed he did not know of any suit pending
against him, but was informed by him that
these were two, one for the use of Harrison the
other for the use of Brannon in each of which
said Betts informed respondents he believed he
could defeat legally and justly. that he had
& before the 10th March 1843 had no notice of
other suits against said Betts but was informed there
was a judgement against him in favor of one
Solomon.

13. Denies that his co-defendant Betts about
March AD 1843 or at any other time, so far as he
knew and belived with any such intentions as stated
in the 13th section of said Bill Executed another deed
as stated in said bill that he has no knowledge or
information of the Execution by his co-defendant
of any deed for the benefit of his creditors unless the
deed annexed to and made part of Complainant's
bill as Exhibit B. and says that the only deed his
co-defendent Executed to him or about the time
of the Execution of Exhibit-B. was a deed to
Respondent as Trustee for said Complainant
comprising all the negroes named in said Bill with a
considerable portion of other personal property
by which deed a life Estate in three fourths
of a section of land in Barbour County and the
whole of said negroes named in said Bill, to wit,