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Respondent then informed complainant that he
should return the deed to respondent Betts as he
was by him instructed to do-

Further answering saith that after a full and
free consultation between complainant and one of
her solicitors, another instrument in the nature of
Articles of seperation was drawn by said Solicitor of
complainant with the request that this respondent
should tender the same to his co-defendant Betts
to be executed- that respondent did deliver to said
Respondent Betts the said blank deed, accompanied
with the request named- also the deed which
respondent had shewn to complainant as last named

That his co-defendant Betts refused to execute said
blank deed drawn by complainant's solicitor, because
the same provided for a seperation betwen
complainant and said Betts- that the deed he had before
signed as before referred to in favor of respondent as
Trustee for complainant was by said Betts, thrown
upon or behind the fine and consumed by the flames

Respondent now says that Complainant did see
said deed and she read the same as he believes and
knows that she heard the same read and that the
purposes of the same was fully made known to her
and he does know that said Complainant did
know that no Estate in remainder was secured to
respondent in said slaves.

14. Respondent further answering says it is not true as stated
in said Bill that this respondent, at the time he accepted said
Deed referred to in said Bill as Exhibit B. know that complainant
claimed said slaves as her seperate property- But says it is
true that he heard that Complainant did claim said
slaves named in said Bill as her seperate property- that the
information he had upon the subject as well as he can now
remember was in substance in the manner following- some nine
or ten years since after as he was informed some controversy
between Complainant and respondent Betts and after she
had as he was informed abused him much and made
some threats said Betts informed respondent that from
information soon after the decease of Complainant's Father
that Alexander Walker had asserted some claim to the negroes