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named in said Bill as Trustee or had endeavoured to induce
his wife the Complainant to believe that a certain deed
or declaration of intention secured to Complainant the negroes
that he Betts had procured a copy of Said writing
corresponding in substance as he now believes with Exhibit A. annexed
to said Bill- that he Betts had had an interview with
said Walker who had admitted to him freely that he
Walker was mistaken- that he Walker had no claim to
said negroes as Trustee- that there was no seperate Estate
in Complainant of said negroes, and that the same were
the right and property of respondent Betts. That said
Defendant Betts informed respondent that when
Complainant was in her storms or out breaks that she
claimed said negroes as her seperate property under the
writing referred to as Exhibit A. a copy of which or that
which purported to be a copy was then tendered by said Betts
to this respondent- and the opinion of respondent asked
as to the legal effect of said instrument upon those negroes
after first informing respondent that said negroes were
given to him by Complainant's father soon after his
marriage with Complainant, without any condition, reservation
or qualification. Respondent did then and does now believe
that said instrument named as Exhibit A. does not in
any manner secure to Complainant any seperate Estate
in said negroes- That said Betts also informed
Respondent that said instrument was Executed by
Complainant's father, after the abandonment of Complainant by her
former husband- and in order to prevent said Nelson from
in any manner controlling any property which said Walker
might give complainant by will as also that he had
given to her while living with said Nelson- and that
said Moses Walker before his intermarriage with Complainant
said to him that the property he intended for
Complainant should be unimcumbered and fully subject to his
marital rights= Further answering respondent saith
that about the time of the marriage between
Complainant and respondent Betts, he either heard John Walker
Complainants Uncle, or Moses Walker her Father or both
speak of the marriage between Complainant and
respondent Betts- And of the situation of Respondent as to
property and of the property which respondent Betts would get