Page 30

In the firm of Wm. Read & Co, Respondant denies that he was a
partner in the firm of Read & Simpson. Respondant denies owning any
part of the account stated in Complainant's Bill. And marked
exhibit (B). Respondant admits that part of the terms for auction
sale were that notes with Security would be required
notwithstanding these rules a great many notes were taken for sale, at
auction without any security but the buyer. Respondant hasn't
seen any notes for private sales except one with security to it.
Respondant had been absent from this State from may 1825
to late in March 1826. Respondant did not make any sales
himself on credit after his return home, determined to close the
concern. On of the notes of J E. Owens amounting to 469 22/100 $
was taken by Complainant himself for goods sold by himself
to J E Owens & Parson & Taylor same amount as does appear by
the Sale Book, Other notes of large amounts were also taken for
private sales made to Dr. Wheeler Randle and others by Complainant
himself. It does not appear on the auction Sales Book that G
E. Owens purchased anything at auction belongong to the
firm. Respondant is left entirely to conjecture to know for what
J & E owens note for 581.78/100 was taken. It may be probable that
Complainant can tell if being an auction transaction of his own
At the time these notes become due Respondant was living
in Mobile and had nothing to do with the collections. James
Douglas was the then agent for the firm. Respondant admits
that Complainant has waited long. And Resondant believes
would waited much longer had he not been sued to enforce
payment from him for goods and real estate purchased
at auction and for money over drawn out of the firm as of the
firm over and beyond the amount drawn by the other partners.
Respondant anxious to close the Concerns of the firm has been
forced to that alternative to enable him to pay off the debts afsd
due by that firm and to get Bank Moneys advanced out
of his own funds to pay the debts of the firm more than three years
ago. In answer to Complainants first Interrogatory wherein he
specially called upon to account with Complainant.
Respondant begs leave to refer to account here to attached