Page 33

34
this knowledge of the State of the business of the firm,
Complainant Still urged for a seperation of accounts, as set forth
in his Bill of Complaint and did want to Select for himself
and for Wm Read Estate two thirds of the notes and accounts then
unpaid, without making any provisions for paying the debts
of the firm. And his first Selection he claimed his own [unclear]
notes on which he is sued on his first and exclusive choice. Wm.
Douglass is a man of too much discernment and Character and
to let any proposition that Could be made by complainant or
any person else mislead him in his duty, he became so much
anoyed by these kind of Depositions that he retired to his new
business leaving all the Books papers and effects of the firm
when he first received them. In answer to what Complainant
has asked in his Bill of Complaint or in his eighth Interrogatory
Exhibit (A) will show how much of the funds of the firm
have been collected by respondant out of Books notes and accounts
of the firm since they have come to his hands. And how he has applied
the money collected. Complainant may have an estimate
of of profits made for him on the account collected and not
accounted for if he thinks proper. in answer to what complainant
has asked in his Bill of Complaint or in his ninth Interrogatory
Exhibit (C) will show a full statement of all accounts and
notes belonging to the firm yet remaining unpaid designating
them Sued on and by whom on their proper claims. All the
accounts were due when the firm was dissolved. The
particular notes stated at foot have been taken for accts and
[???] that could not have been collected otherwise , they are believed
to be good at maturity . The notes of John Simpson became
due after the firm had been dissolved. he has given the time
the were due in his Bill of Complaint. James W Morrisons
notes are also sued on they are in the hands of Respondants
Councel. The greater part of the notes and accounts now
remaining due and unpaid were contracted for with
Complainant himself. he ought to be competant to form an
estimate of their worth whether they are good doubtful or bad