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for the same to your Complainant. This amount your Complainant also claims as a fair charge on a prior settlement with said Ivey. Besides these, your Complainant whilst said Ivey was in Louisiana paid several curtails on the debt aforesaid at the Exchange Bank amounting together to the sum of $ [blank] which he of course has right to charge to the concern of Ivey & Williams. Moreover besides all these your Complainant has paid other sums of money on account of the said Ivey & said Ivey has other and various sums on account of your Complainant all which your Complainant will be prepared to prove whenever a reference of the accounts to a Commissioner shall be directed. In the year 1843 your Complainant being sued by a number of his creditors was compelled to take the oath of an insolvent debtor & to transfer all his interest in the accounts between him & Ivey & in the property conveyed in the deed of Trust aforesaid to Richd. G Baylor then the sheriff of Norfolk County, according to the Statute in such case made & provided. A copy of the schedule given in by him on that occasion is filed herewith as a part of this bill. The creditors of whose suit he thus took the oath of insolvency & whose claims remain unpaid on the following Samuel Wates & Anna his wife, Francis Brock, David M Walker & Sarah M Shepherd Exex of Smith Shepherd decd the said Richard G. Baylor has [died] since suit & administration on his estate in due form of law has been granted by the County Court of Norfolk, to his