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1. Sheet 1 The answer of William N. Ivy to a Bill Exhibited against him and others in the Circuit Superior Court of Law and Chancery for the County of Norfolk by Thomas Williams. This respondent saving and reserving all Exceptions to the manifold Errors and imperfections of the said Bill for answer unto so much thereof as he is advised it is material for him to answer unto answering says: 1st. This respondent and the Plaintiff did agree with each other in the fall of the year Eighteen hundred and thirty Eight to purchase negroes to be sent to Louisiana where they were to be Employed under the superintendence of this respondent in cutting Live Oak Timber for the Navy under Daniel Sanford's contracts n which contracts this respondent and John Allmand were jointly interested with the said D Sanford and the said Williams was by the said agreement to be jointly interested with the respondent in the profits that might be made from the purchase of the said negroes and to bear an Equal share of the loss. The sum of five thousand dollars was borrowed from the Exchange Bank of Virginia at Norfolk on the joint note of said Williams & this respondent and the whole proceeds of the discount amounting to $4921.6[?] paid over by William Reid the agent of the concern to the said Williams, who by the terms of the agreement was to invest said money in the purchase of Negro men suitable for the business in which they were to be engaged. As this respondent had given a deed of Trust on his property to secure the payment of the sum borrowed from the Exchange Bank, which was the whole capital of the Concern and as I was compelled to leave the State to superintend the operation of his Live Oak Contract Partnership in Louisiana soon after the loan was obtained and before any of the Negroes were purchased this respondent took from the said Williams