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This respondent had no authority from said Ivy to buy the said negroes except for his own use or to make any agreement with Williams or representations to him or others that it was the intention of the said Ivy to allow the said Williams to hold the said negroes and he therefore made no such agreement or representations - The paper of written instructions signed by the said Ivy and filed by John S Millson with his deposition taken in this cause will shew the instructions under which this respondent acted in the purchase of the tracts mentioned in the Bill. This respondent begs leave to refer to his deposition filed in this cause & taken on behalf of the defendant Ivy for a full and detailed statement of this respondent's acts as Agent of the said Ivy in relation to the said land to avoid repetition and begs that the same may be regarding as a part of his answer in the same manner as if the same were here repeated. This respondent would state in addition that the highest price which he could have obtained for the tract of land which was cultivated by Williams and the other tract purchased for $70 adjoining the first was $825 viz $500 in Cash and the balance in 12 months but since the land has since been as much wasted by the said Williams who has obstinately and illegally refused to surrender possession of the said premises that this respondent does not believe that the said tracts would now sell for more than $670 - the cost of the same - This respondent would further state that the said tracts of land are subject to the dower right of the wife of said Williams which fact materially impaired their values. He was prevented from making the sale of the said tracts of land by the threats and other improper conduct of the said Williams. In conclusion he denies all fraud and illegal combination and having no interest of any kind in the controversy between the said Williams and Ivy and having fully answered he prays to be hence dismissed with his costs &c Miles Portlock

City of Norfolk to wit: Miles Portlock the respondent in the within answer this day made oath before me an Alderman of said City that the facts set forth in the foregoing answer by him subscribed are true to the best of his knowledge and belief. Given under my hand this 15th day of September AD 1846 - G.B. Cooke