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To the Honorable John Brown Chancellor of the Western District of Virginia The answer of Philip Gaines to the Bill of complaint exhibited against him & John Kelly in this Honorable Court This respondent saying the usual exceptions for answer to the said Bill saith That true it is that about the year 1806 this respondent purchased from John Patton George Jones & [Mark?] Johnson Representatives of [Aaron?] Johnson a female negro named Hagar. The said negro was at the time in the possession of John Patton previous to the purchase of the said Patton Jones & the complainant met at this respondents residence & there the complainant proposed that the said negro should be sold & the proceeds equally divided between the three The said Patton & Jones called in