interest being then due except the sum of $71.40 cts paid as interest up to the 7th August 1840. Your Orators further charge that at the time they became the securities of the said Blakey and Rucker they were both considered good but as Aaron Carpenter who was proverbially a cautious and prudent man thought negro trading hazardous, he determined to have other names and your Orators having confidence in Blakey and Rucker joined them in the bond. Your Orators further state & charge that it turned out that their confidence was misplaced for in the year [blank] James Blakey undertook to sell all his property real and personal to his son Angus R. Blakey for cash actual or pretended and the said Angus R. Blakey claims the whole property as his own and says the whole of the purchase money had been appropriated by him without coming to the bond aforesaid. Whether the sale made by the said James Blakey to his son was bona fide or fraudulent, your Orators do not now know. And for the present they do not intend to charge it as fraudulent reserving to themselves the privilege of doing so hereafter if necessary and the development of facts should soon after render it prudent and justifiable. They will for the present content themselves with the charge that they now make that the said James Blakey is utterly and hopelessly insolvent and all the recent executions agt him have been returned no property. Your Orators further state and charge that George A. Rucker the other principle a short time since to wit in the year [blank] undertook to convey all the property then in his possession consisting of a small tract of Land in the county of Madison upon which he resided containing about [blank] acres and the following personal property.
In trust to [blank] to secure several debts therein alledged to be due to one William H. Twyman of the county of Madison which debts actual or alledged are represented more particularly in the said deed of trust which the parties had rendered in the clerks office for the county of Madison an office copy of which is herewith filed as an exhibit marked B. and which for greater certainty your Orators ask to be taken as a part of this bill. Amongst those debts specified in said deed as due to the said William H. Twyman is one for $500 for which he gave his bond to the said Twyman on the [blank] day of [blank] 1842 This bond your Orators charge was given voluntarily and without any consideration on the part of said Twyman and which was intended to hinder, delay and defraud the creditors of the said George A. Rucker. The only thing like a consideration was as your Orators alledge that the said Twyman should collect the money and furnish it to Angus Rucker the son of the said George a. Rucker to go on to Philadelphia and attend the Medical Lectures there. An object worthy enough in the Father if he could do it without defrauding others and at his own expence. And the better to give a colour to this transaction your Orators charge that the said William H. Twyman colluding with the said George A. Rucker gave his own bond for the $500 payable on demand or at a short day to the said George A. Rucker or to his son Angus Rucker the infant son of the said George A Rucker (and your Orators do not know which) and then put that debt in the deed of trust as if the debt was actually due to him the said Twyman. Your Orators expressly charge that at the date of this transaction the said Twyman well knew the desperate condition of the pecuniary affairs of the said George A Rucker and that many of his creditors would loose their debts