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[Hee?] is [advised?] that this cash bill, so called, was and is wholly unnecessary, because all the facts, specifically charged, and fishing inquiries, could as well have been [driven?] out [when?] interrogatories before the commissioner, and by examining Edmund [Rosser?] as a witness, he having no interest in this controversy. This Deft denies the Abram ever was a partnership negro, [directly?] or indirectly, he was unknowm to this Deft: until they were in the [act?] of [standing?] on 2 Dec 1838, as charged in this [illegible], he was not worth a dollar, and the [illegible] him when the list after his return 19th Dec. 1838 was a wicked and deliberate fraud upon this Deft's rights - he has in his bill given a true version in relation to the negro, and he is advised upon no principal, legal, or equitable can his rights be effected by the cunningly advised plan of the [illegible]: to [palm?] this negro upon the partnership, he was returned upon him by his agent Long, and when he shall have paid his expenses, [right?] will have been done - This Deft is advised that an attempt of one partner to cheat another should not receive countenance, they must confide one with another, and the principal of [caveat emptor?] never [applys?], as in dealings with other persons, who are always supposed to be jealous of [these?] rights, and one required to exercise more caution, - But upon any and every principal this Deft: expects to show by proof, that the negro was utterly [illegible]less and that the Plaintiff knew it, and knowing, can [illegible] the fact [illegible] This Deft: does not admit that the [Pltff?]: had purchased six of the list of negroes intended for Mr. [Rives?], before the partnership, he has declined to give [their?] names, and especially he denies that he has paid for them, he may have assisted in the purchase but was very guarded in the payments, they [usualy?] gave their notes for the negroes purchased one as [drawer?] and the others [endorser?], but whether [drawer?] or [endorser?], it usually fell to the lot of this Deft. to pay - The slaves bought of Smithson, of P. Jones,of J H Jones, of John Stark and of Mosly was bought on join account, joint bonds, or joint [neg?]. Notes were given as aforesaid; Nelly was bought not at auction but [illegible], Nancy never was a partnership negro - Ben was partnership, but neither [illegible] or [illegible] were over partnership property, but the individual property of this Deft: and [service?] Mr. [Rives?] did not take any of the negroes, the proposition to average the price no longer [offered?]. The partnership had never paid a farthing for Nancy, [illegible], and [illegible], these negroes should bear their proportion of expense, and then equal [illegible] will have been done in [illegible] to these three negroes. It is not true, that the partnership proper ever owned of negroes as charged, on the contrary there wer 13 company negroes, 3 of this Deft's: individual property, and one the celebrated Abram, the Pltff: own property, and shift and twist the matter as the Plaintiff will, this is the whole truth, the whole [illegible], and