The answer of Archibald Vaughan to a bill exhibited by Henry Jackson an infant of tender years who sues by his guardian and next friend Pleasant Labby of the town of Lynchburg in the Circuit Superior Court of Law & Chancery for the County of Prince Edward against the said Patrick H Jackson John H Smith & others. This respondent saving the benefit of all exceptions to the errors & inaccuracies of the said bill for answer thereto saith that it is true as the bill states that the said deed of trust was executed to this Respondent as Trustee for the purposes specified in the said deed, and particularly to secure P H Jackson as the endorser of James M Jackson at the Branch Bank in Farmville. This Respondent has believed and yet believes that the said deed of trust was fairly executed for an honest purpose and conveyed only the property which regretfully belonged to James M Jackson. Of the claim and pretensions of Henry M Jackson, this Respondent never heard untill within the last twelve months and knowing nothing of his claims the respond requires [hereof?]. He insists that the said slaves claimed in the bill were conveyed by deed absolutely to James M Jackson (as this Respondent has been informed & believes) That he held them in his possession for more than five years and that Henry Jackson is estopped by the laws of the land from sitting up any secret unwritten trust in reference to the possession or that he can claim them at all after five years possessed by James M Jackson. This Respondent requires proof of the claims & pretensions of Henry Jackson and having answered prays to be dismissed with his costs. A Vaughan trustee Prince Edward County to wit } Personally appeared before me a Justice of the Peace for the said County A Vaughan and duly made oath that the above answer is true to the best of his knowledge & belief. Given under my hand this 23 Aprl 1847 C. R. Barksdale J.P.