daughter Mrs. Jackson, who he said was much attached to her. And he then proposed to Respondent to buy the Girl of him. Respondent asked Partin what he would give for her; Partin said he would give $500 which he considered more than her value for that she was not as valuable as she had been represented to be. Respondent informed Partin he had paid more than that sum for her, and would not accept his offer. Partin then offered $550. and said he would give no more for her, and that he would not give that price but to gratify his daughter. Respondent declined the offer and received the Girl from Partin & brought her home with him and has owned her ever since Respondent utterly denies that he ever heard any intimation whatever, from any source of the claim now asserted by and for the infant Complainant until after he had purchased and paid for the Girl, and upon inquiry in the Town of Farmville and its neighborhood since the institution of this suit, he has been unable to find the first individual who ever heard that Henry Jackson had any claim to Grace, until this suit, for Partin himself had been endeavouring to purchase the said Girl, for sometime before your Respondent purchased her, and only failed to do so, because he was unwilling to pay the price commanded, as Respondent has been informed and was himself willing to purchase her as the property of James M Jackson Respondent does not doubt that all the allegations of Complainants bill have been made upon the representation of the said Pleasant Partin, and so far as they charge your Respondent with a knowledge of any claim on the part of Henry Jackson he wholly Denies this both as to the statement of the bill in regard to the Manner in which and the objects for which said Partin purchased the woman Mary and her children this respondent knows nothing and consequently their allegations must be proved. As to what sort of bill of sale was Executed he knows noting, and he never heard until this suit that either Mary, Anthony, or Grace were the property of henry Jackson the infant Complainant. He only knows that James M. Jackson for many years prior to 1842 had possession of said slaves, that they were regarded in Farmville and its neighborhood as his property and he finally disposed of the whole of them as his own by conveying them by deed of trust to A Vaughan trustee as aforesaid in the year aforesaid & from that time until the sale & purchase of the Girl Grace, no claim was ever set up to her, either by Pleasant Partin or any other person, but all by their silence, at least, acquiesced in the propriety of the conveyance I & Jackson had made at least in his indisputable right to make a [marked?] conveyance of them. Respondent claims that he has fairly purchased and fully paid for said Girl & prays the Court to dissolve the Complainants injunction and dismiss his bill. Having fully answered he prays to be hence dismissed with his costs in this behalf expended. John H. Smith Prince Edward County to wit: John H. Smith came personally before me a justice of the peace in and for the County aforesaid and made oath that the facts stated in the foregoing bill are true so far as stated on his own information, and so far as stated on his own information he believes them to be true. Given under my hand this 21st day of April 1847 [Joseph?] Venable J.P.