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Henry Jackson was a portion, that the said Branch Bank required a large portion of the said debt to be satisfied annually under the penalty of a sale of the trust fund. And that in order that the said property conveyed by the deed might be protected from sacrifice this Respondent paid out of his own funds a large portion of the said debt, that is to say about $7000 for which he has received no compensation, that the remainder of the debt has been partially satisfied by a sale of a portion of the trust fund, and of the girl "Grace" among the rest, that upwards of $3000 yet remains due and unpaid for which the said Branch Bank holds the negotiable note or notes of James M Jackson with this Respondent as the first Indorser. That the remainder of the trust fund is not more, as this Respondent believes, than enough to pay the debt still due to the bank and the Respondent apprehends that he will altogether lose the amount which he has already paid. He herewith files sundry receipts as evidence a portion of the payments he has individually made. The girl "Grace" was purchased by John H Smith for about $600. This girl with the other two slaves mentioned and claimed in the said bill were conveyed by William B Smith absolutely to James M Jackson by an ordinary bill of sale in the year 1834 with out any condition limitation or trust therein expressed, and the said James M Jackson possessed and controled the same continually not only until the year 1842 when the said deed of trust was executed but he held and possessed the girl Grace until about the period of her sale to John H Smith in 1846, and he yet holds the others. And untill the year 1846 this Respondent never knew suspected or heard of any secret limitation or understood trust in favour of Henry Jackson. He never heard of or suspected that any claim or pretencion to these three slaves would be asserted in behalf of Henry Jackson, but always supposed and yet he believes and charges that they were absolutely and unconditionally the property of James M Jackson, and that Henry Jackson has no title or right to them whatever either in law or equity. He emphatically denies that this asserted claim of Henry Jackson to the slaves in question or either of them was known to him or was notorious in the vicinity of Farmville where James M Jackson resided or that it was known to the friends and intimate acquaintances of him or his family. Under these circumstances he insists that the conveyance of these three slaves by deed from William B Smith to James M Jackson having been absolute and unconditional, that the complainant shall not be allowed to contradict explain add to or in any wise to vary that conveyance by parol testimony. He also insists that the continual possession and control of the said slaves remained with James M Jackson more than five years and that there has never been any deed duly recorded wherein is expressed the limitation or trust now attempted to be set up in behalf of Henry Jackson and that as against this respondent who is a executor of James M Jackson, or against other creditors named by the said deed of trust the property in the said negroes must be claimed to have been absolutely in James M Jackson who was the ostensible and as this Respondent believes the real owner of the said slaves. He went upon the said trustee A Vaughan having full power to dispose of the said slaves and that the girl "Grace" although she is admitted to have been a favourite negro with James M Jackson's family was fairly sold and for a reasonable price. This Respondent having answered as fully as he is advised it is material prays the dissolution of the said injunction and that this Respondent may be allowed his costs &c P. H. Jackson