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if he could, the names & ages of the negroes, in order to file his answer to the original Bill, more understanding by this respondent did not then discover the endorsement on the back of the Bill of sale nor the interlineation of the word "redeemable" on the face because he made no examination of it himself but requested Mr. Worsham to examine for these facts, the names and ages of the negroes, and having obtained the information, that paper contained, on that subject, he left the office.  Mr Worsham at an after time, told this Respondent that he Mr Worsham had discovered on that day, the endorsement on the back, and the interlineation on the front of the Bill of Sale, after this Respondent had left the office.  This Respondent also denies that he ever made the interlineation on the face of the Bill of sale of the word "Redeemeth" or that he ever authorized any other person to make such interlineation for him, or that that mark was there whilst the paper was in the possession of this Respondent.  This Respondent also denies that he ever made any attempt to erase the said endorsement or interlineation "by scratching them out" nor did he ever know that these things were on the back and face of the Bill of sale until after the plff had filed his amended Bill and the counsel of this Respondent sent for him to make his answer to this new state of things when the paper was shown to this Respondent and Mr Worsham the Clerk then told him that he had seen these things on the back and face of the Bill of Sale when he last looked at the paper for him, about the 1st of August 1852, to give the names and ages of the negroes  This Bill of sale with this endorsement on the back and the interlineation on the face with the appearance of erasure on both still remains in the Clerks office of this Court among the papers in the Cause of Bradley vs Stevens, where the Bill of Sale has been continually since the 15th day of September 1847 when it was filed with the deposition of B.J. Worsham, and marked (A)  to which this plff and this Respondent can have ready and easy reference.  And this is the only way, in which, at this time, this respondent prefers to exhibit that paper.  The endorsement on the back of said Bill of sale and the interlineation on the face before spoken of This Respondent charges to be a forgery. And he believes and therefore charges that the "scratching" was not done on that paper with a [view?] to obliterate the endorsement or the interlineation, but to present that appearance, whilst the whole should be left perfectly legible and he believes and therefore charges that this whole work has been done very Recently and that it was done in order to effect that which the plff alleges in his amended Bill it has effected when he says  "all of which go to Sustain the allegations of the original "Bill" This Respondent confidently believes that the opposite will be the effect of this new exhibition fortunately for this respondent the endorsement and the interlineation and the [pretended?] erasure all bear the appearance of a very recent transaction and the handwriting, which is perfectly legible, is plainly not the hand writing of this respondent and it is not the hand writing of his nephew George W Bradley who in 1845 was in the habit of doing most if not all the writing for this defendant  The endorsement bears date 4th June 1845  There is an attempt to imitate the hand writing of this respondent but it is a decided failure and though the hand is disguised he thinks it betrays its author  There are other persons as this Respondent believes having more interest in, and feeling more concern about the result of this suit than the plaintiff himself.  This plaintiff about the year 1849 or 50 instigated and assisted as he believes by a portion of the same persons who are now doing the same thing set up a pretended demand for these negroes claiming a right to redeem them under a pretended contract which he said he held from this respondent and pretended to show the said contract of which this Respondent heard and charged at once that he never gave such a paper, and that any paper held by said plff of such import, was a forgery.  The claim thereupon seemed to
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if he could, the names & ages of the negroes, in order to file his answer to the original Bill, more understanding by this respondent did not then discover the endorsement on the back of the Bill of sale nor the interlineation of the word "redeemable" on the face because he made no examination of it himself but requested Mr. Worsham to examine for these facts, the names and ages of the negroes, and having obtained the information, that paper contained, on that subject, he left the office.  Mr Worsham at time, told this Respondent that he Mr Worsham had discovered on that day, the endorsement on the back, and the interlineation on the front of the Bill of Sale, after this Respondent had left the office.  This Respondent also denies that he ever made the interlineation on the face of the Bill of sale of the word "Redeemeth" or that he ever authorized any other person to make such interlineation for him, or that that mark was there whilst the paper was in the possession of this Respondent.  This Respondent also denies that he ever made any attempt to erase the said endorsement or interlineation "by scratching them out" nor did he ever know that these things were on the back and face of the Bill of sale until after the plff had filed his amended Bill and the counsel of this Respondent sent for him to make his answer to this new state of things when the paper was shown to this Respondent and Mr Worsham the Clerk then told him that he had seen these things on the back and face of the Bill of Sale when he last looked at the paper for him, about the 1st of August 1852, to give the names and ages of the negroes  This Bill of sale with this endorsement on the back and the interlineation on the face with the appearance of erasure on both still remains in the Clerks office of this Court among the papers in the Cause of Bradley vs Stevens, where the Bill of Sale has been continually since the 15th day of September 1847 when it was filed with the deposition of B.J. Worsham, and marked (A)  to which this plff and this Respondent can have ready and easy reference.  And this is the only way, in which, at this time, this respondent prefers to exhibit that paper.  The endorsement on the back of said Bill of sale and the interlineation on the face before spoken of This Respondent charges to be a forgery. And he believes and therefore charges that the "scratching" was not done on that paper with a [view?] to obliterate the endorsement or the interlineation, but to present that appearance, whilst the whole should be left perfectly legible and he believes and therefore charges that this whole work has been done very Recently and that it was done in order to effect that which the plff alleges in his amended Bill it has effected when he says  "all of which go to Sustain the allegations of the original "Bill" This Respondent confidently believes that the opposite will be the effect of this new exhibition fortunately for this respondent the endorsement and the interlineation and the [pretended?] erasure all bear the appearance of a very recent transaction and the handwriting, which is perfectly legible, is plainly not the hand writing of this respondent and it is not the hand writing of his nephew George W Bradley who in 1845 was in the habit of doing most if not all the writing for this defendant  The endorsement bears date 4th June 1845  There is an attempt to imitate the hand writing of this respondent but it is a decided failure and though the hand is disguised he thinks it betrays its author  There are other persons as this Respondent believes having more interest in, and feeling more concern about the result of this suit than the plaintiff himself.  This plaintiff about the year 1849 or 50 instigated and assisted as he believes by a portion of the same persons who are now doing the same thing set up a pretended demand for these negroes claiming a right to redeem them under a pretended contract which he said he held from this respondent and pretended to show the said contract of which this Respondent heard and charged at once that he never gave such a paper, and that any paper held by said plff of such import, was a forgery.  The claim thereupon seemed to

Revision as of 20:02, 4 June 2020

if he could, the names & ages of the negroes, in order to file his answer to the original Bill, more understanding by this respondent did not then discover the endorsement on the back of the Bill of sale nor the interlineation of the word "redeemable" on the face because he made no examination of it himself but requested Mr. Worsham to examine for these facts, the names and ages of the negroes, and having obtained the information, that paper contained, on that subject, he left the office. Mr Worsham at time, told this Respondent that he Mr Worsham had discovered on that day, the endorsement on the back, and the interlineation on the front of the Bill of Sale, after this Respondent had left the office. This Respondent also denies that he ever made the interlineation on the face of the Bill of sale of the word "Redeemeth" or that he ever authorized any other person to make such interlineation for him, or that that mark was there whilst the paper was in the possession of this Respondent. This Respondent also denies that he ever made any attempt to erase the said endorsement or interlineation "by scratching them out" nor did he ever know that these things were on the back and face of the Bill of sale until after the plff had filed his amended Bill and the counsel of this Respondent sent for him to make his answer to this new state of things when the paper was shown to this Respondent and Mr Worsham the Clerk then told him that he had seen these things on the back and face of the Bill of Sale when he last looked at the paper for him, about the 1st of August 1852, to give the names and ages of the negroes This Bill of sale with this endorsement on the back and the interlineation on the face with the appearance of erasure on both still remains in the Clerks office of this Court among the papers in the Cause of Bradley vs Stevens, where the Bill of Sale has been continually since the 15th day of September 1847 when it was filed with the deposition of B.J. Worsham, and marked (A) to which this plff and this Respondent can have ready and easy reference. And this is the only way, in which, at this time, this respondent prefers to exhibit that paper. The endorsement on the back of said Bill of sale and the interlineation on the face before spoken of This Respondent charges to be a forgery. And he believes and therefore charges that the "scratching" was not done on that paper with a [view?] to obliterate the endorsement or the interlineation, but to present that appearance, whilst the whole should be left perfectly legible and he believes and therefore charges that this whole work has been done very Recently and that it was done in order to effect that which the plff alleges in his amended Bill it has effected when he says "all of which go to Sustain the allegations of the original "Bill" This Respondent confidently believes that the opposite will be the effect of this new exhibition fortunately for this respondent the endorsement and the interlineation and the [pretended?] erasure all bear the appearance of a very recent transaction and the handwriting, which is perfectly legible, is plainly not the hand writing of this respondent and it is not the hand writing of his nephew George W Bradley who in 1845 was in the habit of doing most if not all the writing for this defendant The endorsement bears date 4th June 1845 There is an attempt to imitate the hand writing of this respondent but it is a decided failure and though the hand is disguised he thinks it betrays its author There are other persons as this Respondent believes having more interest in, and feeling more concern about the result of this suit than the plaintiff himself. This plaintiff about the year 1849 or 50 instigated and assisted as he believes by a portion of the same persons who are now doing the same thing set up a pretended demand for these negroes claiming a right to redeem them under a pretended contract which he said he held from this respondent and pretended to show the said contract of which this Respondent heard and charged at once that he never gave such a paper, and that any paper held by said plff of such import, was a forgery. The claim thereupon seemed to