The answer of William Bourne & Creed C Carter administrators de bonis non of the estate of Thomas Clasby decd. to a bill of complaint exhibited against Thomas Hales decd. late administrator of said Thomas Clasby in the County Court of Amherst by Joseph Dillard.
These respondents saving and reserving to themselves the benefit of all. Just and necessary exceptions which might be taken to the said plaintiffs bill of complaint for answer thereto, or as much thereof as they are advised it is proper or material for them to answer, answering say That they have no personal knowledge of any of the matters and things related, to or alluded to in the plaintiffs bill in relation to the sale and purchase of the negro Edmund, they cannot therefore, admit any of the allegations made by the said plaintiff in his said bill of complaint to be true - only that said plaintiff purchased the negro Edmund of the Intestate of these respondents at the time and for the price therein stated.
These respondents are informed and verily believe, that the facts and circumstances leading to, and attending the sale by their Intestate, and purchase by said plaintiff of the negro Edmund were these. The said Thomas Clasby who was the owner of said negro Edmund previous to the sale, to said Dillard, was anxious to sell said negro, because of his constant habit of running away, and unwillingness to live with said Clasby; for the purpose of procuring a sale to the said Clasby applied to the pltff who was in the habit of buying and selling the species of property, to sell said negro for him, and as an inducement to the pltff to make the necessary exertions to effect a sale, promised to give him all over a fixed price which could be procured for said negro - this proposition the pltff acceded to, and accordingly sent to Mr. [blank] Smith who was then overseer for the pltff, with a letter addressed to the said Clasby requesting him to send on said negro to him by said Smith, which was done - after the said negro had remained with said plaintiff and in his