| Volume 200, Volume 2, Page 396 View pdf image (33K) |
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396 HIGH COURT OF CHANCERY. ing her. He admits, that through the unwarranted apprehen- sions of the complainant, he was compelled to give' security to keep the peace, in order to be released from imprisonment, but denies, that he has forfeited his recognizance by renewing as- saults upon her, or in attacking her with fire arms. He denies that he ever did attack her with any instruments of death, or ever forced her with her child, to seek refuge in the houses of her neighbors. On the contrary, he has always treated this child of the complainant with kindness. On one occasion, at great ex- pense, taking him and his mother to Baltimore, to consult with an eminent physician, on account of his health. That in com- plainant's excessive indulgence of this child, which respond- ent has endeavored to correct, by teaching him obedience and respect to his superiors; and in her improper protection of this negro boy, in his impudence and wilful disobedience, most of the unpleasant misunderstanding between complainant and this respondent has originated. He positively denies the charge of adultery, and that he has ever been guilty of adulterous in- tercourse with other women. He admits the statement of the bill, in regard to the property of the complainant, the institu- tion of suits, &c., and that the child above referred to, is the only child of complainant, and that respondent has no child or other person dependent upon him for support, except the complainant and her said child in part, for without bis labor, and the aid and assistance derived from his property, complain- ant and her family could not have been supported. He admits he was at the time of his marriage, and still is, possessed in his own right of personal property, as stated in the bill, but avers that much of his property, held by him before his marriage, and all his earnings since, have been expended in supporting the family of the complainant, putting up buildings on her dower estate, and various other improvements thereon. He denies the right of the complainant to file this bill or to have any relief thereby sought. On the 23d of December, 1850, Brice T. B. Worthington, the solicitor of the complainant, filed a petition stating that his |
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| Volume 200, Volume 2, Page 396 View pdf image (33K) |
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