Volume 200, Volume 2, Page 451 View pdf image (33K) |
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SEWELL VS. BAXTER AND WIFE. 451 on the 4th of May, 1818. That he further applied a portion of the money so received, in purchase of the lands in Balti- more county, mentioned in the bill. That at the time of mak- ing this purchase, and frequently afterwards, her said father told respondent that a deed should be given to her for said lands, with which arrangement she was satisfied, relying upon her father so appropriating her said money as to be useful to her. That she believes her father paid for the lands at the time of taking the deed for the same, which is dated 28th of October, 1818. That besides the consideration money ($300) mentioned in this deed, he further applied about $500 more of respondent's money towards paying a mortgage on a lot of ground in the city of Baltimore, mentioned in the deed filed with the bill as exhibit A, there still remaining in the hands of her father, the sum of $262, or thereabouts, of her money. That matters so remained until the fall of the following year, and whenever spoken to on the subject, her father continually told respondent that she should have the lands and lot so as aforesaid purchased with her money. That in the fall of 1819, respondent being about to marry with her first husband, Nelson R. Hall, her father executed to her the said deed, exhibit A, that the actual consideration therefor was the said sums of $300 and $500 of her money applied by her father, and the said sum remaining in his hands and retained by him. That she thus actually paid for the lands so conveyed to her, the full consid- eration of $1,017. That having thus shown what considera- tion was paid, she declares it to be untrue, and utterly denies the allegation of the bill, that the said conveyance was made without any good or valuable consideration, or that it was made fraudulently with a design to delay, hinder or defraud the creditors of her said father. And she denies notice or knowledge of any indebtedness of her father to said Sewell or Murray, or either of them, prior to the execution of said deed. She admits that her father occupied said lands from the date of said deed up to the time of his death. That respondent resided upon them during a large portion of said period, she believes for more than ten years, and permitted her father to occupy |
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Volume 200, Volume 2, Page 451 View pdf image (33K) |
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