Hughe, John E., etc. v. Bruin, Joseph, etc.: Chancery Cause, Arlington County
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The answer of Joseph Bruin to a bill of complaint filed against himself and James H Simpson in the Circuit Superior Court of Law & Chancery for Alexandria County by John C Hughes and others. This defendant saving and reserving to himself all benefit of exception to the many errors imperfections and untruths in said bill contained, for answer thereto, or to so much thereof, as he is advised is material for him to answer, saith: That he is not informed, except by said bill of complaint, and therefore does not admit that Amelia Hughes is the widow, and that the other complainants are the children and distributees of Edward Hughes decd. nor that he died intestate, and that no administration has been taken on his estate. Neither does he admit, the sale and purchase as alleged of negro woman Ann, under an execution against Edward Hughes, nor the pretended terms thereof, but of all the allegations in said bill in reference to the aforesaid matters, this defendant demands stric proof. This defendant for the same reason demands proof, that the negro girl Mary Catharine in the bill mentioned is the daughter of the said negro woman, Ann, and of all the matters stated in reference to the history and title of said slaves- denying as this defendant believes he is justifiable in doing, all the charges in said bill except such as are hereinafter and omitted, until they are established, if they or any of them, can be, by competent evidence. This defendant admits that one Henry P. Hill and himself are engaged as partners under the firm name of Bruin & Hill in purchasing slaves for transportation, and sale, in the Southern States. That in the month of February last, whilst this defendant was confined to his room, by sickness, and partner Hill was in the South-their agent James H. Simpson purchased of Frederick Vaccari, of the Town of Alexandria, a negro girl called in the bill of sale, "Mary Catharine Wilson" for whom he paid the sum of five hundred dollars. The purchase appears from the bill of sale which is herewith filed, as an exhibit marked (A) to have been made on the