Hughe, John E., etc. v. Bruin, Joseph, etc.: Chancery Cause, Arlington County
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1. The answer of James H. Simpson to a bill of complaint filed against himself and Joseph Bruin, in the Circuit Superior Court of Law and Chancery for Alexandria County, by John C. Hughes and others. This defendant saving and reserving all exceptions to the many errors imperfections and untruths in said bill obtained, for answer thereto, or to so much thereof, as he is advised is material for him to answer, saith - That he Knows nothing of the alleged claim of the complainants, nor of the sale said to have been made by the Marshall of the District of Columbia, nor of the purchase made thereunder, nor of any of the facts connected therewith, otherwise than is set forth in said bill of complaint. Neither does this defendant Know the name of the mother of the negro girl Mary Catherine, but calls for strict proof of all such matters alleged in the said bill. And further answering this defendant states that on the 16th day of February 1849, he as agent for Bruin & Hill purchased of Frederick Vaccari of the Town of Alexandria, a negro girl slave for life, called in the bill of sale Mary Catherine Wilson, for the sum of Five hundred dollars, which he paid to said Vaccari on obtaining possession of said slave, and took from him a bill of sale, which with the said negro, on the day of said purchase, this defendant delivered to Joseph Bruin one of the firm of Bruin & Hill at their place of business in the County of Fairfax. That at the date mentioned said Bruin was confined to his house by sickness. On or about the 23rd day of February 1849, this defendant as the agent for said Bruin & Hill carried the said slave Mary Catharine with some twelve other slaves to Griffin in the state of Georgia, and then about the 26th day of February