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John Tayloe vs. William Willis, etc.: Chancery Cause, Lynchburg City (Part 1 of 2)

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To the Hon'ble Creed Taylor Judge of the Superior Court of Chancery holden in Lynchburg, the separate answer of William Willis to a bill filed in the said court by John Tayloe. This respondent saving to himself all benefit of exception that it may hereafter be necessary for him to make to the many errors or mistatements in the said Bill contained, for answer saith that he is the son in law of the other Deft and at his instance carried the two negroes in the Bill mentioned to the town of Lynchburg to sell, This respondent as the agent of Richard Dabbs set up the negroe man to sell at the highest bidder, and after he had been cried out, to a stranger whose name I have forgotten, the complainant said he would have bought the man and his wife and would give $950 for the two, and agreed to give that price if the man could be got back, whereupon this respondent prevailed on the purchaser of the man to be off and delivered them both to the complainant at that time Mr Phaup was by and said to this respondent in the presence of Tayloe if any thing is the matter with the negroes now state it, whereupon this respondent said that one of the mans toes was frostbitten. Tayloe examined the toe and said that was nothing This respondent verily believed the negroes were both sound and healthy at the time except the frost bite on the toe, as aforesaid, and had he been called on to warrant them sound and well he would most readily have done so. but he denies expressly having made any representations whatsoever about their health except that above stated, Tayloe made the offer of the price and your respondent said nothing about it