1791-11-24 (static/transcriptions/1791/11/286.jpg)

328)

And this Defendt particularly denies that the said two Deeds or Instruments were forged by this Defendt and the said Cojah Zekeriah. And this Defendt further denies that the said Cojah Zekeriah at any time whatever & particularly in the month of Shawul in the Fussully year 1184 came to this Defendt and that in a conversation (which it is pretended he and this Defendt then held together upon the subject of excluding the Complainant Behader Beg from any particular share or inheritance of or in the Estate and Effects of Shabaz Beg Khan) the said Zekeriah informed this Defendt that he had for that purpose prepared a deed of Gift or Hebanamah and a Deed of General Declaration by which she this Defendt would become sole proprietor of the whole. And this Defendt positively denies that any such conversation to such or the like puport or effect as last aforesaid ever took place at any time whatever between this Defendt and any person whatever. And no such conversation having passed between this Defendt and the said Cojah Zekeriah she this Defendt could not and did not so caution the said Zekeriah as in the said Bill of Complaint is for such purpose falsely setforth. And this Defendt denies that she ever at any time whatever cautioned any person whatever to any such or the like purport or Effect & particularly
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