1792-07-12 (static/transcriptions/1792/07/080.jpg)

Scheme of the said Complainants to protect it against his Creditors which Mortgage and all other Securities for money and other papers ever delivered to this Defendant the amount of which is not Credited in this Defendants accounts here after mentioned are now in this Defendant’s possession and ready to be delivered to him in this Defendants receiving payments of the Balance of such amount this Defendant farther answering saith he admits that some of the papers in the Schedule annexed to the Bill marked C were delivered to this Defendant by the Complainant but as to other papers all those delivered to this Defendant were of no Value and are more ready to be delivered to the said Complainant on this Defendants account being settled and the balance thereof paid this Defendant further answering saith he during that was the said Complainant did directly or indirectly apply to the Defendant for an account and payment of any money or Balance whatsoever on the Contrary this Defendant Saith that the said Complainant well knowing how much money he this Defendant was in advance for him has for these twelve months last [ILL] avoided coming to any account with this Defendant tho’ during the whole of that time