Peter Primm vs. John Lane, James Mackey, John Bolly, and Jeduthan Kendal
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Territory of MissouriMissouri SS

The Several answer of JamesJames Mackey /MackeyJames Mackey to
the Bill of Complaint of PeterPeter Primmcomplainant
against JohnJohn Bolly BollyJohn Bolly this respondant & others.

The Said JamesJames Mackey MackeyJames Mackey now and at all times
therefore saving to himself all and all manner of advantage
of expection to the many untruthserrors uncertainties and imperfections
in the said Bill of Complaint contained for answer
there to say that he is altogether ignorant of any of the
transactions of the said PeterPeter Lane & Boli as charged in the
said complaint except what the said BoliBolly & Primm have
informed him that on the first day of April on the year one thousand eight hundred & Twelve the Said BolyBolly came to
purchase of this Defendant a negro woman & two childrenand promised
to give him four hundred Dollars in cash and horse of one
LaneLane & PeterPeter Primm for two hundred Dollars - that said BoliBolly
proposed to the Defendant to take the same without recourse
and this defendant knowing PeterPeter Primm and believing that
he was as honest man and able to pay the said sum
although he did not know the said John LaneJohn Lane , inquired of
said BoliBolly for what consideration the said horse was given, &
said BoliBolly informed him that it was for a seedhorse
sold to said LaneLane , & that Primm was security - That this
Defendant did thereupon agree with said BoliBolly , to sell him
the said negro woman & twochildren for the sum of Four
Hundred and twenty Dollars in cash & said horse on LaneLane &
Primm& then & there delivered said BoliBolly said negro
wench & children and receiving said sum of money and
said horse in payment, and took on assignment on
said note without recourse that he took the land

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assignment in that may because he knew Primm to
be able to pay that sum : and on the appearance of
said BoliBolly that the consideration of said Note was a
seedhorse that after the said assignment he called
upon LaneLane , for the money. and LaneLane told him he had made
Primmsecure and wished to give this defendant twenty or
thirty Dollars to get that security out of the hands of Primm
but this defendant whollydeclined it That this deponent
also called on Primm for the payment, and said Primmhad
several times him told him that he had signed said note that
LaneLane had put a pocket Book with some papers in his
hands as his security and him suggested any fraud - or
imposition in obtaining said note on his signature
to the same And this defendant did assign the
said note to the said JeduthanJeduthan Kendal KendalJeduthan Kendal without recourse in
the same way for value of said KendalKendal received in a
concessionfor Land bought of said KendalKendal that this
defendant knows nothing of any fraud in obtaining said
note nor in any of the subsequenttransactions and
this defendant denies all and all manner of unlawful
combination and confidency in the complaints bill charged
against him, without that that there is any other matter
or thing in the said complainants said Bill contained
material or effective for this defendant to answer unto
and nor herein and hereby sufficiently answered unto
confessed or avoided traversed or denied is true to the
knowledge and belief of this defendant - all which
matter and things this defendant is ready to aver
maintain and prove as this Honorable court shall award