Samuel B. Smith vs. John Connelly and James Feron
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The answer of SamuelSamuel B Smith B. SmithSamuel B Smith of the Territory
of MissouriMissouri and CountyCounty of St Louis ofCounty of St Louis StCounty of St Louis LouisCounty of St Louis, the defendant
to the bill of complainant of JamesJames Fernon FernonJames Fernon and John

The defendant Samuel B. SmithSamuel B Smith saving
and reserving to himselfand at all times
hereafter all manner of advantage and benefit
of exceptions that may he had and taken to
the many untruths uncertainties insufficiencies
and imperfections in the said complainants bill
of complaint contained for an answer to
part of the complainants bill of complainant says
that he never made any arrangement or agree-
ment with said FernonFernon and Connelly that they
were to dismiss their action of in their
bill mentioned nor in any matter indused
there so. to. do. neither did the said SmithSmith give
them or either of them the said FernonFernon and
Connelly any promise that if they would
so do he would not prosecute his writ of enquiry
of damages against them in that behalf
nor that he would settle with them as they
allege, but he alleges and charges the fact
to be that they commenced said actionof
replevin only with a view of getting the
peltries and other articles traded for therein
mentioned in their profession and there of
their own advice and fraud dis-
missed their said action of Replevin
without that there is no matter or things in

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the said complainants bill of complaint
necessary for this defendant to make answer
to confess confess avoid traverse a
All which matters and things this defendant
is ready to maintain and prove as this
honourable Court shall award and humbly
prays to he hence dismissed with his reasonable
oath and charges most wrongfully sustained
and that the injunction of the said
FernonFernon and Connelly may be dismissed.Samuel B SmithSamuel B Smith the above named defend
ant on his oath says that the matters of fact
stated in the foregoing answer are true

J.G. Parmer

Saml Smith