David CoonsDavid Coons did not at any time before the death
of said duty keep a regular and full set of
mercantile books and accounts, but on the con
trary kept his accounts in memorandum books
and on memorandum papers - that he did for
the most a cash business, and that most
of his transactions in the trade were settled at the
time they were made either by payment in cash
or by note or memorandum and that no other
record or duty of many of his transactions were
ever made - and therfore these defendants are
to obtain from the books and accounts of their
testator and a full knowledge of his transactions
and accounts with said Duty.
But these defendants
are informed by these who were acquainted with
the business of their testator and with his transactions
with said Duty, and so believe, that the demands
allowed in favor of said David CoonsDavid Coons against the
Estate of said Duty then in the Probate Court
occured in the following manner- viz - First -
an account for merchandize purchased by said
Duty of said David CoonsDavid Coons between the 11th day of June 1838 and the 18th of July following amounting
to the sum of twenty dollars and fifty cents
Secondly: a note of said Duty in favor of said David CoonsDavid Coons
for twelve hundred sixty three dollars and forty seven
cents dated the Eleventh day of June A.D. 1838
payable four months after date being for money advanced
and for merchandise sold by said DavidDavid Coons
CoonsDavid Coons to said Duty
Thirdly a note for the
sum of one thousand and ten dollars and sixteen
cents dated the fifteenth of June 1838 payable
four months after date executed by said Duty

to said David CoonsDavid Coons in consideration of cash
advanced and merchandise sold by said DavidDavid Coons
CoonsDavid Coons to one Jesse JonesJesse Jones , to that amount ot the request of
said Duty, the said Duty being at the time
indebted to the said Jesse JonesJesse Jones to the full
amount of said note.
Fourthly - one other
note for the sum of twelve hundred and seventy
eight dollars and sixteen cents,
dated the 24th February A.D.1838 payable one
day after date, given by said Duty to one Wm. P. Stephenson, and by said Stephenson
endorsed to one David GentryDavid Gentry and
by said David GentryDavid Gentry assigned to said DavidDavid Coons
CoonsDavid Coons in his lifetime for a valuable consid
eration and with the knowledge and approba
tion of said Duty, which said last mentioned note was
excuted by said Duty to said Stephenson for
a valuable consideration; and was wholly
due and unpaid at the time of the assign
ment thereof to said David CoonsDavid Coons and
also of the time of the death of said Duty
These defendants utterly deny all
fraud, confederation, conspiracy and unfairness
on the part of themselves or of either of them, and
also utterly deny all knowledge
of fraud, confederation, conspiracy
or unfairness on the part of their testator where
with he is charged in said Bill
Their defendants further state that they have
not nor has either of them any knowledge
in relation to any other matter or thing in
said Bill alleged or charged to which they have
not herein above made special answer.