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Peter Simpson
vs
Bowman &c.

In this cause we expect to prove that the house & lot the sale of which has been enjoined was purchased and paid for with the money arising from the sale of the house & lot to the Plaintiff and from the sale of another house & lot sold by Lenard Bowman and the money received by him a few day previous to the purchase of the house and lot on which they now reside & the sale of which is enjoined in the Bill. That the purchase of the said last mentioned house & lot was made and the whole of the purchase money paid in the matter of September 1863. More than 6 months before the making of the deed alleged to have been made by T S Allcocke & wife to the said Lenard Bowman in trust for his wife & children. We shall therefore contend that as soon as the money was paid for said house & lot in September in September 1863 the Equitable title was vested in the said Lenard Bowman and became liable for all the debts & liabilities of the said Bowman, that he had no right to convey his property to his wife in prejudice of his creditors and of course had no right to procure any one else to make such a conveyance. That the attempt to set up the deed to his wife as a bar to the claim of the Plaintiff is an effort to accomplish by indirect means that which could not be accomplished directly. that the said Deed is fraudulent & void  The said Deed has never been recorded and was acknowledged before a Notary Public who was appointed and held his commission under the (so called) Confederate Government we expect to  that Mrs Bowman was & is the

Transcription Notes:
Lenard Bowman per letter written by his wife ---------- Reopened for Editing 2023-07-22 13:15:29