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that he had an agent in Selma who attended
to all his business, yet he never approached
said agent and said not a word to him
about any claim against the said William
C, so notorious was the incapacity of the said
William C for the transaction of business that
your orators regard it as incredible that the
said Brown would have made a secret
settlement with him, and have taken his
note for so large an amount, if his
pretended claim had been just, and would have
born scrutiny

§ 10.

The said Brown has never pretended to
show any consideration for said note, nor
do your orators know even to this day,
what he pretends or claims to have been
the consideration, saw only by incidental
remarks of his Counsel before the Jury, So
far as your orators know and believe there
were never any dealings between the said
Brown and William C, by which the latter
could have become indebted to Brown, except
for his wages as overseer, and his wages,
as your orators believe and charge were
greatly overpaid by monies secured from said
blacksmith shop without reference to
amounts received by him from other sources
your orators can concieve of no way whereby
the said Brown could have acquired a just
claim against the said William C, to any
thing like the amount of said note, He had
ample means at Selma at command at
all times to supply his wants even to
extravagance, He made large cotton crops at
his plantation near Selma as well as the
one under charge of Brown and moreover
had large amounts due him, considerable
sums from which were coming into the
hands of his agent at Selma, His
income annually was greatly beyond his
wants and expenditures, and was always
at his command as no one had the
authority to restrain him

§ 11.

The said note of $2221.- procured of the
said William C, under the circumstances