Answer Filed in Open Court March 9, 1854
J. Vernon Clerk Davis & Ray Attys
Nicholas Wheeler & Nancy Wheeler
Against Common Pleas
Wesley Williams & William White
Now comes the defendants and for answer say that the consideration of the note owed on in this was two Horses, one Waggon & Harness, which the defendant White bought of the Plaintiff Nancy, and which the plaintiff Nancy fraudulently & falsely represented herself to be the true and legal owner of; but which She did not own then, before, or since; and that the same was then and still is owned by one William Hill of Iowa the Administrator of Abraham Hill, to whom said property belonged at the time of his death & to whose Estate the same belonged at the time of the sale aforesaid and further that said Administrator has demanded & still demands & claims the said property. Wherefore they say that the consideration of said note has failed, pray Judgment accordingly.
Ray, Davis & Major, Attys for the Defendants
And the plaintiffs say that the said Nancy was the owner of said wagon, horses & harness when she sold the same to said deft. Williams, and that the said property never was owned by said William Hill the administrator of the estate of Abraham Hill, dec’d, and the said William Hill never has claimed said property.