Richmond dispatch. [volume] (Richmond, Va.) 1884-1903, 1889-02-20
w. A. THOMAS'SEST
AEswER or Tag cURtT0Rs TO BETTE
LEwiCs ALLEGATIONS.
Nearly All Of Claimants Avermsnts De-
nisd-ThS Superstition Question
Did the Keys Give Possessions

IN tue tDancery Joufb yetWFudN 1ihhu ?.
Quarles snd W. X. Qusries, curators OF the
estate OF William A. Thomas. deceased, filed
a demurrer y a bill OF complaint exhibited
against them by John II. Lewis and Bette
7. Lewis bis wife.
| Answering so much Of the bill as they are
advised they ought to. the curators admit the
death OF the said Thomas, and that be died
iDtestate, but they do not know whether
Bette Lewis l. deceased's natursI child or
not or what position she held IN his house,
| bold whether that OF servant nousekeeper.
or nurse. They admit that said Thomas had
conveyed two pieces Of property in Rich
fnond. worth 5000 or 90 0o0, to trustee
| with siTiclly.gna' ded limitations, for the
beneil! OF said Bettie T. Lewis.
THE THOMAS FAMILY.
The curators have NJ personal knowledge
! OF the number Oi relations left by deceased
nor their exact degree Of relationship,
| though they are advised that there arc seye-
raj oi hrs frat cousins who survive him.
They denv that none OF the deceased's
heirs at law bad any communication with de
ceased for a number OF years before his
| death. for they are advised and believe that
deceased wss IN communication with many
oi hi. relatives and that the relation. existing
| between them were OF kindly character.
the WILL BUSINESS.
They know nothing Of the superstitions
| OF the deceased IN regard TO making VIII
on the contrary. are advised that he bsd In
! dicated his Intention TO have prepared pa
per providing for a distribution OF his nro-
| periy, the details Of which in no way CON-
| port with the present clam OF the complain
ants.
THE DONATIO MORTIs cAUsA.
The curstors deny that deceased gave to
the said Bette T. Lewis by donGiiO norris
cuusa or any other method the bulk OF
! his estate. or any part thereof, as al
legcd I'm sord bill, so as to invest her
with the ownership OF the s'me. and they
insist that the charge IN said bull that at
the time OF said alleged gift the said Will
| liam A. Thomas indicated and explained to
the said Bette +. Lewis the box in which
| the bulk OF bis most valuable securities were
contained, is fully reiuted by the circum-
stance that at the time OF the search made by
| these respondents IN the presence OF said
| Bette 4. Lewis and her counsel for said
securities, she and they eyinccd an utter ig-
norsnce OF their locality. as well as the pro-
per application OF the several keys which she
exhibited.
TIE EXHIBIT.
Aud the respondents especially deny that
at the time Of the investigation made by them
| in the presence Oi said Bette T.. Lewis and
! her counsel, "iOr q will aud into the affairs
OF the estate" as alleged in the said bill. SAID
! Bette 4. Lewis furnished them the paper
alluded to as exhibit 49, purporting to be the
| list OF the property alleged TO have been given
her by said William A. Thomas, though the
notice alluded TO in said bill purp0rted to be
accompanied by said list, and though her
| failure to fife the same was especially brought
| to her attention at the time; and they aver
| that the list filed with said bill, which
pretends 10 indicate specifically the property
! given said Bette +. Lewis as she claims, WAS
actually ObtaIned from The report made by
| these respondents after they had Gscertained
what were the assets Oi said estate by their
investigations made siuce the death OF said
| William A. Thomas.
TIE KEYS AND THE vALUABLEs.
These respondents deny that they acquired
possession Of the assets OF said William a.
! Thomas's estate BY means OF keys or aid
| furnished by Iiettie +. Lewis rs alleged ~ her
bili; but thev aver that thew acquired posses
sion OF the severa! parts OF his personal estate,
| as follows: Eighteen thousand one hundred
| NIu tlHUNN NtNtu Nbiliih HUN iui iiultio
| National Bank OF Richmond. where the same
was on deposit 10 The credit OF said william
A. Thomas, Juhiect alone in his lifetime to
bis check, and which was paid over to these
respondents by said bank as cnratOrs Of sald
| estate. and they did not and could not de
rive any aid in securing the same by the
| psss.bOok alluded TO IN said bill, tue posses
| SION Of Which said Bette 4. Lewis claimed,
and which said pass-bOok was absolutely OF
no avail ia the control or disposition OF SAID
! deposit: negotiable notes aggreRAting $50,
which these respondents found among tne
papers OF said decedeut at his residence, and
! negotiable notes, bond, stocks. gold coin,
and other securities, aggregating about $751;
| 1876, which these respondents found In a
tin box ia Apartment No. 81 in.the vault
OF the Planters National Bank, in the city OF
Richmond, Va, which apartment had been
rented OF said Planters National Bank by
said William \. Thomas.
ACCESS TO TIE VAULT.
That access TO said vault, In which was
located said apartment No. 81, could only be
had through two dOors-aD outer and an
inuer-ffst of which was locked by two
combinations and the second by one, the
KNOWLEDGE OF which WAS alone possessed by
the cashier aud bOOk-keepers OF said bank (;
that these respondents secured access 10 SAID
vault by permission Of said cashier accorded
them bv virtue OF their authority as curatOrs
OF said estate, and that they obtained access
to Apartment No. 3i and the tin box therein
by Use OF the KEYS furnished said william A..
ThOmas by tie bank when he rented SAID
vault and delivered by said William A.
Thomas in bis lifetime 10 one ;. 3. Hughes.
and by said ). b. Hughes turned over to
oe NJ NafH
estate, and these respondents did not there
fore have any occasion TO apply to said Bette
T. Lewis for the KEYS in her possession Or TO
Use the same as alleged IN said bill, and did
not make any such application.
MR.. cUARLEs's AvERaENT.
And the said Mann 5. Quares ayers that
be is the cashier OF said Planters National
Bank, SUD hls for seyersl wears held said pO-
sition, and that as such cashier be is custO-
dian Of said vault; and he ayers that no
time during tho lie OF said William A,
Thomas would he have permitted the said
Bette Y. Lewis or anv one else to secure
access into said yaull and Apartment No. 81
unless they cane authorized by the written
authority Of said William A. Thomas, made
out and signed according 10 tue prescribed
form.
The FIND.
The balance Of SAID personal property, cou-
sIsline Of three watches, one pair OF operas
glasses, aud tWeniI-sevea cents in coin,
they found IN the iron safe belonging TO
said william A. Thomas kept at the stores
house OF Drewry & Co., ana into which .aie
they secured access by the keys OF the same
furnished by SAID ;. b. Hughes, when had
been lett with MIN by said William A.
Thomas Ia bis lifetime ss aforesaid.
These respondents. further answering said
bill, deny ITS allegation that the said Bettie I.
Lewis delivered 10 them toe eabOye-de>cribed
property Of said William A. Thomas.
They aver that they obtaDed possession OF
tue same IN the manner above set forth, and
that with the exception OF the notes found at
his residence amounting to SSiOl and the
few articles found 10 the aforesaid safe at toe
storehoUse OF Drewry & Co. The said Bette
T. Lewis never had possession, actual or
constructive, oi said property. snd nothing
that she could have done would have assist
ed or hinderei these respondents 10 securing
absolute POSSESSION Of the same.
Tia BUNCH or KEYS.
These respondents admit that al the time
OF The Investigation made by them 10 End
Thartsc k4A fatt