The Laurens advertiser. (Laurens, S.C.) 1885-1973, 1910-12-07

tions of fact therein contained and
also so much of paragraph 4 as alleges
any amount due and owing by this de-
fendant to said plaintiff.
A. That defendant, further answe er-
ins tic s:id complaint. ard by way of
defense thereto alleges: That hereto
fore on The 10Th day of December,
1908, this defendant end plaintiff
were married and thereafter continued
to live together as man anG wife until
the -.- lay of \ .vomhor. 1908. when
cer:"m ;ifferec 'es arose which
brou tt about temporary separation
and they lived apart until during the
! month of January, 1908, when re-
lived together from February, 1909,
until November, 1909. when a separa-
ton again occurred, which exists at
the present time. That during their
married life they had born to them
two children, both of whom are now
! living with their mother, the plaintiff
herein.
o. AS further defense of the whole
cause of action DEFENDANT alleges
That Immediately upon the marriage
of plaintiff and defendant plaintiff
turned over to this defendant as her
husband, all her property and affairs
to be managed by him to the best of
his judgment and ability for their mu-
tu,l benefit.
OBJ That the plaintiff, his said
wife, was the owner of a certain tract
of land near the town of Edgefield.
which had on account of inattention
become badly dilapidated and had very
little rental value and yielded annual
ly to her only about $3.50 from all
sources.
tC) That defendant at once under
took to improve and build up the said
place and gave it considerable time
and attention with this in view and
expended thereon large sums of money
in building and repairing houses,
fences ard otherwise building up and
improving the said place, so that as
result of his said labors, efforts and
expenditures in this behalf the said
plantation now yields revenue OF
about four times as much rs It did
originally.
6. That said improvements ard eX
penditures were made from moneys
received from his said wife from time
to time and proceeds of the place and
from his own individual funds. and in
addition to these items of expenditure
the defendant paid insurance on the
buildings and taxes on the property
and generally paid all items and
amounts of every kind incurred in ref
erence to the said plantation and other
property of his said wife, and farmed
portion of said lands himself, and
during each year paid out large sums
OF money to laborers who were en-
gagged therein during the said time.
z. That plaintiff never required and
never intended that any account
should be kept by this defendant. her
said husband. of the money and
FUNDS which came into his hands from
her property or the funds expended
thereon by this defendant from that
source and from his own private
FUNDS and no accurate account in de-
tail was kept. it being the intention
and purpose of both parties that the
| FUNDS should be used for the mutual
benefit of defendant and plaintin and
their said children as family and
they were SO used and expended.
Ihat she knew that no account was
being kept and that the funds were
being expended by both herself and
the defendant without any account
being kept and for the mutual benefit
OF both parties, which was authorized
by her and acquiesced in by her. That
large sums Of money received from
her property and from her said plan
ration were expended by the plaintiff
Tor her own personal comfort and
pleasure and in addition thereto other
large sums of money from time to
time were furnished her by this de-
fendant from his own private funds.
That this defendant also expended
during the said time on himself and
On his wife and children consider
able amount of money. That during
said time he received an annual sal
airy OF some $4,000, and in addition to
! this others sums tnat he made from
time to time, all of which was ex-
/ pended by defendant and his said wife