The herald and news. [volume] (Newberry S.C.) 1903-1937, 1910-12-06
S15,9O5.08
By Credit.

ny CaSQ IrOm rent, I0Vo.. oo0'0'
Yotal Indebtedness. ,9oo.Oe
Total credits. .. >. z,S5Z.oo
Balance due. =. ..Sl3,O|3.Oe
stata Of South Carolina, County Of
Edgedeld.
Personally appears Lucy Dugas
Pillman, who on oath says that she
has read the foregoing complaint and
that same is true Of her own knoWl-
edge except those matters stated on
Information and belief and as to those
she believes them to be true.
Lucy Dugas Tillman.
Sworn to before me this 7th day OF
November, 1910.
Edwin II. Wells,
Notary Public for South Carolina.
Answer.
The defendant herein for answer to
the complaint Of the above named
rlaintiff shows unto the court and
alleges:
i. That all Of the allegations of the
said complaints which pc not herein
after specifically adm4.ted are denied
2. That the allegation of paragraph
1 is admitted and so much of para
graph as alleges demand on this
defendant for payment and his re-
fusal. : -
3. That the allegations Of fact in
paragraphs 2 and are incorrect and
kaintiff - mis- AIKEN ~ :er aNa51.
tions of fact therein contained, and
also so much OF paragraph as al
leges any amount due and owing by
this defendant to said plaintiff.
4. That defendant, further answer
ing the said complaint, and by way of
defense thereto alleges: That hereto
fore, on the 29th day of December,
1903, this defendant and plaintiff were
married and thereafter continued to
live together as man and wife until
the - day Of November, 1908, when
certain differences arose which
brought about a temporary separation
and they lived apart until during the
month Of January, 1909, when a re-
cancellation was had and they again
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.
5. AS further defense of the whole
cause Of action defendant alleges:
That Immediately upon the marriage
of rAaintiff 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-
tual benefit.
(B) That the plaintiff, his said wife,
was the owner of certain tract OF
land near town Of Edgefeld, which
had on account Of inattention become
badly dilapidated and had very little
rental value and yielded annually to
: her only about $3.50 from all sources.
(C) That defendant at once under
took to improve aid 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 ard repairing houses,
fences and otherwise building up and
improving the said place, so that as
"a result of his said labors, efforts and
expenditures in this behalf the said
plantation now yields a revenue OF
about four times as much as it dld
originally.
6. That said improvements and ex-
nenditures 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
arenca to the said plantation and other
property of his said wife, and 1armed
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.