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welfare of the society, and the discipline of that Yearly Meeting was considered and acted upon as the rule and order to which all the meetings and members in this country were held amenable, and over the adjudications in important cases in the said Yearly Meeting here, the Yearly Meeting of London held appellate jurisdiction, which was recognised and submitted to; but in process of time, the Yearly Meetings in this country having been firmly established, and having made and adopted rules of discipline for the well ordering of the inferior meetings under their control, and their respective members, the said Yearly Meeting of London ceased to exercise any further jurisdiction over them; nevertheless the Yearly Meetings in this country and London are still considered, with the exception of the newly organized Hicksite Yearly Meetings, as one compact body of christian professors, united in faith and doctrine, in the forms of discipline and mode of government, and there is a regular advisory correspondence existing accordingly with all the Yearly Meetings of the true Society of Friends in this country and London. This defendant, in further answering, denies the position that there is no subordination of the inferior to the superior meetings of discipline aforesaid. On the contrary, he says that Quarterly Meetings do possess a power over Monthly Meetings, further than merely to advise and assist them in difficult cases on their application; that the Yearly Meeting is not a mere organ of communication without any controlling power-that an appeal lies from the Monthly Meeting to the Quarterly Meeting, from which it is taken, in the last resort, to the Yearly Meeting; that besides this appellate jurisdiction which the superior meetings exercise as aforesaid, over the inferior meetings, there is in the superior meetings an original power of supervision over the conduct of the inferior meetings, requiring no appeal to call it into action; he further says that there is a power to establish and lay down Monthly Meetings, vested in the Quarterly Meetings, and to establish and lay down Quarterly Meetings vested in the Yearly Meeting.

And this defendant, in further answering, denies that a few individuals who had long been continued in important stations, gradually and covertly, began to assume an authority over their brethren never delegated to them, and that they attempted to impose upon the Yearly Meeting a document in a form designed to operate as a written Creed, as stated in said bill of interpleader. On the contrary, he says that the document styled a written Creed, was only a selection from approved and recognised doctrinal writings of the early Quakers, designed to place the principles and religious doctrines of the Society of Friends in a clear and a fair view before the public, they having been greatly misrepresented by an anonymous author in one of the public papers. This defendant denies that a party was organized assuming the character and title of the Orthodox, and that a line of discrimination was attempted to be drawn through the different meetings,

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in order to fill every active station with those under their particular influence, and that in pursuit of this plan they manifested the most inflexible determination to carry their measures, in order to bring their fellow members, possessing equal rights, under their control-that the discipline of the society was in many instances prostrated and obviously violated, as well to screen transgressors of their own party, as to procure the disownment upon vague and frivolous charges, of those who opposed their spirit and measures-that approved ministers were publicly opposed in a disorderly manner-faithful members who bore a testimony against their systematical declension from the principles and practice of the society, were not only treated with marked disrespect and contumely, but were actually proscribed, as stated in said bill of interpleader. On the contrary, he says that the ministers and members opposed, were those who were instrumental in disseminating the doctrines of Socinianism, entertained by the Hicksite party, as above set forth, and in opposing them they did not violate the discipline of their society, but were carrying it into effect, according to the usages and in support of the true doctrines of their society. And this defendant denies that the Hicksite party have settled again the Yearly Meeting of Philadelphia on the principles of its first institution or according to the usages of the society, in forming new Yearly Meetings within the pale of the jurisdiction of a Yearly Meeting already subsisting; on the contrary, those usages have been violated by them, and the said Hicksite party have attempted to displace members of the society holding important stations, because they did not approve of the doctrines of Elias Hicks, withdrew and seceded from the ancient and established Yearly Meeting at Philadelphia still in existence, and formed a new one of their own, contrary to the order and discipline and ancient usages of the Society of Friends, and on the ground of their entertaining doctrines different from those of the Society of Friends, called and known by the name of the Orthodox party. That although they pretend to a majority of members as furnishing the authority for their proceedings, contrary to the usages of the society and the spirit of its institutions, yet it is believed that taking the said Yearly Meeting through as it stood prior to their secession as aforesaid, they composed not much more than half of that body, and that their party, taking into view the whole Society of Friends, are a minority. And this defendant, in further answering, says, that in respect to papers of disownment, alluded to in the said bill, they had been issued against individuals who had virtually seceded from the Society of Friends, by uniting themselves with those who had irregularly set up new meetings under their newly organized and irregular Yearly Meeting aforesaid, and who had adopted the Hicksite doctrines aforesaid. And although it is denied that the principle of deciding by majorities was ever recognised by the Society of Friends, yet in some of the meetings where such papers of disownment were

issued, the majority has been against them. And this defendant says, that the said Orthodox party believing as they do, that they are the true Society of Friends, that the property owned and held by that society prior to the secession, was not held by them individually, but under a solemn trust for the use and benefit of the true Society of Friends, they cannot consistently with their views of duty and of right, undertake to divide and apportion it with the seceders; but they conscientiously believe that it ought still to be devoted to the sacred purposes to which it was originally set apart, and that the said seceders, abandoning, as they have done, the faith of their fathers, ought quietly to retreat, without carrying with them the property and funds of the religious institution from which they have thus seceded. This defendant, in further answering, denies that he has withdrawn himself from the true Society of Friends-On the contrary, he says that the said complainant and the said Stacy Decou, are not members of the true Society of Friends, and that the said Stacy Decou is not the lawful treasurer of the said school fund, and that the interest of this defendant as the obligee of the said bond and mortgage and the money thereby secured, is not in law transferred to him; he admits that the said funds are the property of the Preparative Meeting at Crosswicks, but not of the alleged Preparative Meeting composed of the Hicksite party aforesaid.

He further says, that although the said Hicksite party have pretended recently to disclaim the epithet of Hicksite, yet they followed and treated him, the said Elias Hicks, as their leader, and are still in religious fellowship with him. He further says, that he does not believe that the said Hicksite party adhere to the doctrines of the christian religion as professed by ancient Friends and they seem of late unwilling to divulge their particular religious tenets, and contend that there are no particular religious doctrines held by the Society of Friends. He denies the withdrawal of the said Orthodox party from the Society of Friends, but says on the contrary, that they are identified with them, and that in the institution of the said original suit in Chancery, he has not violated the discipline of the Society of Friends, because the said Thomas L.. Shotwell, the defendant in that suit, is not and has not been for several years last past a member of the Society of Friends.

This defendant denies all unlawful combination and confederacy charged in said bill.

GEORGE WOOD, Solicitor, and of
Counsel with the Defendant.

NEW JERSEY, TO WIT: Joseph Hendrickson, the above defendant, alleging himself to be conscientiously scrupulous of taking an oath, and being duly affirmed according to law, on his solemn

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affirmation, says, that the matters and things set forth and contained in the foregoing answer, so far as they relate to his own acts and deeds, are true, and so far as they relate to the acts and deeds of any other person or persons, he believes them to be true. JOSEPH HENDRICKSON. Taken and affirmed at Trenton, the 2nd day of October, 1829, before me.

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The several answer of Stacy Decou, one of the Defendants to the Bill of Interpleader of Thomas L. Shotwell, Complainant.

This Defendant now, and at all times hereafter, saving to himself all and all manner of benefit or advantage, of exception or otherwise, that can, or may be had, or taken to the many errors, uncertainties, and imperfections in the said bill of Interpleader contained, in answer thereto, or to so much thereof as this Defendant is advised it is material or necessary for him to make answer to, severally answering saith-That he admits it to be true, that in the year 1792, certain persons, to wit-Joshua Bunting, Joshua W. Satterthwaite, William Abbott, Samuel Abbott, Isaac Horner, Nathan Middleton, Thomas Lawrie, Joseph Forsythe, Gideon Middleton, John Tantum, John Stevenson, William Chapman, John Abbott, Samuel Radford, Henry Allen, John Wright, Hannah Middleton, Ann Lawrie, Esther Lippincott, Rhoda Tillins, Mary Allen, Rhoda Robbins, Hannah Hankins, Isaac Colton, Robert Wright, Alice Merrit, Marmaduke Watson, Joseph Bullock, Thomas Taylor, Joseph M. Lawrie, Jacob Middleton, William Satterthwaite, Aaron Wright, Joel Cheshire, Elijah Field, Isaac Combes, George Williams, Samuel Clevinger, Fretwell Wright, Lydia Moore, and John Taylor-styling themselves members of the Preparative Meeting of the people called Quakers, at Crosswicks, in the township of Chesterfield, in the county of Burlington, and State of New Jersey, by a subscription under their

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hands, severally promised to pay on demand, and in specie, at the rate it then passed, unto Samuel Middleton, then treasurer of the school at Crosswicks, aforesaid, begun and set up, by and under the care of the Preparative Meeting of Friends, at Crosswicks, aforesaid, on the twenty-seventh day of Twelfth-month, in the year aforesaid, or to his successors in office, the sum of money by them severally written against their names, with the interest therefor, at the rate of five per cent.-the principal whereof so subscribed, to be and remain a permanent fund, under the direction of the trustees of the said school, then or thereafter to be chosen by the said Preparative Meeting, and by them laid out, or lent on interest, in such manner as they shall judge will best secure an interest or annuity; to be applied to the education of such children as then did, or should thereafter, belong to the same Preparative Meeting, whose parents are not of sufficient ability to pay for their education. And in case the whole, or any part thereof, should not be wanted for such purpose, then and in that case, the said interest or income, or such part thereof as should not be so wanted, to be applied to such other uses of the said school, or schools, then or thereafter to be erected by the said meeting, as the said trustees, then or thereafter to be appointed, or a majority, to consist of not less than five of them, shall think will best answer the designs of the institution:-as by the original subscriptions, (to which, when produced, this defendant asks leave, for greater certainty, to refer,) will more fully and at large appear.

He also admits, that a large sum of money was raised by means thereof, and that an additional sum was raised, in the year 1795, and that a contribution was made thereto by the Preparative Meeting of Chesterfield, being the quota of the Quarterly Meeting stock, amounting to the several sums stated in the said bill. He also admits, that the said sum and fund continued as a permanent fund, under the direction of the trustees of the said school, chosen from time to time by the said Preparative Meeting, and was by them laid out, or lent, on interest, as they judged would best secure an interest until the year 1821.

He also admits, that the said Samuel Middleton continued treasurer of the said fund, until the year 1812, when the said Joshua W. Satterthwaite was appointed, by the said Chesterfield Preparative Meeting, at Crosswicks, to succeed him-who continued treasurer until Tenth-month, 1816, when the said defendant, Joseph Hendrickson, was appointed by the said Preparative Meeting to succeed him.

This defendant also admits, that the loan of two thousand dollars, part of the said permanent fund, was made to the said complainant; and to secure the same, he made the bond, and together with Elizabeth his wife, also made, executed, and acknowledged the deed of mortgage, as is set forth and described in the said bill of interpleader; but for greater certainty, he asks leave to refer to the said bond and mortgage, when produced.

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