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Filed 11 Decr 1811

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And the Said Defendant comes and Defends the wrong and injury complained of in the Plaintiff Declaration and Sayeth as to that Declaration he is not under any Necessity to Plead because he Sayeth the same is in no wise sufficient for the Plaintiff to have and mentain his action aforesaid in manner and form aforesaid neither is he bound by the Laws of the Land to Make any answer there too and this he is ready to verify and for cause of Demurrer in Law agreeable to the form and effect of the Statute in such case made and Provided he here Sets Down and Shews the following

1st because the writ issued contrary to the form of the Statute in such case made and Provided

2^nd because the Petition is complicated made to one of the Judges and commences and concludes as if in court.

3^rd because the Plaintiff hath not given bond nor made oath in this case as the Law requires

4^th because the writ hath no Seal

5^th because the Plaintiff is not a resident of this Territory nor given bond for to Secure the cost according to Law wherefor the Defendant Pray Judgement and that his cost may be allowed him

Perly Wallis Atty

for Deft

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