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William Russell
vs
Thos. H. Tindall
In the Superior Court

And the said William Russell by Searcy his Attorney as to the said plea of the said Defendant by him first above pleaded saith that the said William by reason of any thing by the said Thomas in that plea alledged aught not to be barred from having and maintaining his aforesaid action thereof against him because he says that the said Deed in the said Declaration mentioned was obtained fairly and Honestly by him the said William and not by fraud covin or misrepresentation in manner and form as the said Thomas in his said plea by him first above pleaded alledged and this he the said William prays may be inquired of the country &c.
Searcy for Plff

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And the said William as to the Said Plea of the Said Thomas by him Secondly above pleaded Saith that the said William by Reason of any thing by the Said Thomas in that plea alledged aught not to be barred from having and maintaining his aforesaid action thereof against him because he says that the said Thomas did not pay to him the said William the said sum of money in the said Deed mentioned with Lawful interest for the same in manner and form as the said Thomas hath above in his Said Second plea in that behalf alledged and this he the Said William prays may be inquired of by the said country &c.
Searcy for Plff.

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And the said William as to the said plea of the Said Thomas by him thirdly above pleaded Saith that the said William by reason of any thing by the Said Thomas in that plea alledged aught not to be barred from having and maintaining his aforesaid action thereof against him because he says that he the said William was not nor is indebed to the Said Thomas hath above in his Said Last plea in that behalf alledged and this he prays may be inquired of by the country &c.
Searcy for Plff.

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