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[left margin] 2 Ch 564

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 that by the said Thomas in that plea alleged ought not to be barred from having and maintaining his aforesaid action thereof against him because he says that the said writing obligatory deed in the said declaration mentioned was obtained fairly and honestly by him the said William and not by fraud covin or and misrepresentation in manner and form as the said Thomas hath in his said plea by him first above pleaded alleged and this he the said William prays may be inquired of the Country &c.
Searcy for Plff

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 alleged ought 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 alleged and this he the said William prays may be inquired of by the said Country &c.
Searcy for plff

[left margin] 2 Ch 652
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 alleged ought not to be barred from having and maintaining his aforesaid action thereof against him Because he says That he the [back to image of page 1] said William was not nor is indebted to the said Thomas in manner and form as the said Thomas hath above in his said last plea in that behalf alleged and this he prays may be inquired of by the Country &c.
Searcy for plff