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Liber
P. C. R.
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being altogether Ignorant Concerning itt, haueing never read or
seene the same.
Now soe itt is That Mr Pille by some way or other haueing gotten
the said Conveyance or deed into his custody againe as the Complt
is given to vnderstand And further likewise how that noe Realien-
acon of the said land ever passed from Greenwell to him and prtend-
ing posson to be given or granted him by Greenwell in case the
tobacco should not be payd by him hath Entred vpon that Land and
absolutely solde the same to another person since Greenwells death
without course att Lawe dispossessing the Orphant or heire of his
Freehould and libties contrary to the Statute of magna Charta, cap :
29: & the Statute of Malebrough, Providing in that behalfe And soe
has receiued double pay or sattisfaccon for one and the same land
besides Greenwell being a man illeterate, and Pille himself e drawing
the Conveyance betwixt them both, It is to be prsumed that that
Conveyance is penned in favor of Piles himselfe and his owne ....
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p. 1069
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Orphant who not haueing estate is thereby made vnapt and conse-
quently disabled to wage Lawe Yor Complt therefore doth clearely
detrect from this busines & in most humble wise throwes itt upon this
honoble Con Which Notwithstanding He prsumeth to Instance thus
much & humbly prayes that the sd John Pille according to the vsuall
course in Chancery putt in his answere upon oathe to every perticuler,
and likewise deliuer the aforemenconed Conveyance to the Cort And
declare whether itt be the same or not, whether altred or interlined
[by] himselfe or any other since or afore .... or the Signeing and
delivery thereof how he came possed with itt and who writt itt, by
whome the Realienacon was made and before whome posson given
if such thing were, how much tobacco he hath already recd from
Greenwell upon that Sale whether there were not other Reckonings
betwixt them att the tyme of Greenwells departure then that only,
how much he sould that same land for the second tyme since Green-
wells death
Lastly yor Comprt humbly requesteth this honoble Cort to comis-
erate the prsent condicon of the sd orphant in case itt shall by good
Evidence soe appeare that the Reposson is just and that he be ad-
judged to loose his ffreehould then that the sd Pille repay the tobacco
recd att least with forbearance, and Charges of building Greenwell
enjoyeing and possessing the land & plantacon one yeare only or little
more And he shall pray &c. Wm Euans
To the honoble Philip Calvert Esqr Governor and Chancellor of
Maryland
[The Answer] of John Pille in his deafence to a bill .... Coll-
Willm Evans in the behalfe .... John Greenwell decd Justice when
they haue been enformed of the truth and Examined the reason why
the Feoffees suffred his fathers purchase to be lost when they might
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