Provincial Court Proceedings, 1675.     95

       Thomas Paine Memorandum the three and twentith day of Novem- Liber N N
          agt    ber in the 44th yeare of the Dominion of Caecilius p. 60
     John Quigley     Lord and Proprietary of this Province Att a Provin-
                 ciall Court holden at the Citty of st Maries for the
       Right Honble the Lord Proprietary Came here in Court Thomas
       Paine by Charles Boteler his Attorny and exhibiteth here into Court
       his certaine bill against John Quigley One of the Attornyes of this
       Court here present in Court of a plea of trespass upon the case.
         And whereupon the said Thomas Paine by Charles Boteler his
       Attorny complaineth that whereas the aforesaid John Quigley upon
       the fourth day of July Annoq Dom 1675 at the Citty of St Maries
       aforesaid In consideration that he the said Thomas Paine being
       a Bricklayer at the Special instance and request of him the said John
       Quigley would worke upon a certaine Brickhouse called the State-
       house at st Maries aforesaid which the said John Quigley then had
       undertaken to erect and build the Said John Quigley did then and
       there assume upon himself e and to the said Thomas Paine did faith-
       fully promise that he the said John Quigley when thereunto required
       would well & truly content and pay unto the said Thomas Paine
       Such a quantity of tobacco as he the Said Thomas on that behalfe
       should reasonably deserve to have for his paines and labour therein
       And the said Thomas Paine in fact saith that trusting to the faithfull
       promise & assumption of him the said John Quigley in that behalf e
       made as aforesaid did worke as a Bricklayer upon the said State-
       house from the Said fourth day of July 1675 untill the last day of
       September in the same yeare. for which he saith he doth reasonably
       deserve to have the sume of six thousand pounds of tobacco in caske
       Yet the Said John Quigley his Said promise and assumption not
       regarding but deviseing and fraudulently intending him the said
       Thomas Paine in that behalfe craftily to deceive although often
       thereunto required the said Thomas hath in no manner paid nor
       contended but him to pay hitherto hath refused and as yet doth re-
       fuse whereupon the said Thomas Saith he is dampnified and hath
       losse to the value of ten thousand pounds of tobacco and thereupon
       he bringeth his suite.
         And the said John Quigley by Robert Ridgely his Attorny cometh
       and defendeth the force and injury when &c and prayeth liberty of
       Speakeing hereunto untill next Provinciall Court the same day is
       given to both parties.
         Now here at this day to wit the twelfth day of ffebruary in the
       yeare One thousand six hundred Seventy five came the Said Thomas
       by his Attorny aforesaid & the said John by his said Attorny like-
       wise came, and the said John Saith that he did not assume & promise
       in manner & forme as the said Thomas Paine above against him of
       this he putts himselfe upon the Country and the said Thomas like-
       wise Therefore it is Comanded the Sheriffe that he cause to come