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would content & pay Notwthstanding the said Ann her promise &
assumpcon aforesaid little reguarding, but meaning & fraudulently
intending him the said John in this behalfe craftily & subtily to
deceive & defraud the said surhe of two thousand one hundred eighty
& nine pounds of tobacco according to her promise & assumpcon
aforesaid to the said John hath not paid or any wayes contented
although the said Ann often thereunto required, but the same to
him to pay hath refused & as yett doth refuse to the damage of the
said John Staynes five thousand pounds of tobacco And thereupon
he brings his suite
And the said Ann Jones by Charles Boteler her Attorney cometh
& defendeth the force & injury when &c And prayeth liberty to
imparle hereunto untill next Provincial Court & itt is granted unto
her, the same day is giuen to the plaintiffe also
Now here att this day to witt the Sixteenth day of October in
the third yeare of the Dominion of Charles Lord Baltemore &c
Annoq Doni 1678 came the said parties by their Attorneys aforesaid
And the said Ann by her said Attorney saith, that she did not assume
& promise in manner & forme as the ptt above in his Declaracon hath
declared, & of this she putteth her selfe upon the Countrey And
the plaintiffe also Therefore itt is comanded the Sheriffe of St Maryes
County that he cause to come here twelve &c by whom &c and who
neither &c to recognize &c because as well &c Att which said six-
teenth day of October in the yeare aforesaid came as well the said
plaintiffe as the said Defendt by their Attorneys aforesaid And the
Jurors impannelled being called likewise came to witt Richard
Boughton, John Haslewood Thomas Doxey, John Doxey, Marke
Bromfield, Tho, Bowdle, Tho: Osborne, Lewis Blangy, Tho: Ball,
Henry Howard, Tho: Gilbert & Richard Hodgson who being Elected
tryed & Sworne to say the truth in the prmisses upon their Oaths
doe say that the said Ann Jones did assume & promise in manner &
forme as the plaintiffe above against her hath declared And they
assesse the damage of the said John Staynes to Two Thousand one
hundred Eighty & nine pounds of tobacco Therefore itt is considered
by the Court here that the said Jno Staynes recover against the said
Ann Jones as well the sume of two Thousand one hundred Eighty
& nine pounds of tobacco damages by the Jurors aforesaid in forme
aforesaid assessed As also one thousand & twelve pounds of tobacco
costs of suite And the Defendt in mercy &ca
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