324 MARYLAND COURT OF APPEALS

Land called the worlds End (w^ch he is the rather induced to believe) because
that on the nicest Scrutiny he has been able with the assistance of the most
able and Skillfull Surveyours to make into the bounds of the Land called the
Worlds End and the Land called Martinson he has good reason to believe
and doubts not to demonstrate to this Hon^ble Court that Martinson lyes some
distance from any Part of the Worlds End as by the Bill is falsely Suggested
and if true as the Def^t is advised would not in Law or Equity Entitle the
Compl^t thereto the survey thereof being prior to that of the Worlds End and
the Def^t having purchased the same for a valuable Consideration which has
been by him really and Bona fide pay'd that the Def^t purchased the said fifty
Acres of his L^dships Agent but doth not particularly remember what expres-
sions were by him used when he apply'd to his L^dships Agent for purchasing
the same but denys that he ever made use of any false or undue Suggestions
or means to procure the same or took any other but the usuall methods of
Bargaining or Contracting that the Dcf* alsu dciiys that cvci the Cunipl* made
any Application to him about the said Land otherwise than in a Manaceing
manner threatning that he would Spend five hundred pounds at Law but
that he would recover the Same if the Def^t would not Surrender what he had
so as af^d realy bought and paid for to him that the Def^t thinks that the said
fifty Acres of Land as Convenient Scituated for himself as any other and that
if the same were remote and inconvenient it would not (as the Def^t is Ad-
vised) distroy his right thereto the Conveniences or Inconveniences (as he
Conceives) being only to be regarded with rispect to the value of the Land
and not the right of any Person thereto and that the Def^t beleives and hopes
as far as is [495] Necessary to prove that the severall other Allegations Con-
tained in the said Bill are false without that, that any other matter or thing
in the said Bill of Complaint contained Materiall or Effectuall for this Def^t
to make Answer unto and not herein or hereby well and Sufficiently An-
swered unto Confessed or Avoided Traversed or denyed is true all which
matters and things this Def^t is ready to Averr Maintain and Prove as this
Honbte Court Shall Award wherefore this Defendent Humbly Prays a Dis-
solution of the Injunction Obtained by the Compl^t not only without any
Equity or reason but even ag⁸⁴ both purely to Vex the Def^t and burthen him
with heavy and unnecessary Charges to Compell him to give up his right and
that the Def^t be hence Dismist with his reasonable Cost and Charges in this
behalf most wrongfully Sustained D Dulany.
Jurat. Coram me May the 3* 1719 Phile Lloyd.

Afterwards to Wit the nineth day of May in the same year and at the
same Court comes Nathaniel Hynson Gaurdian as af^d by Thomas Bordley
Esq^r his Councill and Exhibits his replication to the Answer afd as follows
(Viz^t)

The Replication of Nathan^ll Hynson next friend of Nathan" Hynson a
Minor to the Answer of John Ward.