458 MARYLAND COURT OF APPEALS

Two-Tracts. But before the Same were granted him Summons issued Against
the Said W^m Seward requiring him to make his Objections before his Lord-
ships agents thereto which Summons was Duly Notified to him but the Said
W^m Seward being Either Conscious to himself he Could not prove the Condi-
tion paid for the Said Warrant or offer any thing that might be of Advan-
tage to him Or through his Obstinacy refused to appear and Contest his
Right to the Said Lands and thereupon the Said Agents proceeded to hear
the Said Smithson prove his Allegations In the Said Petition Set forth, Ex
parte and being Satisfyed with the Same Granted him the Said Patents. This
Defendant Confesses he hold [sic] half of the Said Tracts of Land Called Cam-
berlake and Sector both together Containing 869 Acres as Assignee of Thomas
Smithson of Talbot County the Patentee and John Daviss of Dorchester
County holds the other half of the Said Tracts. Without that that any other
matter Cause or thing in the Said Complainants Said bill of Complaint Con-
tained Materiall or Effectuall in Law for him this Defendant to answer unto
and not herein and hereby well and Sufficiently answered unto Confessed or
avoided traversed or denyed is true all which matters and things this Def^t
is ready to aver mantain and prove as this Hon^rble Court Shall award and
humbly prays to be hence Dismissed with his Cost and Charges in this behalf
most wrongfully Sustained.
Jur 17^o — die — Septembr 1716^o

coram me Phile Loyd Tho: Macnemara
[657] The Replication of Mary and Ann Seward by Benj^a Woodward and
Mary his Wife their next friends Complainants. To the answer of Thomas
Hicks Defendant

The Said Complainants for Replication to the Said Def^ts Said answer
Say that the Said Bill of Complaint by them Exhibited into this Honble
Court against the Said Defendant is very true certain and Sufficient in the
Law to be by the Said Def^t answered unto and that all and every the matters
and allegations in the Said Bill of Complaint Contained are by them therein
Set forth upon good Cause and just ground and Occasion of Suit and these
Replyants further Say and Averr That the Said answer of the Said Defend-
ants unto the Said Bill of Complaint is very uncertain untrue and insufficient
in the Law to be replyed unto by these Replyants Nevertheless all advan-
tages and benefit of Exception to the Incertainties and Insufficiencies of the
Said Def^ts Said answer to these Replyants now and at all times hereafter
Saved and Reserved for Replication unto the Said Defendants Said answer
these Replyants in and by their Replication Say and Shew in every matter
and thing as before in and by their Said Bill of Complaint they have Said
and Shewed and they doe and Will thereby Justifye mantain and prove their
Said Bill of Complaint and all and every the matter and allegations therein
Comprized to be Certain and true in Such Sort manner and form as the Same
are therein by them these Replyants Set forth and Expressed Without that