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MARYLAND COURT OF APPEALS 561
Twenty four Thousand pounds of Tobacco to recover the Said Land Last
mentioned to the Deft which he the Said Adams Afterwas refused to do Al-
ledging that his So doing would be an Evidence of fraud and give the Complt
Some advantage Agt him but yet keeps every foot of the Land having paid in
all to the Complt only Three Thousand Six hundred and forty pounds of
Tobacco or Thereabouts that this Deft Knows of that the Deft made over all
his Cattle to the Said Adams and Delivt part of them to him or his ordr and
carried Some of his Household Goods to his house with Intent to prevent
their being Taken in Execution by the Compll with the Said Adams Consent
and privity without that any Matter or thing in the Complts bill Contained
and herein and hereby well and Sufficiently answered Traversed or Denyed
all which Matters and things this Deft is ready to aver and mantain as the
Court Shall Direct and prays to be hence Dismissed with his reasonable Costs
most Wrnngfully Sustained.
21st Febry 1722. The Defendant Wm Brewerton Makes Oath that the
facts Contained in the foregoing Answer as of his own knowledge are true
and what relates to the Acts of Others he believes to be True
Sworn to before Benja Tasker
Thereupon the Said Cause Stands further Continued Untill the Next
Court at wch Said Court (To Witt) the Ninth Day of July Anno Dom 1723
Comes as well the Said Complainant by his Council as the Deft Adams by his
Sd Council and thereupon the Def Adams his Demurrer to the Complainants
Said Bill Coming to be Argued before his Honour the Chancellor in pres-
ence of the Complainants and Defendants Adams Council and the Allega-
tions on Both Sides being fully heard and Mature deliberation thereupon
had it was ordered that the [755] Demurrer be overruled and that the De-
fendant Adams answer be filed by the Next Court and also Decreed that the
Defendant Adams Pay Six hundred pounds of Tobo for the Delay etc.
And Thereupon this Cause Stands Continued from Court to Court Un-
till the 18th Day of Febry Anno Dom 1723 At which Said i8th Day of Febry
Come as well the Sd Complt by by [sic] his Councill afd as the Deft Adams by
his Council and thereupon the Said Adams by his Said Council Exhibited
his answer which follows in these words Vizt
The Seperate answer of Alexander Adams of Somersett County Clerk one of
the DeftB to the Bill of Complaint of John Caldwell Complainant
This Defendt IMJW and at all Times hereafter Saving and reserving to
himself all and all manner of Benefitt and Advantage of Exception to the
Manifold incertainties and Insufficiencies of the Complts Sd Bill of Complt
for answer thereto or to So much thereof as this Deft is Advised is anywise
materiall for him to answer unto Answereth and Saith he believes that Wm
Brewerton the other Deft in the Bill mentioned was indebted to the Complt
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