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The Maryland Code : Public General Laws and Public Local Laws, 1860
Volume 145, Page 514   View pdf image (33K)
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514 PLEADINGS, PRACTICE AND PROCESS. [ART. 75.

28th. That the defendant debauched and carnally knew the
plaintiff's wife.

29th. That the defendant converted to his own use, or wrong-
fully deprived the plaintiff of the use and possession of the
plaintiff's goods; that is to say, wheat, rye, household furniture, (or
as the case may be.)

30th. That the plaintiff was possessed of a mill, called "Linga-
nore Mill," in ——— county, and by reason thereof was entitled
to the flow of a stream for working the same, and the defendant,
by cutting the bank of said stream, diverted the water thereof
away from the said mill.

31st. That the plaintiff was possessed of land, called "Idle-
wild," in ——— county, and was entitled to a • way from said
land, over the land of the defendant, to a public highway, for
himself and his servants, with horses and wagons, to go and '
return at all times, at his and their free will, for the more con-
venient occupation of the said land of the plaintiff; and that
the defendant deprived him of the use of said way.

32d. That the defendant falsely and maliciously spoke and
published of the plaintiff the words following, that is to say:
"he is a thief;" (if there be any special damage, here state it
with such reasonable particularity as to give notice to the de-
fendant of the particular injury complained of, for instance,)
whereby the plaintiff lost his situation of book-keeper in the
Bank of Washington.

33d. That defendant falsely and maliciously printed and
published of the plaintiff in a newspaper called "The Exam-
iner," the words following, that is to say: "he forswore him-
self."

34th. That the defendant is a corporation, owning a railroad
between B. and C.; that the plaintiff was a passenger on said
railroad, and by reason of the insufficiency of an axle of the
car in which he was riding, the plaintiff was hurt; and the de-
fendant did not use due care in reference to said axle, but the
plaintiff did use due care.

[This form may be varied so as to adapt it to many cases, by
merely changing the allegation as to the cause of the accident.]

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The Maryland Code : Public General Laws and Public Local Laws, 1860
Volume 145, Page 514   View pdf image (33K)
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