118 PRINCE GEORGES COUNTY
And Whereupon the Said William in his proper person Complayneth that
whereas the Said Hugh [106] the fifteenth day of October in the year of our
Lord 1696 at the Charles Towne within the Jurisdiction of this Court was
Indebted unto the Said William in the Sume of five hundred forty and Seaven
lbs. of tobaccoe being as well for Divers and Sundry Attorneys Fees as alsoe for
tobaccoe paid for him the Said Hugh att his Request as by a pertickeler Account
thereof here ready in Court to be produced more att Large may Appeare and
the Said Hugh inconsideration thereof did Assume upon himselfe and to the
Said William then and there Faithfully promise that he the Said Hugh the Said
Sume of 547 lbs. of tobaccoe to him the Said William when he Should be
thereunto Requested would well and truly Content and pay Nevertheless the
Said Hugh his promise and Assumption aforesaid not at all Regarding but
minding and fraudulently intending him the Said William in this behalfe
Craftily and Subtilly to deceive and defraud the Said Sume of 547 lbs. of
tobaccoe to the Said William hath not paid Although the Said Hugh Afterwards
the day and place aforesaid was often thereunto Requested butt hath hitherto
refused and Still doth Refuse to the Dammage of the Said William of 1000 lbs.
of tobaccoe and thereof he bringeth his suite.
Pledges etc. John Doe, Richard Roe. William Stone.
Mr. Hugh Montgomery Debtor to William Stone 1696.
lbs. tobaccoe
To my Fees in St. Marys County against James Connell in two Actions ...... 200
To Ditto against Simpson and How in the Said County on Scire facias ...... 200
To Clerke and Sheriffes Fees I paid in the Said Actions .................... 147
547
The plantiffe in his proper person Sues the defendant in a plea of trespass
upon the Case and haveing issued out a writt against the Said defendant which
Said writt was by the Sheriffe returned that the Said Defendant is not to be
found in his balywicke and Likewise have Caused a Copy of the Decleration to
be Left at the house he was last knowne to be at in this County And alsoe it is
testified on part of the Said plantiffe here in the Court that the Said Hugh
Montfomery hath Elloined himselfe out of this province.
Whereupon the Said William Stone in his proper person prayeth An Attech-
ment against the goods Chatties and Creditts of the Said Hugh Montgomery as
well for the Said Sume of five hundred forty Seaven pounds of tobaccoe the Debt
for Damages aforesaid as alsoe the Sume of four hundred forty five pounds of
tobaccoe of tobaccoe to the said William Stone at his Request for his Cost and
Charges in this behalfe Laid out and Expended According to the forme of the
Act of Assembly in that Case made and provided etc. And by the Court here it
is granted unto him etc.
William Bourman plantiffe: Joseph Letchworth Defendant.
Prince Georges County Ss. Joseph Letchworth Late of Prince Georges County
planter was Atteched to Answer unto William Bourman Sr. of a plea of trespass
upon the Case etc.
And Whereupon the Said William Borman by William Stone his Attorney
Complayneth that whereas the Said Joseph the 17th day of March in the year
of our Lord 1694 [1695] Att Charles Towne within the Jurisdiction of this Court
was Indebted unto the Said William in the Sume of five hundred pounds of
tobaccoe being for a Cow by the Said William to the Said Joseph Sould and
delivered and the Said Joseph Inconsideration thereof did Assume upon him-
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