NOVEMBER, 1698 COURT 423

date of the Said Bill obligatory upon his the Said Thomas then Dwelling planta-
tion to which payment well and truely to be paid the Said Thomas did binde
himselfe his heires Executors Administrators or assignes firmely by these presents
Notwithstanding which the Said Thomas the Said Sume of 1163 pounds of
Tobacco according to the tennor of the Said bill obligatory allthough often re-
quired hath not rendered but the Same to Pay to the Said Joseph and Company
hath hitherto denyed and Still doth denye to the Damage of them the Said
Joseph and Company of 2000 lbs. of Tobacco and thereof they bring this Suite
etc.

Pledges etc. John Doe, Richard Roe. Joshua Cecell.

The Plantiffes by their Attorney afforesaid haveing Ishued out a writt against
the Defendant which Said writt was by the Sheriffe returned that the Said De-
fendant was not to be found in his baylewick and likewise have Caused a Coppy
of the Declaration to be left at the house where the Defendant last Lived in
this County it is likewise testifyed that the Said defendant hath alianed him
Self out of the Jurisdiction of this Court whereupon the Said Joseph Jacson
and Company by their Attorney afforesaid Prayeth an atteachment against the
goods Chatties and Credditts of the Said Thomas Vaughun for the Said Sume
of one thousand one hundred Sixty and three pounds of Tobacco aforesaid as
allso the Sume of four hundred forty and one pounds of Tobacco their Cost and
Charges in this behalfe Laid out and Expended and by the Court it is Granted
unto him.

Jackson and Company Plantiff: Thomas Vaughun Defendant
Thomas Vaughun Late of Prince Georges County Planter was Atteached to
answer unto Joseph Jackson and Company of London Merchants of a plea of
Tresspass upon the Case etc.

And whereupon the Said Joseph and Company by Joshua Cecell their At-
torney compleineth that whereas the Said Thomas the 3d day of November att
Charles Towne within the Jurisdiction of this Court in the year of our Lord
1698 Stood Indebted unto the Said Joseph and Company in the Sume of one
thousand five Hundred thirty and one pounds of Tobacco being for Severall
goods Wares and Merchandizes Sold and Delivered the Said Thomas by David
Small Factor of the Said Joseph and Company as per a perticular account thereof
here in Court produced relation being thereunto had may more att Large appear
and the Said Thomas to the Said Joseph and Company in manner afforesaid
being indebted in Consideration thereof did assume upon himself and to the
Said Joseph and Company then and there faithfully promise that he the Said
Thomas them the Said Joseph and Company the Said Sume of 1531 lbs. of
Tobacco when he Should be afterwards thereunto requested would well and
truely Content and Pay Nevertheless the Said Thomas his promise and assump-
tion soe as afforesaid made little regarding but mindeing and Fraudulently in-
tending them the Said Joseph and Company in this behalfe Crafftily and Sub-
tilly to deceive and Defraud the Said Sume of 1531 pounds of Tobacco or any
Part thereof to them the Said Joseph and Company by David Small the Factor
of the Said Joseph and Company afterwards the Day and place afforesaid was
offten thereunto requested but the Same to pay to them the Said Joseph and
Company hath hitherto denyed and Still doth denye to the Damage of them
the Said Joseph and Company of 3000 lbs. of Tobacco and thereof they bring
this Suite etc.