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The Maryland Code Public General Laws, 1904
Volume 393, Page 1645   View pdf image (33K)
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ART. 75] FORMS OF PLEADINGS—PLEAS IN CONTRACT. 1645

Pleas in Actions on Simple Contract.

41. That he never was indebted as alleged, or that he never
promised as alleged.

The following forms with the commencement aforesaid shall
be sufficient in actions on deeds or other contracts :

42. That the alleged deed is not his deed.

43. That at the time of the making of the alleged deed the
defendant was and still is within twenty-one years of age.

44. That at the time of the making of the alleged deed the
defendant was and still is the wife of one W. T.

45. That the defendant was unlawfully imprisoned by the
plaintiff, and others in collusion with him, until by duress of
imprisonment he made the alleged deed.

46. That the alleged deed was procured by the fraud of the
plaintiff.

47. That the plaintiff threatened the life of the defendant
unless he would make the alleged deed, and that from fear of
the threats he made the same.

48. That after the sealing and delivery of the alleged deed
it was, without the consent of the, defendant, altered, and the
words (insert them) were inserted and substituted therein for
the words (insert them).

49. That the defendant delivered the alleged deed to one
A. F., as an escrow, on condition that (state the condition) then
the said A. F. should deliver the alleged deed to the plaintiff
as the deed of the defendant. And the plaintiff has not per-
formed the condition.

50. That the alleged cause of action did not accrue within
———— years (state the period of limitation applicable to the
case) before this suit.

Perkins v. Perkins Ex'rs, 1 H. & McH. 400. Gough v Rldgely's Ex'rs, 3
H. & McH. 99. Lamott v. McLaughlin', 3 H. & McH. 324. Stewardson v.
White, 3 H. & McH. 455. Wootton's Ex'r v. Sprlgg's Ex'r, 4 H. & McH.
352. Sullen v. Ridgely, 1 H. & J. 104 Smith v. Williamson, 1 H. & J. 147.
Lansdale v. Ghequiere, 4 H. & J 259. Oliver v. Gray, 1 H. & G. 215
Murdock v. Winter, 1 H. & G. 471. Wall's Ex'r v. Wall, 2 H. & G. 79.
Crain v Yates, 2 H. & G. 332. Green v. Johnson, 3 G. & J. 389 State v.
Green, 4 G. & J. 381. Chambers v Chambers, 4 G. & J. 420. Dorsey v.
Dorsey, 6 G. & J. 12. Nelson v Bond, 1 Gill, 218. Benmngton v. Dins-
more, 2 Gill, 348. Beanes v. Hamilton, 3 Gill, 275. Schlelgh v. Hagers-
town Bank, 4 Gill, 306. Newcomer v. Keedy, 9 Gill, 263. Strike v. State,
1 Bl. 57. Hepburn v. State, 3 Bl. 95. Dixon v. Dixon, 1 Md. Ch 271.
Young's Estate, 3 Md. Ch. 461. Mitchell v. Sellman, 5 Md. 376. Stockett


 

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The Maryland Code Public General Laws, 1904
Volume 393, Page 1645   View pdf image (33K)
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