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Forms.
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XLIX. That the defendant was unlawfully im-
prisoned by the plaintiff, and others in collusion with
him, until by duress of imprisonment he made the
alleged deed.
L. That the alleged deed was procured by the
fraud of the plaintiff.
LI. That the plaintiff threatened the life of the de-
fendant unless he would make the alleged deed; and
that from fear of the threats he made the same.
LII. That after the sealing and delivery of the al-
leged deed, it was without the consent of the defen-
dant altered, and the words (insert them.) were in-
serted and substituted therein, for the words (insert
them.)
LIII. 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 de-
liver the alleged deed to the plaintiff as the deed of
the defendant. And the plaintiff has not performed
the condition.
LIV. That the alleged cause of action did not ac-
crue within ———— years (state the period of limita-
tion applicable to the case,) before this suit.
LV. That before this action be satisfied and dis-
charged the plaintiff's claim by payment.
LVI. That the plaintiff at the commencement of
this suit was, and still is indebted to the defendant in
an amount equal to the plaintiff's claim, for (insert
the cause of set-off as in a declaration; see form,
ante,) which amount the defendant is willing to set-
off against the plaintiffs claim.
LVII. That after the alleged claims accrued, and
before suit, the plaintiff, by deed, released the de-
fendant therefrom.
LVIII. That at the circuit for ———— county
—— terra 1854, the plaintiff recovered judgment
against the defendant for the sum of —— dollars and
—— cents, and —— dollars for costs; and that said
judgment was rendered on the same cause of action
mentioned in the plaintiff's declaration, and is still a
subsisting judgment.
LIX. That he was discharged as an insolvent debt-
or by the circuit court for —— county, (or court of
Common Pleas for the city of Baltimore,) on the
—— day of ———— 1854, and that the alleged claim
accrued before the filing of his petition.
LX. That he applied by petition as an insolvent
debtor to the circuit court for ———— county (or
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