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Kent County Court, Proceedings, 1701-1705
Volume 740, Page 25   View pdf image
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25)      Pay unto a certain Samuel Taylor of the Said County the Sume of
        Eight hundred and ninety pounds of tobacco in Consideration thereof
        the Said Robert Hawkshaw upon himself Assumed and unto the Said
        Edward Chetham then and there faithfully promised that he the Said Robt:
        when by the Said Edward he should be thereunto afterwards required the
        afd 890lb tobacco well and truly he would pay yet notwithstanding the
        afd Robert his promise and Assumption afd made not minding or in Any
        Manner regarding but plotting contriving and fraudulently intending the
        Said Edward in that behalf craftilly and Subtilly to cheat and defraud the
        afd 890lb tobacco according to his afd promise and Assumption altho’.
        often afterwards required he unto the Said Edward hath not paid or
        in Any Manner for the Same given the Said Content but the Same to
        him to pay hath and Still doth deny and refuse to the Damage of the Sd.
        Edward 1700lb tobacco And thereupon he brings this Suit . Macklin pr qr.
        Pledges &ca. John Doe R. Roe ——
                And the Said Robert by Mll. Earle his Attry Comes and Defends the
        force and injury when &ca. And prays leave to Imparle hereunto untill
        next Court which is granted him the Same day is given the plaintf.
        Also. At Which Said next Court to wit the 27th day of January Anno Domi
        170½ Comes the Said Parties by their Attorneys afd And the Said Robert
        by his Attry afd further Defends the force And injury When &ca. And
        for plea Saith True it is the Said Plaintif did pay unto the Said Samuel
        Samuel Taylor the Sume of Eight hundred and ninety pounds of
        tobacco as in Said Plaintifs declaration is Alledged for the use of
        the Said Defendt: But the Said Defendant further by protestation
        Sayth that he and his Son did Do and prform diverse and Sundry
        Services for the Said plaintf. Amounting unto the Sume of
        two thousand one hundred and twenty pounds of tobo. As by an
        Account hereto Annexed and here in Court brought Appeares &ca.
        therefore prays discount According to Act of Assembly. Earle pr Dte.
        Mr. Edward Chetham Dr. ——— 1700    lb tobo
To one hundred and twenty days I was at yr. house Imploy’d |    1060
at 8 pr day                                                                        |
To my Sons work 120 days at 8 pr day                                      1060
Errors Excepted    pr Robt. Hawkshaw            2120
        And the afd Edward by his afd Attorney Says that the afd plea
        of the afd Robert as to the Services of the Said Robert and his
        Son Alledged to be done and prformed above in barr pleaded that
        that plea in Manner and form afd pleaded and the Matter in the
        Same Contained doth not hold Sufficient in law to debarr him the
        Said Edward from having his Accon afd thereupon agt. him the Said Robt:
        And that he to that plea in Manner and form afd pleaded hath no neces:
        :sity nor by the Law of the land is bound to Answer and this he is ready to
        Averr Whereupon for want of Sufficient answer of ye. afd Robert in
                                                                                                            ( that



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Kent County Court, Proceedings, 1701-1705
Volume 740, Page 25   View pdf image
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