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Chancery Court, Chancery Record, 1671-1712
Volume 748, Page 217   View pdf image
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(217)

       and not for Two Individuall and distinct debts taken as they were
       Mentioned in the Consid.racons of the said Deeds Mortgages & writeings &
       whether the Comp.lt were Really and bonâ fide indebted any such greate
       sume To the deft and whether hee did not bring such accons of Replevin
       and Ejectm.t as aforesaid and forced the Comp.lt to seal and Execute the
       Deed of Mortgage of the said six hundred Acres of Land (pte of
       the said Reall estate) for Eighteene thousand pounds of Tobacco and
       that hee might sett forth whether that Land or the Consid.racon thereof
       were not to his sett att Liberty all the Remaind.r of the said Reall and
       psonall estate and to discharge the said former ingagem.ts & not for
       any New Created debt and that hee might Exhibitt a Just and true
       Account to bee Annexed to his Answere of all debts Justly Due to
       him and what hee had payd and Disbursed to any pson or psons
       whatsoever and what Tobacco goods houshold stuffe Cattle and servants
       hee had Received in ballance thereof the Comp.lt being Ready to pay
       what should appeare Justly due to the deft upon the foote of the said
       Account and that upon paym.t of the same the Defts might bee
       Decreed to deliv.r to the Comp.lt all such bills bonds & specialtyes of the
       Comp.lts as the Deft had gott into his hands as aforesaid and had then
       in his posession Undefaced and Uncanselled  And that the Deft
       might bee Decreed to Deliv.r to the Comp.lt The two deeds or Mortgages
       the one of the Reall the other of the psonall estate w.th sufficient Releases
       and Discharges Upon the same and that the deft might Redeliver
       the said Conveyance or Mortgage for the six hundred Acres of Land
       to the Comp.lt w.th Sufficient Releases and Discharges (and that the
       Deft might bee Decreed if the Lawe soe Required) to Reconvey the said
       Lands to the Comp.lt and to Acknowledge the same in any Court
       w.thin this province for the secureing the Title to the same to y.e Comp.lt
       or that the deft should allowe the deft Consid.racon therefore according
       to the true Vallue thereof and that the said deft might Redeliver to
       the Comp.lt psonall estate or that hee might allow the Complayn.t
       Consid.racon therefore according to the true vallue and that the said
       Def.ts proceedings att lawe touching the p.rmisses might bee stayed and
       the Comp.lt therein Releived according to Equity hee humbly Craved
       the favourable Ayd and Assistance of this Hono.ble Court and
       That processe of supa might bee thereout Awarded against the said
       deft To appear in this Court and Answere the p.rmisses  The which
       being Grannted and y.e said deft therew.thall served appeared accordingly
                                                                                              (Afterwards
      


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Chancery Court, Chancery Record, 1671-1712
Volume 748, Page 217   View pdf image
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