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Chancery Court, Chancery Record, 1671-1712
Volume 748, Page 644   View pdf image
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644)

       Uncertainties and insufficiencys of the Defendants answer to him this
       Complt now and at all times hereafter saved and reserved  He this
       Complt in and by this his Replicacon saith and sheweth in evry matter
       and thing as in and by his said bill of Complt he had formerly said &
       shewed  And that he would maintaine his said bill of Complt and the
       matters Contained therein to be true in such sort maner and forme
       as they were therein by him sett forth and Expressed  And thereupon
       for the better strengthening and fortifyeing the Complts said bill of
       Complaints and what was therein sett forth    Humbly prayed Com.r
       might Issue to some honest and discreete person to Examine upon
       Oath (such Evidence as should be pduced to him)  To all such matters
       as should be interrogated relateing to such things as are sett forth
       in the said bill  And that such Com.rs make returne of the Depositions
       as shall be taken before them into this Hono.ble Court by all Convenient
       speed which being granted Com.n Issued to M.r R.d Tilghman of Talbott
       County for that purpose which the said Tilghman accepted of and
       soone after made returne thereof  Together with the Depositions of
       Coll Edward Lloyd & M.r W.m Coursey taken and sworne to before said M.r
       Tilghman which follows in these words (Viz.t)

       M.r William Courseys Deposition   I doe know both Complt and Defd.t
       some tyme in March Court I beleive the One and Twentieth day of March
       in the year 1699 being in Compa with Coll Edw Lloyd and M.r John Hawkins
       and others at the house of M.rs Jane Hemsley M.r Alexander Forbes Came
       and desired me and the rest of the Compa to stay there some small time
       untill Robert Smith Esq.r Came  And to bear Witness for him and the
       said Forbes that he did tender to the said Smith a Deed or deeds of Convey.a
       for the sev.rall Tracts of land which he said he had purchased of the said
       Smith for him to signe Seale and Acknowledge according as by a certaine
       bond or Obligacon he was Obliged which obligacon both then and before
       he shewed me  And accordingly the said Smith Came and in the Porch of
       The said house the said Forbes did tender to him a certaine Deed or
       Writeing drawne by way of Lease and Release of the sd Lands to Seale
       And deliver which he utterly refused to doe  Whereupon the said Forbes
       And others in Compa Desired the said Smith that he would hear the
       Deeds read or read them himselfe that he might the better Judge
       whether they were such as he were obliged to signe &c or not but he


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Chancery Court, Chancery Record, 1671-1712
Volume 748, Page 644   View pdf image
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