Abraham Parker vs. Manuel Lisa
View original image: Page  009
[missing figure]

And as to the fourth plea of the said Defendant the said
plaintiff saith that the said plea is bad & insufficient in Law
to preclude him the said plaintiff from recovering his demand afore

View original image: Page  010
[missing figure]
said, from the said Defendant, nor hath the said plaintiff
any necessity to reply thereto and this he is ready to verify â
Wherefore for want of a sufficient plea in this behalf, the said
plaintiff prays Judgment of her debt & damages aforesaid & his
Costs and for causes of the said plaintiff sits down
and shows the following â

1 That part of said plea which states that the Estates of
George DruillardGeorge Druillard is insolvent was insolvent at the time of
the rendition of the Judgment in the aforesaid declaration
mentioned does not show the amount of assets in the hands
of the Defendant.â

2. It does not show the amount of Debts

3. It does not show in the manner required by Law the
adjustment of the same.â

4. It does not show for what amount the said state is

5. It does not show how the assets in his hands have been disposed

6. Insolvency cannot be pleaded in discharge of this demand after
the finding of the Jury in the former action that the said Defendant
had in his hands assets to the amount of the plaintiffs demand
without lawfully accounting for those assets so as to preclude
the plaintiff from any .â

7. The said plea does not show when auditors were appointed
on said Estate, whether before the seeing forth of the writ
in this case, nor the diligence he used to obtain a final
of the said Estate.

8. The said plea does not state that the said Defendant
exhibited the demand of the plaintiffs with others to said

9. The said plea does not state, that said Report, of said
Auditors had been presented to the court of common pleas to
be approved & confirmed by said Court.â

10. It does not state that the report of the auditors has-
been confirmed by said Court, after which only the administrator