Peter Primm vs. John Lane, James Mackey, John Bolly, and Jeduthan Kendal
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Territory of MissouriMissouri

The Several answer of JeduthanJeduthan Kendal KendalJeduthan Kendal to the
Bill of Complaint of PeterPeter Primm. Complainant
against JohnJohn Boly BolyJohn Boly & others.

The said JeduthanJeduthan Kendal KendalJeduthan Kendal now and at all
times here after saving to himself all and all manner of advantage of
exception to the many untruths, errors, and uncertainties, and other
imperfections in the said Bill of Complaint contained for answer there unto or
to so much thereof, asismaterial for him domake answer
to answerethsaith that he knows nothing of the matters and
things charged in the said Bill of Complaint except what so herein after
set forth. To wit that sometime in the last part of the
year the thousand eight hundred and fourteen or the beginning of
the year One thousand eight hundred and fifteen. JamesJames Mackey MackeyJames Mackey
wished to buy of this defendant a concession for four Hundred
acres of Land, and proposed to assignover to him a note of
hand on the JohnJohn Lane LaneJohn Lane & PeterPeter Primm, for two hundred dollars
which note was dated the twenty third of March One thousand
eight hundred and eleven, payable twelve months afterdate
John BollyJohn Bolly or order, and assigned by said BoliBolly , to said MackeyMackey .
That this deponent did notthen know of the circumstances as by property of the said John LaneJohn Lane but
he knew the said PeterPeter Primm, tohaveproperty, and believedhim
to be able to pay said sum: and that he did agree
to receive the said note, and did receive as assignment
thereof of said JamesJames Mackey MackeyJames Mackey . without recourse, because
he thought the said Primm an honest man and able
to pay the said sum :- and he allowed the said Mackay, the
full amount of said note & theintentone thereon - that
he neitherknew nor was informed that there was any pretense
orsuspicion of fraud relative to said note . - . that
soonafter receiving said note he called on said Primm
for the money, and Primm told him that he signed

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said note as security for LaneLane : That LaneLane had given him a
pocket Book & some paper, containing a title to a lot of
land on the State ofOhio OhioOhio, as his security and if LaneLane would
confess a Judgment withhim on the honorhe would join in
said confession - or that if LaneLane could be induced to pay one
half he would be glad& wouldpay the balancebut
neversuggested any fraud or oppression in obtaining the
saidnote, or his signature: - . - That this defendant was
therein the said pocket Book & paper. by said Primm and
One of said paper was a deed for a Lot of land in Turn
Lancasteror, the state of OhioOhio, or a part of a debt.

That the said PeterPeter Primmneglecting to pay the said
note, he did give the said notetoEdwardEdward Hempstead HempsteadEdward Hempstead
his attorney to himandof theprocuring afterwards he
know nothing, butsupposes the record of the case will
show them at large - That said Primmneverpretended
to him that he was intoxicatedwhen he executed the
said notenordoeshebelieve that was the case: nor
the same was obtained by fraud or imposition - and
this defendant would nothave taken any assignmentof said
note had he thought or believed it had been unfairly
a obtained . - and this defendant denies all
and all manner of unlawful combination and conspiracy
in the complainants Bill set forth against him. - without
that that there is any othermatter a thing in the said
complainants Bill of Complaint contained material effectual
for this defendant to make answer unto - and not herein and
hereby sufficiently answered unto, confessed or avoidedtraversed
ordenied is how to the knowledge and belief of this
Defendant - all which matters and things