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

The Several answer of John BollyJohn Bolly
to the Bill of Complaint of PeterPeter
Primm. complainant against this
respondantJames MackeyJames Mackey & JeduthanJeduthan Kendal
KendalJeduthan Kendal

The said John BollyJohn Bolly now and at all times hereafter reserving
to himself all and all manner of advantage of
exception to the many untruths was and uncertain his
in the said Bill of Complaint contained so answer there
to says that in the spring of the year one thousand eight
hundred and Eleven he was in the town of Saint LouisSt Louis, and owned
a certainseed Horse. Which was in the opinion of this respondant
worth Two Hundred dollars : that there he met one JohnJohn Lane
LaneJohn Lane with whom he had little or no acquaintance, and
knew nothing of his character except that he had
heard he gambled sometimes that LaneLane asked him how
much he would take for said Horse, and this respondant
told him that the price was two Hundred Dollars that LaneLane
said he would give him that price and invited him so
go to in Saint LouisSt Louis, and this respondantsays
proved for the sake of receiving the money for the Horse - and
we went there : and when we came there LaneLane did not
pay the money but proposed to give a note for that
amount with good securityfor and this respondant told him
that he might have the Horse if he would get good
securityfor that amount but otherwise he should not
That said LaneLane offered so given one Mark as Security but
he was not taken & LaneLane then offered PeterPeter Primm the complaintant
and this respondant knowing Primm to be a man settled

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at Saint LouisSt Louis, having a trade & with that sum agreed to
take said Primmwith said LaneLane that WilliamWilliam Fuget and
AdamAdam Brown BrownAdam Brown were present with this respondantPrimmLaneLane
Burke that someone drew a Note for said sum &
when this respondant heard it read he did not like the form
and as far as he recollects the said Fugetdrew another
and the said LaneLane & Primmsigned the same & delivered it to
your respondant and he delivered the Horse to said LaneLane , in
the evening - which note is the same set forth in the
complainants Bill - And this respondant denies that he and
LaneLane agreed to use their exertion to induce the said Primm
to become security although LaneLane might have done itnor
did he use any fraud or circumvention or persuade the said
Primm to drinkstrong Drink or to make him intoxicated
for that purpose. nor does he know that said Primm was
intoxicated or incapable of managing his affairs with
prudence nor did he pretend to said Primm or to any
other person that said now contained any other clause
or condition than what was written in said note : nor
that if said LaneLane continued in town until the next day the said Primm was discharged - all which matters
if insisted upon by said Primm he prays may be proven
That this Respondant the next day went home to where he
lives on the Meramec and this deponent further answering
saith that about the first day of April, in the year, one thousand eight hundred & Twelve this respondant was about
trading withJamesJames Mackey MackeyJames Mackey for some negroes - and then
promised to assign over said note : and said MackeyMackey
that if he would like an assignment of the same with
outrecourse this would have : and said MackeyMackey