Samuel B. Smith vs. John Connelly and James Feron
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Between JB SmithB Smith plaintiff
James FernonJames Fernon and John Connelly
Defendants

In the Superior CourtSuperior Court
In Chancery The replication of S B SmithB Smith complainants to the
answer of JamesJames Fernon FernonJames Fernon & John Connelly Defendants This saving & reserving to himself all and all manner of
of exception to the manifold of misefficienciesof the said answer for replication
thereunto saith that he will and prove his said bill to be true
certain and sufficient in the law to be answered unto and that the
said answer of the defendants is uncertain untrue and insufficient to be
replied unto by this without that, that any other matter or
thing whatsoever in the said answer contained material or effectual
in the law to be replied unto confessed and avoided traversed or denied
is true all which matters and things this is and will be
ready to and prove as this honorable Court shall direct and
humbly prays as in and by his said bill he has already prayed

MM McGirk McGirkM McGirk solicitor

for
complaint