Samuel B. Smith vs. John Connelly and James Feron
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The demurrer of Samuel B. SmithSamuel B Smith of the
Territory of MissouriMissouri and county of StSt Louis LouisSt Louis to
all and every part of the complainants
bill of complaint execpt that part
by the said SamuelSamuel already answered to

The said Samuel B. SmithSamuel B Smith by
not confessing or acknowledging
all in any matters and things in said bill
of complaint to be true, in such sort
and manner as the same one therein expr-
-essed and contained. to all the
of the said complainants bill
that answered as by this defendants answer, and for
causes of this defendant
the following first for want of equity
in the complainants bill by their own
shewing. Second the subject of the Comp-
lainants is not within the
jurisdiction of a Court of equity. Third
that the said defendant is
to answer for the conduct of a third
person with whom he was not
and over whose conduct he had
no contract. Fourth that the subject

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matter of the complainants bill or that part which relates to the action of replevin in the circuit court
of the is only
in a Court of Law and was there decided
according to the principles of and Law and there a made there
Fifth that the defendant was not
at the time of being served with a copy
of the complainant. bill of complaint
with a copy of the complainants exhibits refused
to in their bill of complaint. , All which
matters and things this defendant doth
and is ready to prove as this Honorable
court shall direct , and here by judge-
ment of this honorable court whether he
shall make any further an other answer thereto.

M Mc GirkM Mc Girk atty


for deft