James Fernon and John Connelly v. James Smith
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[missing figure]
Samuel B SmithSamuel B Smith
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Fernon G Connelly

Pleas in
In the Circuit CourtCircuit Court
October Term 1817

.

And the said defendant by M
M Girk his attorney comes and defends the wrong
and injury when and where & C and says that he did
not take the property goods and chattels in the said
declaration mentioned or any or any part thereof in
manner and form as they the said plaintiff have above
thereof complained against him and of this he the said
SamuelSamuel puts himself upon the Country

And the said SamuelSamuel for further plea in
this behalf says that the said plaintiffs of having and main
taining their said action thereof against him ought
to be bared and precluded Because he says that the
property of the said goods and chattels in the said
declaration at the said time where it is alleged he
took the same from the said plaintiffs was in him
self the said SamuelSamuel to wit, at Saint LouisSt Louis.

without this that the property of the said goods &
Chattels or any part thereof at the said time mentioned
in the said declaration was in the said plaintiffs
as by the said Declaration above supposed And this
he the said SamuelSamuel is ready to verify wherefore he
prays Judgment and a return of the said goods to be
adjudged, to him and that damages be assessed,
for the of the use of the said goods. and his
Costs.

And the said SamuelSamuel for further plea in
this behalf says the said plaintiffs of having and