Letty Fenwick vs. Samuel Abbot
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and for further plea in this behalf as to the making
the said assault on the said plaintiff and the beating
wounding and imprisonment for the said space of
time in the said declaration mentioned, the said
SamuelSamuel says, that the said plaintiff ought not
to have or maintain her aforesaid action thereof
against him because he says, because he says
that the said plaintiff before and at the time
where in the said declaration mentioned, was the
servant, of him the said defendant, and as such
bound faithfully to serve him the said defendant,
and the said defendant further saith, that the
said plaintiff just before the said time where
in the said declaration mentioned, neglected her duty
as servant as aforesaid, in and about the business
of him the said defendant, and behaved and
conducted herself in a disorderly, saucy,contumacious
and improper manner toward the said defendant
and then and there contrary to the obedience due
to the said defendant, resisted and refused to obey

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the lawful commands of him the said defendant
whereupon the said defendant, then and there did
moderately chastise and the said the said
plaintiff for her neglect of duty disobedience and
misconduct, and inso doing did necessarily and una
voidably a little beat bruise, and ill treat the said
plaintiff and imprison her for the space of time
in the said declaration mentioned as was lawful
for him to do for the cause aforesaid, which are the
same supposed trespasses in the said declaration
mentioned. And this the said defendant is
ready to verify, wherefore he prays judgment if the
said plaintiff ought to have or maintain her
aforesaid action thereof against him

GeyerGeyer for defts