William Hanna v. William Sublette
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WilliamWilliam Hanna
admr of Jno Hanna
vs
Wm. Sublette

And the saidWilliam SubletteWilliam Sublette
1 by GeyerGeyer his attorney comes and defends the wrong &
injury when &C and says that the said plaintiff
ought not to have a maintance his aforesaid action
thereof against him- the defendant, because he says
that he the said plaintiff is not nor ever hath
been administrator of the goods & or chattels rights or
credits which were of the said John Hanna deceased
in manner and form as the said plaintiff hath
above thereof in his said declaration alleged and
this the said defendant prays may be enquired of
by the county &C

And for further plea in this behalf the said
defendant says that he did not undertake &
promise in manner and form as the said plaintiff
hath above thereof in the said several counts of
his declaration or either of them, alleged and of
this he puts himself upon the county &C

And for further plea in this behalf the said
defendant says that the said plaintiff ought not
to have or maintain his aforesaid action thereof
against him because he says, that the said
John Hanna deceased before and at the time of
his death was and the said plaintiff administrator
as aforesaid, since the decease of the said John before
and at the time of the commencement of this suit
was indebted to the said defendant, in a large
sum of money to wit in the sum of two thousand
dollars for money by the defendant lent and ad
vanced & out & expended for the said
John in his life time and at his request, and
for money by the said John in his life time had
and received to the case of the defendant, and
also on the further sum of two thousand dollars for
divers goods wares & merchandizes sold and delivered
to, and for meal drink clothing washing & lodging found &
provided for the said John on his life time by the
plaintiff and at his like special instance & request

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which said several sums of money due and
owns to the defendant and together exceed the damages
sustained by the plaintiff, by reason of the non
performance of the several supposed promises &
undertakings in the declaration mentioned, and the
said defendant is ready and willing and hereby
offers to sett off and allow to the said plaintiff the
full amount of said damages according to the
form of the statute in such case made & provided
to wit at the county aforesaid and this the defendant is ready to verify and
prays judgment &C

GeyerGeyer

for defts