(seq. 12)

Debt on Judgement

the Inferiour Court of Common Pleas within the country of Middle-
sex where neither the Ptt nor the said Daniel are or at the time
the purchase & service of the writ aforesaid were Inhabitants & thus
the said Daniel is ready to verify wherefore he prays judgement
that the said Miriam of her action aftersaid against the said
Daniel may here be barred is that he the said Daniel may
recover his double costs of this suit against the said Miriam
according to the act aforesaid.
Jona Sewall

And the said Miriam says that she by any thing by
said Daniel above in pleading alledged ought not to be preclu-
ded from having & maintaining her action of aforesaid thereof
against him the said Daniel had because she says that the
plea aforesaid by him the said Daniel in manner & form a-
foresaid above pleaded of the matter in the same contained ar
not sufficient in law to preclude her the said Miriam from
her actions aforesaid thereof against the said Daniel had to
which said plea she said Miriam hath no necessity nor is
bound by the law of the land in any manner to answer: and
this she is ready to verify Wherefore for want of a sufficient
answer in this behalf she the said Miriam prays judgement and her
debt aforesaid together with her damages by reason of the detention
of that debt to be adjudged to her.

Fra. Dana
Josiah Quincy junr.

And the said Daniel says that his plea aforesaid in manner
& form aforesaid above pleaded and the matter in the same con-
tained are good and sufficient in law to preclude her the said Miri-
am from her actions aforesaid thereof against him the said Daniel
had which said Plea of the matter therein contained he said Da-
niel is ready to verify & prove at the Court Pl. And because the
said Miriam doth not answer to that plea nor hitherto in any
way deny the same he the said Daniel as before prays judg-
ment.