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Wherefore by reason of the law and the
premises the Defendant moves the
Court for an arrest of Judgement and for
a new trial herein -

Upon the following grounds - to wit =

First

Because the Court erred in sustaining the
demurrer to the first and second pleas of
defendant - made to the indictment herein -
The said demurrer not being well taken -

Second

The Court erred in sustaining the
replication of prosecution to the third Plea
of defendant and in refusing to sustain
the traverse of defendant to said replication
because said Plea was true and well pleaded
and said replication was untrue and not
supported by evidence - and There being no
evidence introduced in relation thereto
for the Court to act upon it
erred in making any ruling upon the
same in the absence of testimony.

Third

The Court erred in amending the minutes
of the Court relating to the presenting and
filing of the indictment herein -
Because the minutes had been made at
a former term of said Court and the Court
had lost all jurisdictions after them -