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held for said County of Montgomery at the Court
House in the town of Montgomery judgment was
rendered by the said Court against the said Plaintiff
and the said defendant for the sum of nine
hundred and twenty six dollars principle debt, besides
interest costs of protest and costs of suit (the said suit
being discontinued as to the said Vardaman) and
the said plaintiff avers that afterwards, towit, on &c.
at &c. he was compelled to pay the whole amount of
said judgment towit the sum of one thousand
dollars principle interest and cost. By means whereof
the said defendant then and there became liable to
pay the Plaintiff the one half of said judgment, towit,
the sum of five hundred dollars and being so liable
the said defendant afterwards, towit, on &c. at &c.
undertook and faithfully promised so to do whenever
he should be thereunto afterwards requested.
And whereas also the said defendant, towit, on &c.
last aforesaid at &c. aforesaid was indebted to the
said Plaintiff in a certain other sum of five
hundred dollars for money paid, laid out and
expended to and for the use and benefit of the said
defendant by the said Plaintiff at the special instance
and request of said defendant and being so
indebted he the said defendant in consideration
thereof then and there undertook and faithfully
promised to pay the said plaintiff the said
sum of money whenever he should be thereunto
afterwards requested.
Yet the said defendant although after requested
to pay said sums of money or either of them has
hitherto and still does wholly neglect and refuse to
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