Pleas, circa 13 September 1843 [JS v. Reynolds and Wilson–A]

  • Source Note
  • Historical Introduction
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&) circuit court Sept[emb]er term A D 1843,
)
)
Joseph Smith)
and the said defendants by [William] Heaton their attorney, come and defend the wrong and injury when &c and say that they are not guilty of the said supposed tresspasses above laid to their charge or any part thereof in manner and form as the said plaintiff has above thereof declared against them and of this they put themselves &c
And for further plea in this behalf as to the making the said assault in said mentioned and with a little force and violence seizing and laying hold of the said plaintiff and pulling and draging him about, and pulling and tearing the said plaintiff with a little haste and violence from his & family & a little forceing and compelling the said plaintiff to go from and out of a certain dwelling house, into the public road, and along divers roads to the town of , and then and there with a little force and against the will and consent of the said plaintiff imprisoning and holding and keeping him in duress detained and confined during the space of time in said declaration mentioned and then and there with a little force seizing and laying hold of said plaintiff and dragging forcing and compelling him to go through the streets of and then and there attempting to drag and convey the said plaintiff out of the said , in the said plaintiffs declaration mentioned the said defendants according to the form of the statute in such cases made & provided say that the said plaintiff ought not to have or maintain his aforesaid action a[gai]nst them because they say that before the said time when &c in the said plaintiff declaration mentioned to wit at a circuit court [p. [1]]
&) circuit court September term A D 1843,
)
)
Joseph Smith)
and the said defendants by William Heaton their attorney, come and defend the wrong and injury when &c and say that they are not guilty of the said supposed tresspasses above laid to their charge or any part thereof in manner and form as the said plaintiff has above thereof declared against them and of this they put themselves &c
And for further plea in this behalf as to the making the said assault in said mentioned and with a little force and violence seizing and laying hold of the said plaintiff and pulling and draging him about, and pulling and tearing the said plaintiff with a little haste and violence from his & family & a little forceing and compelling the said plaintiff to go from and out of a certain dwelling house, into the public road, and along divers roads to the town of , and then and there with a little force and against the will and consent of the said plaintiff imprisoning and holding and keeping him in duress detained and confined during the space of time in said declaration mentioned and then and there with a little force seizing and laying hold of said plaintiff and dragging forcing and compelling him to go through the streets of and then and there attempting to drag and convey the said plaintiff out of the said , in the said plaintiffs declaration mentioned the said defendants according to the form of the statute in such cases made & provided say that the said plaintiff ought not to have or maintain his aforesaid action against them because they say that before the said time when &c in the said plaintiff declaration mentioned to wit at a circuit court [p. [1]]
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