Sam: Chancery Cause, Augusta County (Part 1 of 2)
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would more than compensate for the profit he has derived from the use & occupation of it. - As to the other items your respondent avers that some of them are altogether unjust & the others have no relation to the matter in controversy - The alleged debt to Stout never was due form your respondent & if the plff. paid it or bought it, he did so in his own wrong, & he has no right now to require your respondent to pay it - The other items are not proper offsetts [offsets] to this demand, & moreover if they were, your respondent is informed that the plff. has a right to sue at law on his account, & there your respondent can meet him before a jury & have the benefit of all his legal defences - There is no allegation in the bill that your respondent is insolvent, & therefore no ground is shewn for an injunction - Your respondent knows nothing of what transpired between Mr. Effinger & the plff., but he thinks it very clear from plffs. own shewing, that Mr. Effiner's reason for not making a defence at law was his belief that a court of equity was the most appropriate forum for the litigation of the matters in issue & not any impression that the matter was to be referred. Your respondent cannot perceive the relevancy to the matters in issue, of the history of the manner in which he acquired his freedom - The plff. has dealt with him as a free-man, & his right to freedom cannot now be collaterally questioned, & more