each, against your petitioner and bail bonds, they have very good security, and your petitioner shall speedily get the money returned and paid into court. Your petitioner therefore humbly prays your honor to enlarge Petition to withdraw a Plea. In Chancery. A. B. Complainant, Between and To the Honorable James Kent, Chancellor of the state of New-York. The humble petition of the defendant, 1 Sheweth: That the plaintiff, having filed his bill in this honorable court against your petitioner, and your petitioner having put in his plea, and demurrer thereto, your petitioner is since advised to make other defence to the said bill. And your petitioner, therefore prays your honor, that he may withdraw his said plea and demurrer, upon the payment of costs. And, &c. To the Honorable James Kent, Chancellor of the state of New-York. The humble petition of the plaintiff, Sheweth : That your petitioner, in term, last past, exhibited his bill in this honorable court against the defendant, to which the said defendant appeared, but hath neglected to put in his answer thereto; and, the said defendant, living and residing within the distance of as by the affidavit annexed appears: miles from Your petitioner, therefore, most humbly prays your honor, that he may be at liberty to make out process of contempt against the said defendant, for want of his answer, returnable immediately. And, &c. Petition to amend a bill, by adding a defendant. In Chancery. Between A. B. Complainant, C. D. Defendant. To the Honorable James Kent, Chancellor of the state of New-York. That your petitioner, in term, last past, exhibited his bill in this bonorable court against the defendant, to which the said defendant appeared, but hath neglected to put in his answer thereto; and, the said defendant, living and residing within the distance of miles of as by the affidavit hereunto annexed appears: Your petitioner, therefore, most humbly prays your honor, that be may be at liberty to make out process of contempt against the said defendant, for want of his answer, returnable immediately. And, &c. Petition to amend a bill, on payment of costs. In Chancery. Between A. B. Complainant, C. D. Defendant. To the Honorable James Kent, Chancellor of the state of New-York. The humble petition of the plaintiff, Sheweth : That your petitioner, having filed his bill in this honorable court against the defendant, C. D. hath only put in his answer thereto, (none other of the defendants having yet appeared thereto,) upon pe rusal of whose answer, your petitioner is advised by his counsel, to amend his bill : Your petitioner, therefore, most humbly prays your honor, that he may be at liberty, to amend his bill, upon the payment of costs. And, &c. Petition of a defendant, to be admitted in Forma Pauperis. In Chancery. A. B. Complainant, Between and To the Honorable James Kent, Chancellor of the state of New-York. The humble petition of the defendant, Sheweth : That your petitioner is served with process, to appear to, and answer the plaintiff's bill, but being very poor, (as by affidavit appears,) is by reason of such his extreme poverty, unable to make his defence thereto, if not permitted to defend in Forma Pauperis : Your petitioner, therefore, humbly prays your honor, to admit In Chancery. To the Honorable James Kent, Chancellor of the state of New-York. The humble petition of the defendant, Sheweth: That the plaintiff, having filed his bill in this honorable court, against your petitioner, and others, whereto your petitioner hath appeared, and taken an office copy thereof, and his time for answering not being yet expired, nor being in contempt: Your petitioner, therefore, most humbly prays your honor, to grant unto your petitioner, a month's time to plead, answer or demur, to the plaintiff's bill, And, &c. 1 Petition of Feme Covert, to answer without her husband. In Chancery. A. B. Complainant, Between and (C. D.& E. F. Defendants. To the Honorable James Kent, Chancellor of the state of New-York. The humble petition of the defendant, E. wife of the def't. C. D. Sbeweth : That the plaintiff, bath exhibited his bill, in this honorable court, against your petitioner, and her said husband, whereto your petitioner hath appeared; and, in regard of your petitioner's said husband, hath absconded, and lived separate from her these years: Your petitioner, therefore, most humbly prays your honor, that she may be at liberty to put in her answer to the plaintiff's said bill, without her husband. And, &c. To the Honorable James Kent, Chancellor of the state of New-York. The bumble petition of the defendant, Sbeweth: That the plaintiff, having filed his bill against your petitioner, he has appeared thereto, and taken a copy. That your petitioner, residing in the county of a commis sion is issued, to take his answer, and made returnable in weeks, &c. but, your petitioner finds he shall not be able to return the same within the time limited by the strict rules of the court, and forasmuch as your petitioner is not in contempt, nor has yet any order for time: Your petitioner, humbly prays your honor, that he may have time to put in his answer to the said bill, until and that all process of contempt, for want thereof, be in the mean time stayed. And, &c. Petition to examine a witness De Bene Esse, before issue joined. In Chancery. Between A. B. Complainant, C. D. Defendant. To the Honorable James Kent, Chancellor of the state of New-York. The humble petition of the complainant, Sheweth : That your petitioner, having filed his bill in this honorable court, against the said defendant, whereto he hath appeared; but, the said defendant, living a great distance from in the country, he hath obtained time to put in his answer till the first day of next term. That one G. H. of, &c. gentleman, a very material witness for your petitioner in this cause, and without the benefit of whose evidence your petitioner, (as he is advised,) cannot safely proceed to a hearing of this cause; and the said G. H. being age, or upwards, and very weak and infirm, so that, in all probability, years of he may not live till your petitioner can bring his cause to an issue, as by the affidavit annexed appears : Your petitioner, therefore, most humbly prays your honor, that he may be at liberty, forthwith, to examine the said G. H. De Bene Esse, as a witness for your petitioner in this cause, saving all just exceptions. And, &c. |