COMPLAINTS. INDORSEE AGAINST MAKER ON NOTE. That the defendant on at , by his note in writing for value. received, promised one G. H. to pay him or his order dollars in months from thatday; that G. H. endorsed the note to the plaintiff, yet that the defendant has not paid the same, &c. OR That the defendant signed a note, of which a copy is hereto annexed, that the payee endorsed it to the plaintiff, yet that the defendant has not paid the same. at INDORSEE AGAINST INDORSER ON NOTE. That one G. H. on by his note in writing for value received, promised the defendant to pay him or his order dollars in months from that day; that the defendant endorsed the note to the plaintiff; that when it became due, it was presented to G. H. for payment, but that he refused to pay it, and that notice thereof was thereupon given to the defendant; yet that the defendant has not paid the same, &c. OR That one G. H. signed a note, of which a copy is hereto annexed, that the defendant endorsed it to the plaintiff, that when it became due it was presented to G. H. for payment, but that he refused to pay it, and that notice thereof was thereupon given to the defendant; yet that he has not paid the same, &c. PAYEE AGAINST ACCEPTOR, ON A FOREIGN BILL OF EXCHANGE. That one G H at Liverpool, in England, on made his bill days of exchange in writing, and directed the same to the defendant, at the City of New-York, and thereby required the defendant in after sight of that his first of exchange, (the second and third of the same tenor and date not paid,) to pay to the plaintiff value received, that the defendant on that he has not paid the same. dollars for accepted the bill; yet Complaint by payee against drawer, and by indorsee against drawer, acceptor and indorser, may be drawn in a similar manner. ON A POLICY OF INSURANCE. That on the defendants signed a policy of insurance, of which a copy is hereto annexed; that the plaintiff was then the owner of the vessel therein mentioned, and continued such owner until her loss; that the vessel while proceeding on the voyage described in the policy, was totally lost by the perils of the seas; that the plaintiff's loss, by reason thereof, was dollars; that on he furnished the defendants with proof of the loss and of the plaintiff's interest; yet that the defendants have not paid any part of such loss. That on OR THIS. then the plaintiff was the owner of the ship lying in the port of New-York; that the defendants, in consideration of a premium there for paid to them by the plaintiff, made a policy of insurance upon the ship for a voyage from New-York to Cadiz, in Spain, and at and from Cadiz to her port of discharge in the United States, and thereby promised to insure for the plaintiff dollars upon the ship for the voyage, against the perils of the seas and other perils in the policy mentioned. And the plaintiff avers, that the ship, sailed from New-York on the voyage described in the policy, and while proceeding thereon was, by the perils of the seas, wrecked and totally lost, of which the defendants on on actice; yet that they have never paid any part of such sum. had That on ON A COVENANT. the defendant executed, under his hand and seal, an instrument in writing, of which a copy is hereto annexed; that the plaintiff has complied with all its provisions on his part, but that the defendant has not complied with the following provision thereof, viz: FOR ASSAULT AND BATTERY. That the defendant at on assaulted and beat the plaintiff: wherefore the plaintiff demands judgment against the defendant for the injury, and that the defendant may be adjudged, to make to the plaintiff compensation in damages therefor, to the amount of $ That on FOR TRESPASS IN TAKING GOODS. at the defendant without leave, and wrongfully, took the following property of the plaintiff, viz: wrongfully, entered a lot of land, of which the plaintiff is the owner in fee (or if he have a lesser estate describe it) situated at and broke up the ground, &c. FOR LIBEL. That the defendant being the proprietor (printer or publisher) of a newspaper published in the called the lowing libel concerning the plaintiff was on the fol published there parties therein named, of which a copy is hereto annexed, take upon himself the execution of the trusts therein mentioned, and has nevertheless committed the following breaches of trust. Wherefore the plaintiff demands, that the defendant may be restrained by injunction from any further disposition of the trust property, compelled to render to the plaintiff, compensation in damages for the breaches of trust, removed from the trust, and another trustee appointed in his place Dated ANSWERS. SUPREME COURT, County of Albany, CD TO COMPLAINT ON NOTE. CD, defendant, answers to the complaint, That he did not sign the note mentioned in the complaint. County of Albany. C― D-- being sworn, saith, that he believes the foregoing answer to be true. That the note was not presented to G. H. for payment, as is alleged in the complaint. ON INSURANCE. That the ship was not lost by the perils of the seas, as is alleged in the complaint. OR That the plaintiff did not comply with the following conditions of insurance, viz: OR That the vessel was unseaworthy when she sailed on the tioned in the complaint. ON COVENANT. That the defendant did comply with the provision in the agreement set forth in the complaint, therein alleged not to have been complied with by him. FOR ASSAULT AND BATTERY. That he did not assault or beat the plaintiff, as is alleged in the complaint. FOR TRESPASS IN TAKING GOODS. That he did not take the property mentioned in the complaint. OR That the property mentioned in the complaint was not the property of the plaintiff. FOR TRESPASS IN ENTERING UPON LAND. That he did not enter the lot of land mentioned in the complaint. FOR LIBEL. That the charge published, as alleged in the complaint, was true in all its parts. The plaintiff, A—— B—, replies to the answer of C- DThat the defendant did not pay the note mentioned in the complaint, as he has alleged in his answer. County of Albany. A A. B. Piff. or E. F. Piff's Atty. B, being duly sworn, saith, that he believes the foregoing reply to be true. |