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Latest revision as of 10:55, 29 November 2021

The answer of Robert Mayo Jr: exor: of Ransdell Peirce decd: to the bill exhibited in the Cirt: Court of Westmoreland by Wm G. Peirce against him and others, defendants. - This respondent, saving &c. &c. for answer to the said bill, or as much thereof as he is advised it concerns him to answer, says - That he admits the execution of the deed referred to in the said bill - the death of Isabella, Ann E. R., Ann and of the said Ransdell Peirce as set out in the same: This respondent says that a suit is already pending & undetermined on the Chancery side of this hon: Court, instituted by the comp't. against the said Ransdell Peirce in his life time for an account of the profits of the property conveyed by the said deed and for any waste thereof by said Ransdell - That an account of the same has already been ordered and taken in the said pending suit, and this respondent prays to be allowed the benefit of the fact of the said pending suit, as tho' the same were pleaded in the most formal manner & refers to the record of the same in this hon: Court now remaining - This respondent denies that the said Ransdell Peirce committed any waste of the property in the said deed mentioned, and that any loss or damage has accrued to the same, save such as was produced by natural causes, wear & tear and the consumption of such as was consumable in the use. This respondent, (if the said bill raises the question) submits the construction of the said deed to your honour, insisting that the said interests & shares of the said Sarah E. R., & Isabella Peirce in the property conveyed, divided upon their death to the said Ransdell Peirce their father. And having fully answered he prays to be hence dismissed with his costs in this behalf expended &c- Ro: Mayo Jr. Exor R. P. decd: