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both actual and constructive fraud as hereinabove charged.
14. The plaintiff further charges that by reason of its conduct,
as hereinabove described, the defendant has barred and estopped itself from
the right to so plead.
15.
The plaintiff fears that unless the defendant is enjoined
and restrained from setting up the defenses hereinabove mentioned in the
action nowpending in the United States District Court for the District of
New Jersey, that the said court will sustain one or more of said defenses
and thereby theplaintiff will be denied all right of recovery of damages.
16. The plaintiff also fears that unless in the interim and
pending the hearing of this cause and the determination of whether the
defendant should be permanently enjoined from setting up the defenses
hereinabove mentioned in the action now pending in the United States
District Court for the District of New Jersey, the defendant be enjoined
and restrained from making any application to said court to dismiss the
plaintiff's action as being barred by the statute of limitations or for want
of prosecution, the plaintiff's rights will be impeded or destroyed.
PLAINTIFF is without adequate remedy in the courts of law and
therefore prays:
1. That the defendant answer this bill of complaint without oath
and eachstatement herein made.
2. That it be decreed that it would be and is a fraud upon the part
of the defendant to set up and plead in defense of the action pending in the
United States District Court for the District of New Jersey that the cause
of action is barred by the statute of limitations, and that the defendant
is debarred and estopped from doing so.
3. That the defendant be permanently enjoined from setting up in
defense of the action pending in the United States District Court for the
District of New Jersey that the cause of action is barred by the statute
of limitations.
4. That the defendant be directed to withdraw from its answer filed
in the action pending in the United States District Court for the District
of New Jersey all matters therein set up wherein it is alleged that the ac-
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"ocrText": "both actual and constructive fraud as hereinabove charged.\n14. The plaintiff further charges that by reason of its conduct,\nas hereinabove described, the defendant has barred and estopped itself from\nthe right to so plead.\n15.\nThe plaintiff fears that unless the defendant is enjoined\nand restrained from setting up the defenses hereinabove mentioned in the\naction nowpending in the United States District Court for the District of\nNew Jersey, that the said court will sustain one or more of said defenses\nand thereby theplaintiff will be denied all right of recovery of damages.\n16. The plaintiff also fears that unless in the interim and\npending the hearing of this cause and the determination of whether the\ndefendant should be permanently enjoined from setting up the defenses\nhereinabove mentioned in the action now pending in the United States\nDistrict Court for the District of New Jersey, the defendant be enjoined\nand restrained from making any application to said court to dismiss the\nplaintiff's action as being barred by the statute of limitations or for want\nof prosecution, the plaintiff's rights will be impeded or destroyed.\nPLAINTIFF is without adequate remedy in the courts of law and\ntherefore prays:\n1. That the defendant answer this bill of complaint without oath\nand eachstatement herein made.\n2. That it be decreed that it would be and is a fraud upon the part\nof the defendant to set up and plead in defense of the action pending in the\nUnited States District Court for the District of New Jersey that the cause\nof action is barred by the statute of limitations, and that the defendant\nis debarred and estopped from doing so.\n3. That the defendant be permanently enjoined from setting up in\ndefense of the action pending in the United States District Court for the\nDistrict of New Jersey that the cause of action is barred by the statute\nof limitations.\n4. That the defendant be directed to withdraw from its answer filed\nin the action pending in the United States District Court for the District\nof New Jersey all matters therein set up wherein it is alleged that the ac-"
}