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44 N.J.Law 485, 487; Holoway V. Appelget, 55 N.J.Eq. 383, 505; Clark V. Augustine, 62 N.J.Mq. 689, 695; Freeman V. Conover, 95 N.J.Law 89, 93. See also, Magner V. Mutual Life Association, 44 N.T. supp. 868; affirm- ed, 162 N.Y. 657; Thompson V. The Phoenix Insurance CO., 136 U.S. 287, 300. Howard V. West Jersey, etc., R.R.CO., 108 521 (supra) That statement was recently approved by the Court of Errors and Appeals in Partrick V. Groves, 115 N.J.E. 208. It suggesta e much wider scope to the doctrine of *fraudulent concealment* then is generally accepted elsewhere. See Dewson, Fraudulent Concealment and the Statute of Limitutions. 31 Mich. L.R. 591; Note, Fraudulent Concealment of e Right of Action end the Statute of Limitations, 43 Harv. L.R. 471; Tood V. Carpenter, 101 U.S. 135. In Lincoln V. Judd, 49 N.J.E. 387, the complsinant shipped sheep to the defendants who sold them and romitted the proceeds of the sales, less their commissions and amounts purported to have been ex- pended for freightage. The freightage deducted was grossly in excess of the actual charges but the complainants accepted the moneys as correct, relying on the defendant's honesty and did not discover the fraud presumebly for over six years. the defendants demurred to the bill for an accounting on the grounds that the complainant had an ade- quate remedy at lew and that more than six years had elapsed ance the ceuse accrued. But the court overruled the demurrer, holding that "in cases of fraud the time limited within which the action must be brought will not commence to run until the discovery of the fraud, or until the complainent was in a situation whore, by the exercise of reasonable diligence, he would have discovered the fraud." Another case, Hollowey V. Appelget, 56 N.J.E. 583, held that the defense of the statute in an action at law would be enjoined in equity where a defendant sold certain municipal bonds efter making an agreement with en attorney to pay hin a percentage for collect- ing the bonds and allowed the statute to run without informing the attorney of the faot. See comment, la Harv. L.R. 220. The court held in Clark V. Augustine, 62 N.J.F. 689, that non-

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    "ocrText": "44 N.J.Law 485, 487; Holoway V. Appelget,\n55 N.J.Eq. 383, 505; Clark V. Augustine, 62\nN.J.Mq. 689, 695; Freeman V. Conover, 95\nN.J.Law 89, 93. See also, Magner V. Mutual\nLife Association, 44 N.T. supp. 868; affirm-\ned, 162 N.Y. 657; Thompson V. The Phoenix\nInsurance CO., 136 U.S. 287, 300.\nHoward V. West Jersey, etc., R.R.CO., 108\n521 (supra)\nThat statement was recently approved by the Court of Errors\nand Appeals in Partrick V. Groves, 115 N.J.E. 208. It suggesta e\nmuch wider scope to the doctrine of *fraudulent concealment* then\nis generally accepted elsewhere. See Dewson, Fraudulent Concealment\nand the Statute of Limitutions. 31 Mich. L.R. 591; Note, Fraudulent\nConcealment of e Right of Action end the Statute of Limitations,\n43 Harv. L.R. 471; Tood V. Carpenter, 101 U.S. 135.\nIn Lincoln V. Judd, 49 N.J.E. 387, the complsinant shipped sheep\nto the defendants who sold them and romitted the proceeds of the\nsales, less their commissions and amounts purported to have been ex-\npended for freightage. The freightage deducted was grossly in excess\nof the actual charges but the complainants accepted the moneys as\ncorrect, relying on the defendant's honesty and did not discover the\nfraud presumebly for over six years. the defendants demurred to the\nbill for an accounting on the grounds that the complainant had an ade-\nquate remedy at lew and that more than six years had elapsed ance the\nceuse accrued. But the court overruled the demurrer, holding that\n\"in cases of fraud the time limited within which the action must be\nbrought will not commence to run until the discovery of the fraud, or\nuntil the complainent was in a situation whore, by the exercise of\nreasonable diligence, he would have discovered the fraud.\"\nAnother case, Hollowey V. Appelget, 56 N.J.E. 583, held that\nthe defense of the statute in an action at law would be enjoined in\nequity where a defendant sold certain municipal bonds efter making\nan agreement with en attorney to pay hin a percentage for collect-\ning the bonds and allowed the statute to run without informing the\nattorney of the faot. See comment, la Harv. L.R. 220.\nThe court held in Clark V. Augustine, 62 N.J.F. 689, that non-"
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