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1. That the defendant answer this bill of complaint without oath and each statement 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 de- barred and estopped from doing so, as to the counts aforesaid. 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 as to the counts aforesaid. 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 action is barred by the statute of limitations as to the counts aforesaid. 5. That pending the hearing of this cause the defendant be enjoined and restrained from taking any proceedings in the action pending in the United States District Court for the District of New Jersey to dismiss or non-suit the same, until the determination of the cause made by this bill, and that the defendant be likewise enjoined and restrained from proceeding in said court and in said cause to secure a determination of the issues raised by the matters set forth in its answer relating to the barring of the claim of the plaintiff by the statute of limitations, as to the counts aforesaid. 6. That plaintiff may have such other and further relief as may be equitable and just. 7. That a writ of subpoena may issue commanding said defendant to answer this bill of complaint and to abide by such decree as this court may make in the premises. The plaintiff, Thomas Connolly, residing in the City of Newark, aforementioned, says thats SECOND COUNT 1. The plaintiff repeats the allegations of the first count. total

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Document data

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Type
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    "ocrText": "1. That the defendant answer this bill of complaint without oath\nand each statement herein made.\n2.\nThat 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 of\naction is barred by the statute of limitations, and that the defendant is de-\nbarred and estopped from doing so, as to the counts aforesaid.\n3.\nThat 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 of\nlimitations as to the counts aforesaid.\n4.\nThat the defendant be directed to withdraw from its answer filed\nin the action pending in the United States District Court for the District of\nNew Jersey all matters therein set up wherein it is alleged that the action is\nbarred by the statute of limitations as to the counts aforesaid.\n5.\nThat pending the hearing of this cause the defendant be enjoined\nand restrained from taking any proceedings in the action pending in the United\nStates District Court for the District of New Jersey to dismiss or non-suit the\nsame, until the determination of the cause made by this bill, and that the\ndefendant be likewise enjoined and restrained from proceeding in said court and\nin said cause to secure a determination of the issues raised by the matters set\nforth in its answer relating to the barring of the claim of the plaintiff by the\nstatute of limitations, as to the counts aforesaid.\n6. That plaintiff may have such other and further relief as may be\nequitable and just.\n7. That a writ of subpoena may issue commanding said defendant to\nanswer this bill of complaint and to abide by such decree as this court may\nmake in the premises.\nThe plaintiff, Thomas Connolly, residing in the City of\nNewark, aforementioned, says thats\nSECOND COUNT\n1. The plaintiff repeats the allegations of the first count.\ntotal"
}