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    Lincoln Document Signed "Conkling & Lincoln & c for J B Moffatt" in an unknown hand. Sangamon Co. [Ill.], March 1849, about two and one-quarter pages, folio. A complicated plea in Willis H. Johnson vs John B. Moffatt and Thomas Lewis, asserting that a cross bill was unnecessary to enable the court "to render complete equity between the parties to the original bill…[I]t does not introduce any new party or set up any new defence, nor present the facts…in a new light….it contradicts what said Johnson has admitted in his answer to the original bill….it does not seek any affirmative relief…Because in the original bill…Moffatt did not seek any relief against Johnson, but only against Lewis because Lewis had all the assets that were not charged to the partners separately in his hands, and Johnson was a necessary defendant only in consequence of his having been a partner…Johnson was merely a nominal defendant and consequently it was entirely unnecessary for him to file a cross bill and it could not aid him in his defence. That as…Moffatt sought no relief against Johnson in the original bill, said Johnson has not shewn in his cross bill that he was entitled to any relief against Moffatt, neither has he shewn that he is entitled to any affirmative relief against Lewis, other than what he could have obtained under the original bill, because he admits in his answer to the original bill that Lewis' answer to the same is true…" From the Henry E. Luhrs Collection. Accompanied by LOA from PSA/DNA.

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    20th-21st Monday-Tuesday
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