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[fol. i.]
Frederick County to wit
Joseph Margruder late of Frederick County yeoman was attached to andever unto Philberd Greenweal in a plea of Trespass on the ease and soforth and where upon the said Philberd by R.B Taney his Attorney complains that whereas the said Philberd now is a good true honest and faithful citizen of this State, and as such good true honest and faithful citizen of this State, from the time of his nativity hitherto hath always behaved had and governed hisself himself and hath always been esteemed and reputed amongst all his neighbours, and other good and worthy citizens of this State to whom he was known to be a man of good name fame credit & reputation and hath always hitherto lived free, untouched unspotted and wholly unsuspected of and from all and all manner of [ ] felonies, knavery, trickery deceit falsehood, thieving or stealing or any other such hurtful crimes by means whereof the said Philberd before the speaking and publishing of the several false feigned scandalous opprobrious and malicious English words hereafter mentioned had deservedly obtained and aquired to himself the benevalence good opinion and credit of all persons any way acquinated with him, and of divers other good and worthy citizens of this State yet the said Joseph well knowing the premises
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[fol. ii.]
but contriving a maliciously intending the said Philberd in his aforesaid good name fame credit and reputation to prejudice degrade and injur & wholly to destroy the same and to bring him into public hatred scandal ignominy and disgrace and to subject him to the pains and penalties by the Laws and Statutes of this State made and provided against those who commit the crime of stealing Horses, on the first-day of May in the year eighteen hundred and three at Fredrick County aforesaid in a certain discourse which he the said Joseph then and there had with the said Philberd, in the presence and hearing of divers good and worthy citizens of this State of and concerning the said Philberd, he the said Joseph then and there falsely and maliciously said rehearsed proclaimed and loudly published these false feigned scandalous malicious and opprobrious English words, to of, and concerning the said Philberd in the presence and hearing of those citizens that is to say "You (meaning the said Philberd) are a Horse thief" "You (meaning the said Philberd) stole Horses" "You (meaning the the said Philberd) stole Horses frequently" "You (the said Philberd) meaning) are a Horse thief and all your generation" (meaning the generation and family of the said Philberd) "You (meaning the said Philberd) are a damned Rascal and I (meaning the said Joseph) can prove you (meaning the said Philberd) so: By means of the speaking of which said several false feigned scandalous
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[fol. iii.]
malicious and opprobrious English words, the said Philberd is greatly hurt prejudiced and injured in his aforesaid good name fame credit and reputation, and is fallen into great hatred scandal and disgrace among all his said neighbours and other good and worthy citizens of this State insomuch that divers of those citizens to whom the innocence and integrity of the said Philberd in the premises were unknown have always from the speaking of the said several false feigned scandalous malicious and opprobrious English words hither to so vehemently suspected the said Philberd to be guilty of felony and Horsestealing, that they on that account have always from thence heitherto refused & still do refuse more and more [...] have any conversation with him or to have any thing to do with him as befo[...] th[...]y were acustomed to have, and would have done again had not these words been spoken to the damage of the said Philberd in the sum of five hundred pounds current money and therefore he brings his suit andsoforth
Pledges Jno. Doe ----------- Rd. Roe
R. B. Taney Attorney} --- for the Plaintiff ---}
