Clay v. Carroll

In an action for the recovery of money brought by plaintiffs against the defendant in the Superior Court of the county of Merced, the defendant, by way of counter-claim, filed the following answer:—

“ And for a further and separate answer, and by way of counter-claim, this defendant alleges that, at and before-the commencement of this suit, the said plaintiffs were, and now are, justly and legally indebted to this defendant in a large sum and amount of money, to wit, the sum of $2,000, or thereabouts, over and above all set-offs, claims, demands, counter-claims, or otherwise, for and on…