Miller v. Lynch

The amended complaint states, in substance: That on the twentieth day of March, 1887, one John Smith was indebted to the plaintiff in the sum of one hundred and sixty dollars, to be by him paid in rails, viz., three thousand rails at fifty dollars per thousand, to be made and delivered on or before July 1,1887, and that, as security for the payment thereof by said John Smith to plaintiff, plaintiff had a pledge therefor, — two horses, two sets of harness, and wagon and bob-sled; that said defendant, on said twentieth day of March, 1887, being desirous to obtain the services of said Smith, and…