Koons v. Price

Price sued Koons on four promissory notes, and to foreclose a mortgage, given to secure their payment, on certain real estate situate in an addition to the city of Richmond, or South Richmond, as it is called. The notes and mortgage were made a part of and filed with the complaint. The answer was in two paragraphs :

First. The general denial.

“For second and further paragraph of answer, the defendant says that he admits the execution of the notes and mortgage described in and filed with plaintiff’s complaint, but that the same were obtained from him through misrepresentation, deceit, and fraud,…