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Hazard versus Thomas C. Durant correspondence from Abraham Payne, Providence, R.I., 1875-1880

Page 01

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Kingston NY. Dec 1. 1875 Hazard et al. v Durant et al. My dear Sir, I had a full consultation yesterday with Mr Honey about this case in which I put before him distinctly what in my opinion was the position of the case & what we ought to do. 1. I think upon a fair presentation of the case, the Court ought to allow us to appear, and defend the case. It is to be presumed that they will do what they ought to do 2 To present the case fairly we should make a motion which should present a history of the case, and all the cuts & omissions of Durant, with the reasons therefore, and his present attitude in the case verified by oath 3. This motion so prepared & verified will, if I am correctly instructed, show that Durant has not at any time wilfully disobeyed an order of Court and that it is not
 
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