This section is from the book "Popular Law Library Vol11 Common Law Pleading, Code Pleading, Federal Procedure, Evidence", by Albert H. Putney. Also available from Amazon: Popular Law-Dictionary.
State or Illinois, ..........County.
ss.
..........Court of..........County,
............Term, A. D. 190..
..............................Plaintiff......in this suit, by...........
Attorney....., complain.....of......................................
Defendant......of a plea that ... .he.... render to the said Plaintiff....
the sum of..........................................Dollars, which at.............................to wit: at...........................
.... he.... owe.. . ., and unjustly detains from................
For that, Whereas, the said Defendant...., heretofore, to wit, on the..........................day of............................in the year of our Lord one thousand nine hundred...........................
in the County aforesaid, made..................................certain writing obligatory, sealed with.............................seal, bearing date the day and year last aforesaid, and then and there delivered the same to..................................................in and by which said writing obligatory, the said Defendant.... by the name, style and description of...................................................
agreed to pay to the order of the said..................................
by the name, style and description of..................................
.......................................................................................................................................
for value received. And the said......................................
to whom or to whose order the said writing obligatory was payable, afterwards, to wit: on the same day and year and at the place aforesaid, indorsed the said writing obligatory in writing, by which said indorsement the said
................................................then and there ordered and appointed the said sum of money in the said writing obligatory mentioned to be paid to the said Plaintiff...., and then and there delivered the said writing obligatory, so indorsed, to the said plaintiff..... By reason whereof, and by force of the statute in such case made and provided, the said Defendant.... became liable to pay said Plaintiff..... said sum of money mentioned in said writing obligatory, and being so liable, in consideration thereof, then and there agreed to pay the same to the said Plaintiff.............., according to the tenor and effect, true intent and meaning of the said writing obligatory aforesaid, and of the indorsement aforesaid, to wit: at the place aforesaid; and although the said sum of money hath been long since due and payable, and although often requested, the said Defendant.... ha.... never paid the said sum of money, or any part thereof, but refuse.... so to do, whereby an action hath accrued to the Plaintiff.... to demand and have of the said Defendant.... the said sum of..........................
..........Dollars and ....................cents, in said writing obligatory specified.
Yet the Defendant...., although often requested, etc., ha.... not paid the said sum of money, or any part thereof to the Plaintiff...., but so to do ha.... hitherto wholly refused, and still do.... refuse, to the damage of the said Plaintiff___of ..................................Dollars, and therefore .............. he.... bring suit, etc.
.............................................................
Plaintiff.... Attorney.........
..............Court of..........County.
Of the..........Term, A. D. 190..
ADS.
..................
Cognovit.
And the said.................................................
Defendant.....in the above entitled suit, by............................
Attorney....., come.... and defend....... the wrong and injury, when, etc., and waive.... service of process, and say.... that ... .he.... cannot deny the action of said Plaintiff...., nor that .... he.... owe.... and
..........indebted to the said Plaintiff.... in the sum of................
................Dollars and............................cents, and that the Plaintiff.... ha.... sustained damages on occasion of the non-performance of the several agreements in said declaration mentioned, including the sum of ................................................Dollars for
................reasonable Attorney's fees for entering up this Judgment, over and above..............other costs and charges by............about
..........suit in this behalf expended to the amount of..................
..........Dollars and......................cents; and the said Defendant..........further agree. .. . that no writ of error or appeal shall be prosecuted on the Judgment entered by virtue hereof, nor any bill in equity filed to interfere, in any manner, with the operation of said Judgment, and that .... he.... hereby release.... all errors that may intervene in entering up the same, or issuing the execution thereon, and consent.... to immediate execution upon such Judgment.
...............................................
Defendant.... Attorney....
 
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