And the said as to the said Pleas of the said Defendant by him secondly and thirdly above please [pleaded?] saith that the sum and the matte[r] and things therein contained in manner and for[m] as the same are above plea[d]ed and set forth are not sufficient in law to bar or preclude him the said from having or maintaining his aforesaid acti[o]ns thereof aganst the said Defendant and that the said is <​not​> bound by law to answer the same— and this he is ready to verify Wherefore he prays judgment and his damages by him sustained on occasi[o]n of the committing of the said grievances to be adjudged to him &c—