committing of the said grievances by the defendant as aforesaid, from thence hitherto wholly refused and still do refuse to have any transaction, acquaintance, or discourse with him the said plaintiff as they were before used and accustomed to have and otherwise would have had; and also by reason thereof one Edward Dale, who, before and at the time of the committing of the said grievances, was about to retain and employ, and would otherwise have retained and employed, the plaintiff as his servant for certain wages and reward, to be therefore paid to him, afterwards, to wit, on the day and year last aforesaid, wholly refused to retain and employ the plaintiff in the service and employ of him the said Edward Dale (s), and the plaintiff hath from thence hitherto remained and continued and still is wholly out of employ; and the plaintiff hath been and is by means of the premises otherwise greatly injured to the plaintiff's damage of £ and thereupon he brings suit, &c.

SECT. 3.-The next Precedent is for Words spoken of a Doctor of Physic.

FOR that whereas the plaintiff, before and at the time of the committing of the several grievances hereinafter mentioned, was and now is (†) a doctor of physic, and the profession, business, and calling of a doctor of physic hath practised, carried on, and exercised, and still doth practise, carry on, and exercise, with great skill, care, and integrity, and, before the speaking and publishing of the false, malicious, slanderous, and defamatory words herein-after mentioned, had duly taken the degree of doctor of medicine, and obtained

(s) As to the averment of special damage, see ante, p. 102.

(t) As to the averment of special character, see ante, p. 99.

a diploma conferring on him the said degree: And whereas the plaintiff hath not ever been guilty, nor was, until the speaking and publishing of the said libel as aforesaid, held, considered, suspected, or believed to be guilty, of quackery, forgery, fraud, imposition, or deceit; by means of which said several premises the plaintiff, before the speaking and publishing of the said libel, was not only held in high esteem and repute by all his neighbours and other good and worthy subjects of this realm, but had also thereby acquired and was then daily and honourably acquiring certain great gains and emoluments in the exercise of his profession, calling, and business as aforesaid; yet the defendant well knowing the premises, but greatly envying the happy state and condition of the plaintiff, and contriving, and wickedly and maliciously intending, to injure the plaintiff in his good name and reputation, and to bring him into public scandal, shame, and disgrace with and amongst all his neighbours and other good and worthy subjects of this realm, and to cause it to be suspected and believed by those neighbours and subjects that the plaintiff was not a physician, but a quack, and had been guilty of forgery, fraud, imposition, and deceit, and thereby to injure the plaintiff in his said profession, calling, and business, heretofore, to wit, on the now last past, in a certain discourse which he the defendant then had with divers subjects of our lady the now Queen, and in the hearing and presence of divers other of such last-mentioned subjects, of and concerning him the plaintiff in his aforesaid profession, calling, and business, and of and concerning a certain diploma then alleged by one of the said last-mentioned subjects to have been shown him by the plaintiff, creating him the plaintiff doctor of medicine, he the defendant then,

day of

in the presence and hearing of the said last-mentioned subjects, falsely and maliciously spoke and published of and concerning the plaintiff in his said profession, calling, and business, and of and concerning the said diploma, these false, scandalous, malicious, and defamatory words following; that is to say, " He (meaning "the plaintiff) is no doctor, but only a quack, and it "(meaning the said diploma) is forged." By means whereof the plaintiff hath been and is injured in his said good name and reputation, and brought into public scandal, infamy, and disgrace with and amongst all his neighbours and subjects, insomuch that divers of those neighbours and subjects have, on occasion of the committing the said grievances as aforesaid, from thence hitherto suspected him to have been and to be a quack, and a person guilty of forgery, fraud, imposition, and deceit, and have on that account from thence hitherto wholly refused and still do refuse to consult with and employ him in his aforesaid profession, calling, and business; and by means of the said several premises he the plaintiff hath been deprived of divers great gains and emoluments which would otherwise have accrued to him, and hath been otherwise greatly injured to the plaintiff's damage, &c.

SECT. 4.-The following is a Form of Declaration for Words imputing Insolvency to a Tradesman.-The Law upon this Subject is stated, ante, p. 19.

COMMENCE with the usual commencement and inducement of good character, and proceed :

And whereas also the said plaintiff, before and at the time of committing of the said grievances, and from thence hitherto, hath used and exercised and still uses and exercises the trade or business of a

uses and exercises his said trade or business with integrity and punctuality, and hath always well and truly paid and discharged all his just debts and obligations, and hath not been, nor is, nor, until the committing of the said grievances, hath ever been suspected to be, either unable or unwilling duly and faithfully to pay and discharge all such debts and obligations; by means whereof the said plaintiff, before the committing of the said grievances, had not only deservedly obtained the good opinion, confidence, and credit of all his neighbours and other good and worthy subjects of the realm to whom he was in anywise known, but had acquired and was still continuing to acquire in his said trade or business divers large profits and emoluments; yet the said defendant well knowing the premises, but contriving, and wickedly and maliciously intending, to injure the said good name, fame, and credit, and to bring him into public scandal, infamy, and disgrace, and to cause it to be suspected and believed that he the said plaintiff was in poor and indigent circumstances, and incapable of paying and discharging his just debts and obligations, and to oppress and ruin him the said plaintiff, in a certain discourse which he the said defendant then and there had of and concerning the said plaintiff in his said trade or business, the several false, scandalous, malicious, and defamatory words following; that is to say, "He (meaning the "said plaintiff) owes more money than he is worth. "He (meaning the said plaintiff) is run away. He

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(meaning the said plaintiff) is broke." By means whereof he the said plaintiff hath been and is greatly injured in his aforesaid good name and credit, and brought into public scandal, infamy, and disgrace with and amongst all his neighbours and other good and worthy subjects of the realm, insomuch that divers of

those neighbours and subjects, by reason of the committing of the said grievances, from thence hitherto suspected and believed and still do suspect and believe the said plaintiff to be insolvent, and incapable of paying and discharging his just debts, and have by reason thereof wholly refused to have any further dealings or transactions with the said plaintiff in the way of his trade or otherwise; and the said plaintiff hath been and is greatly injured and damnified in his said trade or business or otherwise, to the plaintiff's damage,

&c.

SECT. 5.-The next Precedent, which is for imputing Dishonesty to a Tradesman, commences with the usual Inducement of good Character, and proceeds as follows.

AND whereas also the said plaintiff, before and at the time of the committing of the said grievances, and from thence hitherto, hath used and exercised and still uses and exercises the trade and business of a tailor, and hath always conducted himself and still continues to conduct himself with honesty and integrity in his said trade or business, and hath never been guilty, nor, until the committing of the said grievances, been suspected to have been guilty, of any cheating, fraud, or dishonesty in his said trade or business, or otherwise; by means whereof the said plaintiff, before the committing of the said grievances, had not only deservedly obtained the good opinion, confidence, and credit of all his neighbours and other good and worthy subjects of the realm to whom he was in anywise known, but had acquired and was still continuing to acquire in his said trade or business divers great profits and emoluments for his maintenance and support; yet the said defendant well knowing the premises, but