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Rye (P) sued upon a promissory note and Phillips (D) plead an accord and satisfaction. P objected to the introduction of the accord and satisfaction evidence at trial, and that was sustained. P then motioned for a directed verdict which was granted; a mere promise of a creditor to receive, and of the debtor to pay, a sum less than the debt in full satisfaction of it is without consideration and binds neither party. D motioned for a new trial, that was denied, and D appealed.

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