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To the Honourable the Judge of the High Court of Chancery

Humbly complaining Sheweth unto your Honour, Your [Gratar?] William Holliday
that sometimes in the year eighteen hundred. Your [Grator?] purchased in fee
Simple of a [certain?] James Welsh one of the defendants herein after named
a Fract of Land near the Town of Winchester in the County of frederick,
containing one hundred and six acres, for which your [Grator?] agreed to give
three thousand five hundred dollars- that in [?] of this agreement
your [Grator?] conveyed in fee simple to the said Welsh a House and [?] in the said [Four?]
of Winchester valued by then said Welsh at the sum of seven hundred pounds
that he also paid to the said Welsh the farther sum of one hundred
pounds in Cash, and [?] to him three several Bonds, two of which
for one hundred pounds each, and the other for the Sum of fifty pounds
and your [Grator?] furthur sheweth that the said Welsh on his part at the
same time made to your Grator a Conveyance in fee Simple for the Fract
of Said abovementioned, having first [a?] your [Grator?] that his F
the was clear and indisputable, and that theres no Mortgage or any [?]
[?brance] what was upon that said Sand; and in order to confirm
his assurances thus made as aforesaid, he then said Welsh exhibited a
Letter written by a [?] Thomas [?] another [?] [?] hereto (the four?
answer of the said Land) to a certain Edward Smith [?] who was an agent
of said Rootes, stating that he the sad Rootes had sold the said Land
to the said Welsh, and desiring the said Smith to give & [?] to the said
Welsh, or if he then said Smith should have [?] the said Land, that the
[?] should pay the [?] to him then said Welsh_ and as a further
confirmation to his assurances the said Welsh did moreover exhibit to your
Grator- feed from the said Rootes to himself in fee simple containing
a ground Warranty and also sundry Tithe & [?] [?] to the said Land
which Letter, & end, and Tithe papers were [?] by the said Welsh to
your Grator.

And your Grator further sheweth, that in [?] as the said seed from the
said Rootes to the said Welsh had not been recorded, and that the Wife of
the said Rootes had not been a party to the said seed. Your Grator some
time afterwards requested the said Edward Smith to write to the said
Rootes for the purpose of maining a new Seed in which Mrs Rootes shou'd
become a party, who accordingly did write to the said Rootes and received for answer that he
the said Rootes had a [?] upon the said Land to the amount of twelve
hundred and fifty pounds which was a widened by a Mortgage from
the said Welsh to the said Rootes hearing even date with the Seed from
the said Rootes to the said Welsh, which informants when communicated to your
Grator [?] his astonishment and [?] and your

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