Brief Prepared by James Monroe in Monroe v. Skinner, 20 October 1824 - Page 1

To the honorable Henry St. George Tucker, Judge of the
Superior Court of chancery holden at Winchester, Respectfully
complaining

Herewith unto you Honor your Orator James Monroe
that your Orator is the proprietor of a tract of land in the County of
Loudoun of which the late Joseph Jones, formerly a Judge of the
General Court died seized and possessed: that the said landing purchased
with other land contiguous to it, about the year 1794 by your Orator and
the said Joseph Jones, jointly, from Charly Carter who had claimed
and recovered the same from Robert Carter of Romini by virtue of
of the last will and testament of a common ancestor. Your Orator has under
stood, and believes it to be a fact, that when a conveyance was made by the
said Robert to the said Charles, there was a provision inserted in the deed for
the benefit and security of the tenants who had obtained leases from the said
Robert, that on the 16 day of October in the year 1767, the said Robert executed
a deed to one Thomas Hill for 213 acres, for three lives, as will be seen by
reference to an authentic copy of the said deed, hereto annexed as part of this
will, that the whole of the quantity of 213 acres lay within the boundaries of
the land conveyed by the said Robert to the said Charles and by the latter under
under the sale aforesaid, to the said Joseph Jones, and your orator: that the
[?] of this tract of 213 acres being thus in the said Joseph Jones and
your orator, a part thereof about 128 acres, with other land in possession was
conveyed in fee simple to one Chapman: so that there is now remaining in your
orator the [?] right to about 80 or 85 acres: that of the tract of 213 acres,
one Nathan Skinner who is prayed to be made defendant hereto is in possession
claiming right to the same, by virtue of a transfer thereof, from some person
having right thereto, and by virtue of the fact which he alledges that two of
the certain [?]viz, to wit, Joseph and Reuben Hill are yet alive: whether
the fact be so or not, your orator does not know: but upon this point the said
defendant is bound, as will presently appear, to give information. Your orator begs
leave farther to state, that occupied as he has been for several years, with public
concerns, he has had very little time to donate to his private affairs, but in the
transient views which he took of the subject, he thought that he could easily
discern, that the defendant had forfeited his right to the land, first by not
keeping on the land the buildings required, and secondly by the commission of
egregious waste, not more than one eighteenth part of the land as he believes being now in wood:
that your Orator became desiory of obtaining this land from the defendant in an