Brief Prepared by James Monroe in Monroe v. Skinner, 20 October 1824 - Page 3

himself, holds the land in defiance of right, in defiance of his bargain, and
of the decision of the referees, without assigning any other reason in indication of
his conduct than this, - that he does not approve the award or decision, and that
your Orator formerly, of his own accord, offered better terms. In tender
consideration whereof, and for as much as your Orator cannot obtain a complete
title to the said land, without the aid of a Court of Equity, whose peculiar province
it it is to compel the officials execution of contracts, and to prevent waste and
destruction of property. To the end therefore, that the said defendant may or
[hath?] answer the premises, as particularly as if he were here interrogated as to
each allegation, that the said defendant may, be compelled by a decree of
the honorable Court, to surrender the said land to your Orator, and in the mean
time, to abstain from committing any kind of waste on the same, or taking
any thing there from, and that your Orator may have such relief in the premises,
as may be consonant to equity. May it please your Honor to grant to your
Orator a writ of subpoena and of injunction directed to the said defendant,
commanding herein to abstain from entering on the same land, or from cutting
any thing thereon, or committing any waste thereon, &c. &c., and your Orator
&c. &c.
James Monroe

District of Columbia, Washington County [?],
This day, to wit the
twentieth day of October in the year 1824, James Monroe came
before me a Justice of the peace for the said County, and made said
that the facts alleged in the foregoing bill are true to the best of his knowledge
and belief. Given under my hand the day and year, aforesaid.
R. C. Weightman. Seal