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UVA Law Library at Sep 18, 2017 05:17 PM

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Orator further sheweth that during the Interval between his purchase made of the
said Land from the said Welsh as aforesaid, and the time when your Orator
made the discovery of the Fraud and Deception practiced upon him by the said
Welsh which has been above stated, the said Welsh who had previously contract
ed an account with a certain Peter Lanck as Your Orator has been informed and believes assigned to the said Lauck, your
Orators Bond for fifty Pounds being one of those abovementioned to have been
given by your Orator to the said Welsh in part of the Consideration for the
Tract of Land aforesaid.
And Your Orator further Sheweth that immediately after receiving Information from
the said Edward Smith of the said Rootes having a Mortgage from the said Welsh
upon the said Tract of Land, which Information Your Orator believes to be true, Your
Orator called upon the said Peter Lauck, informed him of the Fraud which had
been practiced upon your Orator by the said Welsh, and apprized the said Peter
Lauck whom your Orator prays may also be made a Defendant to this his
Bill of Complain of the acquitable Defence which Your Orator shoud rely up-
on in order to extricate himself from the Payment of the said Bond, and
at the same time admonished the said Lack that he has better endeavour to
obtain satisfaction from the said Welsh; which Your Orator well hoped the
said Lauch woud have done - But now So it is, May it please Your
Honour, that the said Peter Lauck (coulining and confederating with the
said Thomas Rootes, and James Welsh and with divers persons unknown to your
Orator whose Names when discovered Your Orator prays may be inserted herein
with apt words to charge them as parties) hath actually brought Suit in the
County Court of frederick upon the said Bond and having obtained a Judg
ment thereon hath issued as Executor thereon, altho Your Orator is apprehen
sive from the prior Mortgage of the said Rootes, and from the desperate Circ
cumstances of the said Welsh that no Compensation can ever be recovered for
the Injury which Your Orator hath already sustained, All which Actings
and Doings of the said Lauck and his Confederates are contrary to Equity
and goo Conscience -- in tender Consideration where of and for as
much as Your Orator is without Remedy in the premisas at the Common
Law, and is proper to be relieved before your Honour in a Court of Equity
where frauds and Impositions are set aside and Evidences unduly detained
an directed to be delivered up, and Matters of this Nature are properly
cognizable -- To the End therefore that the said Peter Lauck, James Welsh
and Thomas Rootes, and their Confederates when discovered, may full, true
and perfect Answers make to all and singular the premisas, as if the same
were here again repated and interrogated -- And especially that the said
Thomas Rootes may upon his corporal Oath declare whether the Mortgage afore
said from the said Welsh to him the said Rootes was really executed at the time

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Grator further sheweth that during the Interval between his purchase made of the
said Land from the said Welsh as aforesaid, and the time when your Grator
made the deserving of the Fraud and and reception practiced upon him by the said
Welsh which has been above stated, the said Welsh who had previously contract
ed an account with a certain