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with the sd Turnipseed on his counsel as orator supposes
and are the foundation of two of the actions brought as afd
against Orator

XV. Orator further sheweth that the sd several bills
of sale are in equity to be taken and considered as
mere mortgages to secure the sum really due to said
Turnipseed with legal interest, and on the payment
of the sd sum really due, with legal interest the said
several bills of sale ought to be delivered up by the sd Tur-
nipseed to Orator together with the sd two notes purporting
to be given for the hire of the sd slaves, to be cancelled.

XVI Orator further sheweth that he ever hath been
and still is willing to pay the sum really due with
legal interest, and Orator had well hoped that the sd
Turnipseed after he had received the sd bills of sale as afd
would have come to a just and equitable settlement
with Orator, and upon the payment of the sum really
and justly due with the legal, would have delivered up
the sd bills of sale and the sd two notes to be cancelled - But
now so it is may it please your Honor the sd Turnipseed
pretends that the sd bills of sale are not and were not in-
tended as mortgages but are really and legally absolute
bills of sale intended to pass the title to the sd slaves to
sd Turnipseed and that the sd notes were really given for
the hire of sd slaves, and insists upon the prosecu-
tion of th esd actions against orator, all which pre-
tences orator charges are untrue - In consideration whereof
and for as much as orator hath not any adequate ve-
[?] at law, and can only be relieved in this Honor-
able Court, where matters of this and the like kind are
properly recognizable and relievable - to the end there-
fore orator prays that that [sic] the sd Turnipseed may be