Practicing Law in the Early American Republic

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

Charlottesville 13 Jany. 1844.

D Sir

I learn by a letter, just rec'd but in a manner too indefinite to found any actions upon, that a suit is pending in one of the Courts of Essex. I presume the Superior Court, and I take it for granted, in Chancery between Wormeley's ex'ors, and the the heirs of Staige Davis, of Middlesex, in which is involved the title to a tract of land near Urbanna, of which Mr Davis died seised many years ago, and which appears to have been sold by his heirs, or some of them, to a Mr Oakes.

The same letter informed me that Mr Wright, had been employed as counsel for Davis' heirs, but as I can only conjecture that his address is Tappahannock & it is important to have the information I seek without delay, I take the liberty of trespassing upon your Courtesy, so far as to request you to communicate this letter to Mr Wright, if he resides at Tappahannock, or within your reach, and if otherwise, to send me, yourself, a brief statement of what I wish to know.

I am anxious to learn 1. The style of the suit, that is the names of the parties, plaintiff and defendant, and the court where it is pending.