Practicing Law in the Early American Republic

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