Peter Primm vs. John Lane, James Mackey, John Bolly, and Jeduthan Kendal
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Territory of MissouriMissouri
County of Saint LouisCounty of Saint Louis A Bill in chancery for an
injuction to stay proceedings
at Law

PeterPeter Primm
Complainant vs
JeduthanJeduthan Kendal KendalJeduthan Kendal
JamesJames Mackey MackeyJames Mackey
John BoleyJohn Boley &
John LaneJohn Lane
Respondents

To the honorable the judges of the superior
court for the Territory aforesaid â sitting as
a Court of chancery â

The complaint of PeterPeter Primm
unto your honors humblycomplainingtherewith â

That in the year one thousandeight hundred and eleven
or about the twenty third day of the month of March
in that year at the Town of Saint LouisSt Louis your orator
then being on his partaccidentally in company with and
in the presence of and John BolyJohn Boly then of the the district
of Saint LouisSt Louis now the county of Saint LouisSt Louis and oneJohn LaneJohn Lane
of the same place. And that then and there sometime in the
presence of your orator and at other times a little as well from
your orator's full hearing there was a certain conversation
and pretendedtreaty of a certain contract as sale of a certain
stud or seedhorse between the said BollyBolly and LaneLane
Where upon the said BollyBolly offered and proposed the said horse
to the said LaneLane for sale and asked for said horse of said LaneLane
the sum of two hundred dollars and thereupon the said LaneLane
agreed to give the said BollyBolly the said sum of two hundred dollars
for said horse whereas in truth and good conscience the
said horse was not worth more than sixty dollars and there
upon the said LaneLane and BollyBolly agreed between themselves that
the said LaneLane now to have the horse for the aforesaid sum

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of money and that the said LaneLane then being very poor and
unable to pay the said sum of money the said LaneLane was to
use his exertions to induce and procure your orator to become
bound with him said LaneLane in an obligation or note for the
payment of the said sum and also the said BollyBolly was to use his
exertions with your orator to procure and induce him your orator
to execute to him the said BollyBolly an obligation or note as security
for said LaneLane for the payment of the said sum of money and for
the aforesaid before the said LaneLane and BolyBolly confederating
with many others unknown to your orator did persuade and
endeavor with your orator to become the security of the said -
LaneLane for this payment of the said sum of money and execute
an obligation on note with said LaneLane for the said sum of money
to be paid to the said BollyBolly and thereupon your orator
refused to so to do and could not execute said note or obligation
as security for said LaneLane But the said BollyBolly and LaneLane not
yet content with your orator did use furtherartfraud and
circumvention in this behalf by persuading your orator to drink
strongdrink thereby intending to prevail on your orator to get
drunk and become intoxicated and get him your orator
in that situation to become security for said LaneLane for
the payment of said sum of money to the said BollyBolly and
your orator says that the said LaneLane and BollyBolly together with
others their confederates did prevail on your orator then and
there afterwards on the day aforesaid to get drunk and become
intoxicated by their urgent and frequentlyrepeatedsolicitations
to drinkwhiskey and other strongdrink under a pretense
of much friendship and extraordinary regard they had for your
orator. Whereby your oratoraftermanyhours of repeated solicitation
and pretendedfriendship of the said BollyBolly and LaneLane and
others their confederates was induced to drink much whiskey and
other strongdrink as that heyouroratorbecameextremely
much drunk and intoxicated and entirely incapable to manage his concerns
with any kind of direction judgment or presidence
and your orator thus being in that situation was again solicited and requested by the said Lane Bolly and
others their confederates to become bound with the said
LaneLane in an obligation or note for the payment of the
aforesaid sum of money to the said BollyBolly for the price
pretended to have been agreed on for said horse by said
LaneLane and BollyBolly . The said Bolly LaneBolly Lane and others