The following facts are affirmed by the complainant
and denied by the defendants; there, that on the
county third day of March in the year eighteen hundred and eleven at the town of St. LouisSt Louis in the
Territory aforesaid, John LaneJohn Lane and John BollyJohn Bolly did
persuade and procure the complainant to be
made and become drunk and intoxicated with
strong liquors;

2nd That when the said BollyBolly and then and there sell to
the said LaneLane a certain studhorse for two
hundred dollars.

3rd That The said horse was not then and there
in good conscience worth more than sixty dollars
4th. That the said LaneLane was then and there very poor
and unable to pay the said sum of two hundred
dollars.

5th That the said LaneLane and BollyBolly then and there agreed
between themselves to induce the said complainant
to become boundtogetherwith the said LaneLane in an
obligationornote to the said BollyBolly for the payment
of the said sum of two hundred dollars

6th That the said BollyBolly was to use his exertions to will
the complainant to become bound as security for said
LaneLane for the payment of said sum of money.

7. That the complainant at firstrefused to be come bound
as security as aforesaid

8th. That they did procure him to become intoxicated
with an exception to induce him to become bound
as the security of the said LaneLane for the payment
of the said sum to the said BollyBolly .

9 That when he was thusintoxicated the said
BollyBolly and LaneLane and others declared and
operator to the said complainant that the said
complainant would never be injured by being
security in that behalf for the said LaneLane . and
most particularly assured the complainant
that the said LaneLane as a man of honor and
would not let any who would befriend him
suffer.

10 That when the said BollyBolly and LaneLane presented
the said obligation or note to the complainant
they pretended and assented to him the same
contained a condition therein that if the said
LaneLane remained in the town of Saint LouisSt Louis
until the next day after that then present
day, then the complainant was discharged
from the effect of the said obligation a note.

11 That the complainant then requested the
said BollyBolly to read the same to him or to
let the complainant read the same