Peter Primm vs. John Lane, James Mackey, John Bolly, and Jeduthan Kendal
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Orator says that said writ of execution is not
on his your Orators good & C
but that the said executionyetremains in the
hands of the said Sheriff an executed your
Orator now here offer to your Honors a record of
proceeding hadin said court and the judgmentof
saidcourt on said casewhich will more
fully appear reference being had theretoall of
which and doings and pretenses of the
said John BollyJohn Bolly JohnJohn Lane LaneJohn Lane JamesJames Mackey MackeyJames Mackey
JeduthanJeduthan Kendal KendalJeduthan Kendal and others their confederates
are contrary to all equity and good conscience
and greatly tend to the defrauding of your Orator
of his just rights Intended consideration whereof and for
as much as your Orator is without remedy in the
premises at the common law and as the premises

properly relievable before your honorson this
Court sitting as a courtof Chancery where
contractsfraudulentcontractsfrauds
and impositions are setaside and where
fraudsandimpositionsofthisnatureare
most properly cognizable to the end therefore that
the said JeduthanJeduthan Kendal KendalJeduthan Kendal JohnJohn Bolly BollyJohn Bolly JamesJames Mackey
MackeyJames Mackey and John LaneJohn Lane and others their confederates
where discovered may full true and perfect
consciencemake to all and every the matters and
things herein contained as particularly and as fully
as if the same were here again repeated and disinterrogated
and that not only a to their direct and
positive knowledge and remembrance but also as to
their best information judgment and belief and especially
that the said John LaneJohn Lane and John BollyJohn Bolly
may answer and set for the whether or not your

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Orator PeterPeter Primm was not at the time of executing
the said promisory note drunk and intoxicated
to a degree so as to render him in their judgment
and opinion unable to manage his own business
and concerns with any kind of skill
or judgment whether they the two of them oreither
of them the said LaneLane or BollyBolly did not endeavor
and use their exertions to get your orator drunk
and intoxicated as stated herein and when your
Orator wassodrunkand intoxicated prevail on
your Orator to execute said promissory note
as security for said LaneLane and whether your
Orator and not for a long time reprise to execute
said note when sober and free from & intoxication
and whether or not at the time of said notes
execution the said LaneLane was not considered and
generally regarded to be insolentor nearly so
and whether said horse was in good conscience
worthmore than sixty dollars and if sohow
much more and whether BollyBolly about that
time where said note was about to be executed
did not state to your Orator that LaneLane
never would leta manbe in
who would befriend him and whether your
Orator did not expressa wish to have the said
note read to him or to be permitted to read it himself
and whether they said Bolly LaneBolly Lane and others
their confederates did not that that was
unnecessary as BollyBolly was a man of honor and
would not deceive your Orator and fully and
specially whether the said BollyBolly did not then &
before the execution of said note pretend to your
Orator that the said note Contained a condition
therein that if the said LaneLane wouldremain