Peter Primm vs. John Lane, James Mackey, John Bolly, and Jeduthan Kendal
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(11)

In the Town of Saint LouisSt Louis till the next day after
the date of said note or till the next day after
the said note was executed that there and on that event
your oratorwould be discharged from said note
or the sum of money mentioned to be securedthere in
and whether they the said Lane Bolly & others these
confederatesdid or did not lay ahold of the circumstances
of your orator being drunk and intoxicated to get
of your orator to execute said note and whether
they the said LaneLane and BollyBolly did not by the whole of their conduct on that occasion and by the
whole of the transactionintent and contract that
LaneLane on his part should buy the said horse from
BollyBolly and not pay for him at all but by the
aforesaid contrievance make your orator
pay for said horse without receiving anything
therefore and that BollyBolly on his part was to sell the said -
horse toLaneLane at the aforesaid priceperceivingLaneLane to
insolvent or nearly so and by the aforesaid means compel your orator to to pay for the same. And also that
the said BollyBolly may answer and fullystate what consideration he said BollyBolly receivedfrom the said
JamesJames Mackey MackeyJames Mackey for said note and why he transferred the
same to MackeyMackey and also why he assigned the same
to MackeyMackey without recourse to him said BollyBolly and
if part of the reasonwas not that he expected your orator
would not be ultimately liable to pay said note
and also the said JamesJames Mackey MackeyJames Mackey and JeduthanJeduthan Kendal KendalJeduthan Kendal
an particular required to state whether or not at the
time they or either of them took on assignment of said note if they or either of them did not know partially
or know by information of others that the said note

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(12)

had been obtained from your orator by fraud and
imposition and at the time the said JamesJames Mackey MackeyJames Mackey
took an assignment from BollyBolly of said note why the
said assignment was made so as to be without recourse
our said BollyBolly and what reason if any BollyBolly gave
for making such an assignment and what consideration the said JamesJames gave BollyBolly for said note
and also why the said JamesJames Mackey MackeyJames Mackey on hispart gave
his assignment of said note to the said KendalKendal
without recourse on him Or his by any
whatever eitherin law or equity and why the said
KendalKendal took such an assignment and what
consideration said KendalKendal gave said MackeyMackey
for said note and the said MackeyMackey and KendalKendal
are specially required to fully and clearly state all
they know of their own knowledge and all that
they know by information respecting the promises
as if the same had been fully set down have
and they had been interrogated thereto

And your orator prays that a writ
of injunction may be granted to stay the proceedings at
law on said judgment and execution directed to the
said JeduthanJeduthan Kendal KendalJeduthan Kendal and to the Sheriff of the said
County of Saint LouisCounty of Saint Louis and to the clerk of the CircuitCircuit Court
CourtCircuit Court for said County of Saint LouisCounty of Saint Louiscommending them
and each of them to desist from all other and further
proceedings an the said writ of execution and said Judgment
until the next time of this Court and theyto
beholden at the Town of Saint LouisSt Louis in and for the
county of saint Louis on the first monday in
February next and then and there said injunction may
be made perpetual and that a summons
may issue from the office of this court for the said
county of Saint LouisSt Louis To the said JeduthanJeduthan Kendal KendalJeduthan Kendal