(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
(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


