Michel Lacroix vs. Louis Tayon, Maurice Blondeau, and Bazile Proulx
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of getting paid either by ProulxProulx or TayonTayon that the said
TayonTayon will knowing he never paid one cent to ProulxProulx
for said note and that the assignment there of was only
intended to enable him (as he himself stated and
persuaded said ProulxProulx to believe) to collect the debt &
not to transfer the property therein to him and will
knowing moreover the advantage he has over your orator
at common law by said endorsement in
order to displace your orator out of the amount
due on said note; is proceeding to collect the same
by execution against said Blondeau & if not
from him then from your orator & said Lee as
his bail

But now so it is may it please your honors the said
Louis TayonTayon and confederating to and with them the said ProulxProulx & Blondeau & with divers
other persons at present unknown to whose names
where discovered your orator prays may be inserted in
this his bill of complaint with apt words to charge them
the order to defraud & cheat your orator out of the amount
remaining due as aforesaid on said note amounting
as aforesaid to the sum of about sixteen hundred
dollars currency of the United StatesUnited States, pretends that
he is entitled to the whole amount of said balance he well knows that he paid nothing for said
note - that it was endorsed by said ProulxProulx in
blank that is merely with his name or signature
on the back thereof, merely to enable him the more
certainty to collect the amount thereof and not to
transfer the property therein to him, and altho he
well knew that the aforesaid amount then
due on said note was due andowing to your orator as the equipper of said ProulxProulx at and
before the time of said endorsement yet of his own accord
if he did not purchase said note in fact & intruth & on that can in collusion

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with said ProulxProulx is endeavoring to cheat & defraud your orator of the same
your oratorfurthermore states that the said note has been
repeatedly demanded of said TayonTayon both by your orator
and the said ProulxProulx as has been stated to your orator by this last also that he should desist from
the collection thereof. To which he replies that if your
orator will give him five or six hundred dollars out
of the aforesaid ballance of said note he will give it up
Being fully aware that your orator would be able in this
honorable court where the merits of this transaction can be
fully searched into, thoroughly to develope and expose to the
scorn & contempt of the publick this most wicked and
nefarious fraud the said Louis TayonTayon has also through
different persons and at different times, proposed a
compromise to your orator and offered to relinquish
his claim to the contents of said note of your orator
would pay him a certain sum of money less than
half the amount of said balance for which he has
obtained judgement. In the fullness of his hopes
that the laws of this country would afford him an
opportunity of showing the justice of his claim
to the which amount of said judgement, your orator
has uniformly spurned with indignation
at all their offers of a compromise for a part thereof. All which actings &
doings of the said Louis TayonTayon & the confederates are fraudulent oppresive & unjust

In under consideration whereof and
for as much as your orator is perfectly remedyless
at Common law and cannot have a discovery from
said TayonTayon & the said ProulxProulx themselves on their oaths whether the said TayonTayon did
really in truth purchase said note of ProulxProulx &
of so how much he paid for or whether the same
was not left in his hands & opposition merely for
collection & endorsed by said ProulxProulx in blank for