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that the said Lewis Allen, whom your orators and oratrixes pray to be made defendant hereto, refuses to permit them to prosecute their claims to freedom that the deposition of Ann Meriwether, which was taken in a suit instituted by them in the District Court of Brunswick for their freedom against David Allen, whose administrator the defendant says that he is, and which suit abated by the death of the said David Allen is lost out of the office of the District court aforesaid; but is, as your orators and oratrixes have been informed and believe, in the knowledge or possession of the defendant: that the said deposition fully established their rights. To the end therefore, that the defendant may, on oath, perfect answer make to the premises: that they may be decreed to be free, and the deposition aforesaid of the said Ann Meriwether may be established and perpetuated, she being very aged and infirm; that the defendant may set forth the names of the other persons of the family of your orators and oratrixes whom he has sold; to whom he sold them; and at what prices: that the defendant may be compelled to give security for the forthcoming of those sold at some [short?] day to be appointed; or that they may receive any further or other relief, more agreeable to equity

May it please your honor to grant to your orators and oratrixes a writ of subpoena and, if necessary, a writ of ne exeat to the said Lewis Allen directed, commanding him &c