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To the Honorable Robert W Baker judge of the Circuit Superior Court of Law & Chancery for the County of Norfolk humbly complaining shews unto your Honor your Complainant Thos Williams, that in the year 1838 Wm N Ivey then of this County pursuant to your Complainant to form a corpartnership with him for the purchase of slaves to be sent to Louisiana to be there employed on their joint account & afterwards disposed of for their joint benefit. To commence this business the said Ivey proposed that himself & your Complainant should put a note with their joint names discounted of the Exchange Bank of Virginia at Norfolk for five thousand dollars, that so much of the proceeds as might be necessary should be paid to your complainant, that the said Ivey should give a deed of trust upon certain property belonging to him to secure the said Bank, & that your complainant should execute a deed in Trust upon certain property belonging to your complainant to secure the said Ivey. Your complainant charges that the said copartnership was accordingly formed, the said note jointly signed by Ivey & himself, discounted of the Bank, a deed of Trust given by Ivey to secure the same & a deed duly executed by your complainant dated the 30th October 1838 conveying to Henry S Alimand as trustee certain property therein mentioned. This deed, tho it recites that your complainant was indebted to said Ivey in the sum of Five thousand dollars, your Complainant avers was in fact intended only to secure any amount which your Complainant might owe to said Ivey as a final settlement of the concerns between them. Your Complainant admits that he received the greater portion of the proceeds of said note, all which he invested in the