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To the Worshipful Court of Norfolk County, in chancery sitting, Humbly complaining, sheweth unto your worship, Your Orator, Wm N Ivy that on the 30th day of October 1838 Thomas Williams of the County of Norfolk being indebted to your Orator in a considerable sum of money, to wit the sum of $5000, in order to secure the same did execute a certain deed of trust to Henry S. Allmand, trustee dated the day and year aforesaid, a certified copy whereof is herewith filed, marked (A) and prayed to be taken as part of this bill whereby he conveyed to the said Henry S Allmand trustee, certain real and personal estate, there in mentioned upon the trusts and conditions stated therein, Your Orator gives the Court to understand and be informed, that a considerable portion of the said debt is yet unpaid by the said Thomas Williams and that the said Henry S Allmand trustee, has departed this life so that the conditions and trusts of the said deed cannot now be fulfilled without the appointment of a new trustee. The said Henry S Allmand died intestate and his estate was administered upon by Robt E. Taylor to whom letters of administration were granted by the Court of Norfolk Borough on the [blank] day of 1843. The heirs at law of the said Henry S Allmand are John Allmand, Wm H. Allmand, Louisa, Elizabeth Albert Honoria and John Allmand Jr. Mary, Edward and Emmeline Tabb to whom the legal estate of the said real property conveyed by the said deed had descended. In Tender Consideration whereof and for as much as your Orator is without relief in the premises, save by the aid of a Court of Equity where matters of this suit are properly cognizable, to the end therefore that the said Thomas Williams, Robt E Taylor admr of the said Henry S Allmand, John Allmand, Wm H Allmand, Louisa & Elizabeth Allmand, Albert, Honoria & John Allmand Jr, Mary, Edward, & Emmeline Tabb, the last six being infants under the age of 21 years, may be made parties defendant hereto that said last six by a guardian or guardians to be assigned them by the Court and may answer the allegations of this bill as fully as if particularly interrogated thereto that the worship Court will appoint a new trustee in place of the said Henry S Allmand to succeed to all the powers and duties conferred and imposed by the said deed upon the trustee therein named and grant such further