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To the Hon. Daniel Smith, Judge of the Circuit Superior Court of Law & Chancery in and for Rockingham County the bill of complaint of Henry Phillips humbly complaining respectfully sheweth That on or about the 20" of March 1846 one Andrew Newman then a resident of the state of Missouri was the owner of a negro man Slave named Bill in the county of Rockingham under the control of James Newman & Alexander Newman as agents for said Andrew Newman with power to sell his Slaves; on the day above stated your orator purchased of said James & Alexander acting as agents for Andrew Newman the said Slave bill at and for the price of five hundred dollars, payable in installments of one hundred cash the first payable on the 15th May 1846, the other installments of one hundred dollars cash were to be paid on the 20th of March 1847, 1848, & 1849 & 1850 - The two last installments to bear interest from the 20th of March 1848; the bill of sale is filed herewith as exhibit A - and it will be perceived that there is no warranty of soundness in the bill of sale - although the price agreed on was the price of a sound slave; the bonds were not drawn in exact conformity with the contract but are drawn so that the three cash all fall on the 20th of March 1848; your orator objected to sign the bonds so drawn, but was induced to sign them by the assurance of Alexander Newman that the matter should be adjusted. Andrew Newman to whom the bonds were made payable having departed this life Jacob Hornsberger his administrator instituted an action of debt upon three of the bonds (your orator having paid two of them) on the law side of this court and at the May Term 1849 recovered