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that the sum which he may be entitled to recover in consideration of the matters hereof, depends upon the result of the settlement of extensive & difficult accounts, which of itself would make his claim over equitable jurisdiction, even if the said Martha, against whose estate in the hands of her Committee he is seeking recovery, did not belong to that unfortunate class, of whom the Court of Chancery from its earliest foundation has ever the been voluntary difficient Guardian. Your Orator therefore being wholly remediless at law & relievable only in a Court of Equity where matters of this sort are properly cognizable humbly prays that the said William Watts and Edward Saunders as Committee of the said Martha Watts may by the proper process be made parties defendant to this suit, and compelled on oath to answer the allegations hereof as fully as if the same were here repeated & they thereto specially interrogated. May it further please your Honor to direct all proper accounts to be taken & finally give to your Orator such compensation & relief in the premises as may appear to be just & proper. Grant to your Orator the Commonwealth's writ of Subpoena "Commanding &c" and all such other aid as his case may require & equity & good conscience dictate, as as in duty bound he will ever pray &c.
John B. Dabney & N. H. Campbell } Attys