Plaintiff's Bill, 12 January 1801
Page one of a bill in suit in the case of Patrick Boyle and Michael McKewan v. George Lindenberger, signed by Wythe January 26, 1801. Special Collections Research Center, Swem Library, College of William & Mary.
Document Text, 12 January 1801
To the Honble the Judge of the High Court of Chancery of the State of Virginia Complaining Sheweth unto your honour your orators Patrick Boyl and Michael McKewan that a certain Charles Ingolesky & Charles W Ingolseby formerly Mr. chants & Co partners under the name and sign of Ingolseby & McKewan in the lawn of Martinsburg purchased of your Orator Patrick Boyl a considerable quantity of Goods Wares & Merchandizes to the am. of £1583.1 pounds for which they executed bonds & notes to your said Orator payable at different & distant time ^and now due which said bonds & notes are in your ^sd Orators possession ready to be produced at any time if required, that after the said Ingolseby & McKewan had for a short time carried on a losing & unprofitable trade in the said town & being likely to fail, they entered into an agreement with a certain Geo. Lindenberger, a Dep. hereinafter named and who was also a creditor of the said Ingolseby & McKewan agreed to deliver who all the Goods which they then had on hand and the debts due to them to the said Lindenburger in trust for himself your said orator and all other the Creditors of the said Ingolsby & McKewan to be applied to the equal benefit of all the said Creditors, as by a true Copy of the said Articles of Agreement.