"To the honourable John Brown, Judge of the Superior Court of Chancery holden at Staunton. The bill of George S. Clemmer respectfully represents, that on the 20 day of November 1820, Charles Potter, David Potter, Catherine Potter and Eve Potter entered into a contract in writing with a certain Peter Koontz, whereby they convenanted to sell and bound themselves jointly and severally to convey to the said Peter Koontz four tenth parts of the tract of land whereon David Potter Senior resided at the time of his decease, that is to say, their four divided parts in the said tract of land, partition thereof having been before that time made in a suit brought by your orator in this court, in which case the plat of partition is filed whereby the several parts, to which the said Charles and Eve are entitled will appear, and to which your orator for that said purpose refers as a part of his case, as also to the contract aforesaid, herewith filed marked A. For this land, the said Peter Koontz covenanted to pay to the other parties to the said contract the several sums therein specified. This contract was afterwards assigned by the said Peter Koontz to your orator for a valuable consideration, as will appear by the endorsement thereon, wherby your orator became entitled to all the benefits thereof, and has received from the said David and Catherine conveyances of their parts, so that there only remains to be conveyed to him, those parts sold by the said Charles and Eve. Your orator states that some time after the date of the said contract, the said Eve Potter intermarried with a certain Christian Moneymaker, and soon thereafter departed this life without having had any issue by him, but leaving an illegitimate son named James Potter, an infant of tender years (which she had sometime before her marriage, by some other person), her only legal representative, to whom the legal title to her interest in the said land descended at her death. Your orator states that the said Eve and her husband, before and after her marriage, have received the sum of two hundred and fifteen dollars, forty-five and a half cents, on amount of her part of the land aforesaid, leaving a balance due under the contract aforesaid of only $4.54, as will appear by a statement and vouchers accompanying it herewith filed marked B. The said Charles has received the sum of $77.62 1/2 leaving a balance due him under the said contract of $122.57 1/2 - which said several sums your orator has always been ready and is now willing to pay upon receiving proper conveyances for those parts of the said land sold by the said Charles and Eve. Your orator states that the said Charles Potter has failed to make him a conveyance, although often required to do so, and the said Eve, having departed this life without having made a conveyance, your orator is without relief in the promises without the will of this honourable court. Your orator does not believe that there was any administrator on this estate of the said Eve Moneymaker, and therefore knows not to whom the small balance aforesaid ought to be paid, but will pay it to whomsoever your honour may designate. He therefore prays that the said Charles Potter, James Potter, infant son of the said Eve, and Peter Koontz may be compelled to answer the same on oath of the balance due him - that a guardian be appointed to answer on the part of the infant defendant and a Commissioner appointed to convey for him the land sold as aforesaid by his said mother, and that the said Peter Koontz may say whether he did not assign the said contract to your orator - grant such other further relief to your orator as is consistent with equity and adapted to the nature of his case."
[no date given]