LOUDOUN COUNTY, VIRGINIA - COURT RECORD, 1794 File contributed for use in USGenWeb Archives by: Renee L. Dauven ---------------------------------------------------------------------------------------- Joseph Burson vs Peter Romine. Chancery Court Records. M1675. Loudoun County Court. Leesburg, VA. Bill of Complaint To the Worshipful court of Loudoun County sitting in chancery Humbly Complaining shewth unto you Worships Your Orator, Joseph Burson That some time in the year 1792 a certain John Romine who he prays may be a defendant to this Bill of Compliant came to you Orators house and Bargained with him to serve him as a laborer on his plantation for the space of eight months his time to commence on the first of April in the said year and you Orator agreed to pay him for his service Twelve pounds. In consequence of the Bargain aforesaid the said deft. did commence his service with this Complainant in April and continued to live with him for about the space of three months at the end of which [creased paper] he intimated to this Complainant a desire to go to Winchester to see a criminal hang'd who had been condemn'd there and accordingly left this Complainants house with a promise of returning and staying his timeout with him. But this Complt. understood he enlisted himself at Winchester to go out against the Indians and never returned to the complainants house to comple[an?] his service nor has he ever seen him since. He gave his Father an order for his clothes left at this Complainents house and he was obliged to deliver them up to him. His said Father also commenc'd a Petition in behalf of the said defendant on the acct. hereto annex'd claiming wages for the three months he had lived with him at the rate of 3 [op?] per month. This Complainant in expectation that the defendant would serve his full time with had advanced him several articles which is [?anditted] him [page 2] in his said acct but he never expected that the defendant would charge him by the month as the Bargain was different and the principal inducement to the Complainant for hiring him was his labour during the whole of the busy season of the year and therefore he conciev'd that he not only ought to be discharg'd from the payment of any hire at all but he ought to have had his payment returned to him and therefore when the Petition was serv'd on him he told the Father of the defendent that he should defend it and came to Leesburg with that intention, But he was there told by his said Father not to do it, that he would take the Petition out of Court and they would make it up themselves and under this promise this Complainant returned home without employing a Lawyer and the said Peter the defts Father obtained in his absence and without his knowledge a Judgement against him on his said acct and threatens to execute the same on this Complainant all which actings and doings of the said defendant are contrary to equity and good concience and [tied?] to the manifest wrong and [approssion?] of your Orator. In tender consideration whereof and For as much as your Orator is remidiless in the premisses by the suit rules of Common Law and cannot be relieved but by the assistence of this worshipful Court. To the end therefore that the deft may true and perfect answer make to all and singular the premesses as if the ssame were herein again repeated and interrogated and that he be injoined from proceeding upon his Judgment asforesaid and that the Court may make such [page 3] award and determination as to them shall seem consistent with Equity and good conscience may it please the Court to grant to the Compt the Commonwealth most gracious [?] of Jupee and Injunction [?]. Swarn for the Complianant: Ack. to in Court February the 10th 1794 Wm H Harding DClerk ************************************************************************ USGENWEB NOTICE: These electronic pages may NOT be reproduced in any format for profit or presentation by any other organization or persons. Persons or organizations desiring to use this material, must obtain the written consent of the contributor, or the legal representative of the submitter, and contact the listed USGenWeb archivist with proof of this consent.