Literal transcription.  Punctuation, spelling and capitalization are accurate except when absolutely necessary for clarification.  Items in parentheses and italics are my own comments.  xxx denotes illegible word.  (sp) indicates misspelled word as it appears in document.  * indicates page break as noted in document.   ^ indicates inserted word.  –Tess Grant

                        To his Excellency Isaac H. Williamson

            Governor and Chancellor of the state of New Jersey

           

                                    Humbly complaining sheweth (showeth) unto your Excellency your orators “The President Directors and Company of the State Bank at Trenton” that your orators are a corporation and were incorporated by an act of the Legislature of this State pafsed (passed) on or about the twenty eighth day of January, in the year of our Lord Eighteen hundred and twelve with Banking priviledges (sp), capable in law to sue and be sued plead and be impleaded, defend and be defended in any Court of record and in any other place whatsoever__ That your orators shortly afterwards received deposits made loans and discounts ifsued (issued)Bank notes, post notes, Bank bills and carried on Banking businefs (business) until on or about the sixteenth day of May in the year of our Lord Eighteen hundred and thirty five, when the said State Bank being embarrafsed (embarrassed) in its affairs, stopped payment and ceased to carry on their said Banking businefs (business) __  That the President Directors and Cashier of the said Bank then in office, declared the said Bank to be insolvent, and refused to pay the creditors of the said Bank particularly such creditors as had made deposits and had ballances (sp) due them on accounts and those holding its Bank bills and notes-  That on the day and year last aforesaid Abner Reeder was President and one of the Directors and Robert McNeely, James T. Clark, Benjamin Fish, Jasper S. Hill, David Johnston, Francis S. Labaw, Stephen Clark, Evan Evans, John Barnard, John Potts, John R. Smith and Garret D. Wall were also Directors of the said *Bank and Lambert Richey was the Cashier-  That the said Directors had held their said respective offices from the second Tuesday in November then last past and most or all of them for a number of years preceding and some of them from the first organisation (sp) of the said Bank or for a considerable part of that time-  That the said Lambert Richey in or about the month of April 1816 took upon himself the duties of Cashier of the said Bank, he having been previously thereto appointed to that office by the President & Directors of the said Bank and continued to be the Cashier thereof until the said Bank stopped payment as aforesaid and for some time afterwards__  And your orators further shew (show) that at or about the time the said Bank stopped payments as aforesaid there was and for a long time before had been Three thousand and eighty shares or some other large number of shares of capital stock of the said State Bank subscribed on each of which shares had been paid the sum of thirty dollars or thereabouts making the capital of the said Bank actually paid in the sum of ninety two thousand four hundred dollars or thereabouts.  That the said bank had ifsued (issued) and in circulation one hundred and ten thousand four hundred and fifty six dollars or thereabouts in notes- besides other Bank notes Post notes and Bank bills to a very large amount not then ascertained and had received discounts or interest amounting to five hundred and forty three dollars and sixteen cents or thereabouts which had not been divided among the Stockholders, and was also indebted to several Banking Companies, Corporations, Dealers and Individuals in large sums of money part whereof was not ascertained and part liable to be disputed  and there were also doubtful and unjust claims against the said Bank__  That your orators were entitled to and then had in bills and notes discounted outstanding the sum of one hundred and eighty thousand two hundred and ten dollars and fifty one cents or thereabouts which Bills and notes discounted consisted chiefly of Promifsory (Promissory) notes and partly of Bills of exchange Bonds bills mortgages Checks drafts or securities for money made and given by sundry persons.  And your orators were also entitled to and then had in real estate in their Banking house lot and appurtenances in Trenton eleven thousand two hundred and fifty eight dollars and twenty eight cents or thereabouts and in other houses and lots six thousand dollars or thereabouts and were xxx (fixed? seized?) in xxx (fee? fees?) xxx (simple? in file?) of the said real estate and pofsefsed (possessed) thereof.  And your orators were also entitled to and then had in specie two thousand one hundred and thirty one dollars and sixty nine cents or thereabouts in Bank notes of other Banks six thousand two hundred and forty two dollars and fifty six cents or thereabouts-  They had also two hundred and sixty one shares or thereabouts of Capital stock of said of said Bank which at it par value amounts to seven thousand eight hundred and thirty dollars or thereabouts-  There was also due to the said State Bank from other Banking Companies and Corporations Fourteen thousand eight hundred and twenty nine dollars and fifty cents or thereabouts and sundry dealers with the said State Bank had overdrawn their accounts and were indebted to the said State Bank in the sum of one hundred and thirty five thousand eight hundred and fifty (or sixty) six dollars and thirty three cents or thereabouts-  And your orators had other property the particulars whereof are to them unknown-

                        And your orators further shew (show) that at the time the said State Bank stopped payment as aforesaid their accounts and affairs were in great confusion from design or accident or both and no accurate or satisfactory statement of its affairs was or could be made from which the debts or credits of the said State Bank could be rightly ascertained__  That on or about the twelfth day of May in the year last aforesaid a statement of the affairs of the said Bank was made by the said Lambert Richey the then Cashier of the said Bank entered in a statement Book kept for that purpose for the use of the said Directors and laid before them and a like statement was made by the said Lambert Richey on or about the twenty ninth day of August in the year  last aforesaid-  That another statement of the affairs of the said Bank was made at the request of the said Directors by Evan Evans one of the said Directors on or about the twenty eighth day of August * in the year last aforesaid__  And another statement of the affairs of said Bank on or about the twenty ninth day of August last aforesaid was made by Charles Parker Esquire at the request of the Stockholders of the said Bank or some of them but for greater certainty as to the said respective statements your orators pray leave to refer to the original statements when produced or to due proof thereof but which statements respectively your orators charge to be in many or some respects erroneous and many or some items and particulars were wholly omitted or wrongfully inserted therein-

                        And your orators further shew (show) that after the said Bank stopped payment as aforesaid the said President and Directors (except John Bernard who died shortly after and has left no personal representation in this state) continued in their said respective offices until on or about the second tuesday in November then next following, that during that time they did not pay the debts due to the Creditors of the said State Bank or make any provision for the due and just distribution among them of the property and funds of the said Bank xxx (rateably?) and in a fair and just proportion according to the sums or amounts due to them respectively or in any other manner-  That the Stockholders of the said State Bank or some of them being greatly difsatisfied (dissatisfied) with the conduct and management of the said surviving Directors refused to re-elect them and at an election held for * the choice of Directors for said Bank on or about the third Tuesday in October in the year last aforesaid thirteen other Stockholders were elected Directors and on the second Tuesday in November then next following the new board of Directors was duly organised (sp) and vacancies since happening in the said board have been filled-  That at the time of filing this your orators bill of complaint George Woodruff Esquire is President and one of the said Directors and William Potts, Samuel Paxson, Thomas Capner, George Brearley, Absalom Blatchley, Edward Yard, Isaac Gulick, Caleb S. Greene, Edmund Burroughs, Phineas xxx (Seales?), George Rozell & Henry A. Paxson- Are also Directors of the said Bank who have all taken upon themselves the duties of their said Offices-

                        And your orators further shew (show) that the said new board of Directors got pofsefsion (possession) of the Banking house for your orators and several large parcels of the Bank notes of the said State Bank being only part of the amount ifsued (issued), and some of their books and papers but one or more book or books and papers of said Bank has or have been withheld from them particularly the latest book of minutes, of the said Bank containing their proceedings for several years then last past was kept and withheld by the said late surviving Directors or by some or one of them and is still kept and withheld from your Orators and the said new board of Directors contrary to their frequent requests, who have been permitted on one or more occasions to examine the said Book of minutes, but have * not had liberty so to do – as they have requested and as occasion required;  That your Orators or the said New Board of Directors got pofsefsion (possession) of no other property except the small sum of Sixteen dollars and eighty cents or thereabouts which was overlooked and left by the said late directors by accident or mistake, all which and more has been necefsarily (necessarily) expended in and about the businefs (business) of the said Bank-

                                                            And your Orators further shew (show) that they made rules and regulations for conducting the businefs (business) of the State Bank at Trenton, they having lawful authority to make them, and thereby among other things ordained in words or in substance or effect, that all notes from any citizen of the State, should not be discounted unlefs (unless) two responsible names were given at least the drawer and endorser, nor should any note be received and allowed to be discounted from any citizen of any other State unlefs (unless) three responsible names were annexed, viz: the drawer and the endorser-  That there should be a quarterly meeting of the board of Directors for the regulation superintendance (sp) and examination of the affairs of the Bank-  That a Committee of three of the board of directors should be appointed every quarterly meeting of the board whose duty it should be to examine the State of the Bank every month and enter the report of their examination in the minutes book kept for that purpose and before the expiration of that appointment examine the monies in the vault and compare the same with the account exhibited by the Cashier and report * the same to the first meeting of the board, but for greater certainty as to the said rules and regulations your orators pray leave to refer to the same when produced and shewn (shown) to this Court; or due proof made thereof- which said rules and regulations were in full force and effect during all or a considerable part of the time the said late Directors were in office as aforesaid__

                        And your orators further shew (show) that since the said new board of Directors was organised (sp) as aforesaid your orators have been and now are entirely without money funds or means to pay the creditors or satisfy the Stockholders of the said State Bank their just and lawful claims or any part thereof-  That the said late Directors for and during all the time they were directors as aforesaid were receivers and had the care and administration control and management of all the Books papers Post-notes Bank notes and Bank-bills Capital monies funds and property belonging to the said Bank and received by said Bank in deposit for safekeeping or otherwise from persons and corporations dealing therewith to a xxx large amounts to your orators unknown That the said late Directors during all the time they exercised the said corporate powers as aforesaid were Trustees for your orators and accountable in this Court for every fraudulent breach of trust committed by them as such Trustees-  That at or about the time the said Bank stopped payment as aforesaid and for some time before and afterwards the said late Directors or some of them committed permitted or * suffered xxx fraudulent breaches of trust hereafter mentioned in respect to the monies Books papers funds and property of your orators under their management and controul (sp) as aforesaid and that Lambert Richey, John Davifson (Davisson), Charles Gordon, James Tunney, Pierson Hunt and the Trenton Banking Company or some or one of them knowingly aided and afsisted (assisted) in all or some or one of the said fraudulent breaches of trust-

                                    That the said state Bank in its fair and regular businefs (business) had not met with any such lofses (losses) as would deprive their creditors of the payment of their just demands nor the Stockholders of the Capital paid in or some considerable part thereof-  That the said State Bank has been and is ruined in its credits and greatly injured in real and personal property by the mis-application of said property or the fraudulent breaches of trust or both of the said Abner Reeder, Robert McNeely, James T. Clark, Benjamin Fish, Jasper S. Hill, David Johnston, Francis S. Labaw, Stephen Clark, Evan Evans, John Bernard, John Potts, John R. Smith and Garret D. Wall while in office as aforesaid and their confederates and thereby the said last named Directors and their confederates became liable and the survivors now are liable and ought to account to your orators for the said Post-notes Bank-notes Bank-bills capital monies funds and property or are chargeable and ought to be charged therewith either jointly or according to their respective liabilities-

                                                And your orators further * shew (show) that at or about the time the said Bank stopped payment as aforesaid or shortly before or after the said last named Directors or some of them and their confederates here after mentioned got in their pofsefsion (possession) or under their controul (sp) and converted and disposed of to their or some of their own uses and purposes or some other unlawful uses and purposes some of the Books and papers and all or some considerable part of the monies, funds, and real and personal property of your orators except what was obtained pofsefsion (possession) of by the new board of Directors as aforesaid-  That the said late Directors unmindful of their duty and in violation of the trust xxx (required?) in them as such Directors and with the intent and design to deprive your orators of their said property or to defraud your orators or for some other such purpose or purposes unlawfully placed or permitted or suffered all or a very considerable part of the monies funds Bills and notes discounted and personal property of the said State Bank to be placed beyond the immediate reach or controul (sp) of your orators or any new Directors that might thereafter be chosen thereby also hoping and intending wholly or partly to elude or avoid investigation – and all controversies respecting the same, and to embarrafs (embarrass) frustrate or discourage your orators from seeking any redrefs (redress) therefore-  That the said late Directors in pursuance of the fraudulent intents and designs aforesaid or for some other unlawful purpose or purposes wrongfully placed or permitted or suffered all specie and Bank notes of other Banks aforesaid, and a considerable * part of the aforesaid Bills and notes discounted set forth and contained or mentioned in Schedule A to this your orators bill of Complaint annexed amounting to one hundred and thirty two thousand seven hundred dollars and twenty five cents or thereabouts and some other property belonging to the said State Bank at Trenton to get into the hands and pofsefsion (possession) of Robert McNeely & David Johnston two of the said late Directors or in the hands and pofsefsion (possession) of some one or more of the said late surviving Directors.  That by collusion and connivance with the said late Directors or some of them the said Robert McNeely and David Johnston or one of them while they continued in office as aforesaid or afterwards or both got into their or his pofsefsion (possession) or under their or his controul (sp) all the said specie Bank notes of other Banks and bills and notes discounted last aforesaid and other monies notes funds and personal property to a large amount the particulars whereof are to your orators unknown, belonging or which then lately belonged to the said State Bank at Trenton and have appropriated or converted the same or some considerable part thereof to the use of the said late Directors or some of them or to their own use or to some other unlawful use or purpose-

                                                That in like manner some deed or deeds of conveyance has or have been made or pretended to be made for the real estate or some part thereof then or lately belonging to the said State Bank to the said Robert McNeely or to some one or more of the said late Directors who thereupon took pofsefsion (possession) * and received the rents and profits thereof all which pretended conveyances transfers or afsignments (assignments) of the said real and personal estate of the said State Bank your orators charge to be made xxx (malafide?) and without authority or consideration or both fraudulent breaches of trust and otherwise unlawful.

                                                                        And your orators further shew (show) that the Trenton Banking Company and Pierson Hunt their Cashier or one of them, without right or lawful authority got into their pofsefsion (possession) or under their controul (sp) part of the aforesaid bills and notes discounted set forth and contained or mentioned in schedule B to this your orators said bills annexed amounting to the sum of Forty seven thousand five hundred and nine dollars and twenty five cents or thereabouts and other bills and notes discounted & personal property to your orators unknown and converted or appropriated the same or some considerable part thereof to their use or the use of one of them or to some other illegal use or purpose; which Schedule to this your orators bill annexed marked A & B. your orators pray may be taken and accepted on part of their said bill.  That all or a considerable part of the said last mentioned bills and notes discounted and property was or were also obtained wholly or partly by the Trenton Banking Company aforesaid and by the said Pierson Hunt or one of them through dealings and negotiations with the said late Directors, Lambert Richey and John Davifson (Davisson) or some or one of them which destroyed the just rights of your orators and through fraudulent breaches of trust or acts of grofs (gross) negligence or both of which they the said Trenton Banking Company and Pierson Hunt or one of them had due notice committed permitted or suffered by the said late Directors Lambert Richey John Davifson (Davisson) or some or one of them.  That the Trenton Banking Company aforesaid and the said Pierson Hunt or one of * them had or has in their pofsefsion (possession) or under their controul (sp) one or more drafts or orders drawn by Lambert Richey the late Cashier of the said State Bank at Trenton on Charles Gordon or some other person or persons for sundry large sums of money amounting in the whole to the large sum of Thirty thousand dollars or thereabouts which sum had been represented by the said Pierson Hunt as much lefs (less), which checks or drafts or some of them had been presented for payment which was refused and no xxx (Protest?) or notice given thereof-  And for securing the payment of which said Checks or drafts The Trenton Banking Company and Pierson Hunt or on (one) of them at or about the time the said State Bank stopped payment as aforesaid held several Promifsory (Promissory) notes obligations or securities for money made or given by Lambert Richey John Anderson.  Anderson and Richey and John Davifson (Davisson) respectively and indorsed (sp) each for the other or some other notes or obligations or securities for money amounting in the whole to the sum of thirty thousand dollars or some other large amount all or some part of which said notes obligations or securities for money were secured wholly or partly by a mortgage given by the said John R. Smith on certain lands or real estate a particular description whereof your orators are unable to set forth for want of information or by some other mortgage or mortgages Which said last mentioned notes obligations securities for money and mortgage or mortgages was or were without right or authority given up by the Trenton Banking Company aforesaid and Pierson * Hunt or one of them to and received by the said Lambert Richey, John Anderson, Anderson & Richey, John R. Smith and John Davifson (Davisson) or some or one of them or some other person or persons with the intent and design to deprive your orators of the benefit thereof upon some agreement or understanding whereby or by means whereof The Trenton Banking Company aforesaid and the said Pierson Hunt or one of them got into their pofsefsion (possession) or under their controul (sp) as aforesaid the said last mentioned bills and notes discounted and property aforesaid of the said State Bank at Trenton and The Trenton Banking Company aforesaid and the said Pierson Hunt or one of them by reason of the dealings and transactions aforesaid or for some other reason to your Orators unknown were enabled to sell and did sell a large amount of the notes of the said State Bank at Trenton at a discount and afterwards while holding the property of the State Bank as aforesaid also purchased a large amount of the bank notes or Bank bills of the said State Bank at a large discount and by the said last mentioned purchase made or intended to make great or some gain or profit.

                                                And your orators further shew (show) that the said late Directors or some of them in violation of their duty as Directors as aforesaid did overdraw their accounts with the said State Bank from time to time and oftentimes intentionally or otherwise and thereby fraudulently or otherwise obtained the monies and funds of said Bank to a large amount that at the time the said Bank stopped payment as aforesaid several accounts of the said late Directors were * overdrawn in large sums of money that is to say the said Jasper S. Hill in the sum of twenty five thousand two hundred and forty three dollars and fifteen cents or thereabouts John Potts in the sum of seven hundred and nineteen dollars and eighty seven cents or thereabouts, John R. Smith in the sum of Five thousand seven hundred and seventy five dollars and eight cents or thereabouts Garret D. Wall in the sum of Three thousand one hundred and sixty three dollars and eighty seven cents or thereabouts, James T. Clark in the sum of Nine hundred and sixty nine dollars and four cents or thereabouts and Benjamin Fish in the sum of Two hundred dollars or thereabouts making in the whole the large sum of Thirty six thousand seventy one dollars and one cent or thereabouts that the said sums so overdrawn by the said last named late Directors respectively or a considerable part thereof were and are justly due to your orators-

                                                And your orators further shew (show) that the said Jasper S. Hill and John Davifson (Davisson) were often and at different times severally in the employ or service of the said late Directors for the purpose of circulating the Bank bills of the said State Bank and exchanging them for other Bank notes or for some such purpose that at or about the time the said Bank stopped payment as aforesaid and at one or more time or times previous thereto by or through the fraudulent breaches of trust of the said late Directors or some or one of them the said Jasper S. Hill and John Davifson (Davisson) or one of them got in to their pofsefsion (possession) or under * their controul (sp) large sums of money in the Bills of the said State Bank at Trenton or some other money or funds part or all of which is not charged to them or either of them in the books of the said Bank the amount whereof is to your orators unknown for the purposes aforesaid or some other purpose which they or one of them have mis-applied and converted to their or one of their own uses or some other unlawful purpose or purposes and for which they have never accounted-  And moreover the said John Davifson (Davisson) at or about that time did in like manner also overdraw his accounts with the said State Bank and received thereby divers (diverse?) large sums of money belonging to your orators amounting in all to the sum of forty two thousand seven hundred and fifty two dollars and fifty three cents or thereabouts-

                                                And your orators further shew (show) that Charles Gordon and James Tunney of the city of New York jointly or severally and for their joint or separated interest and account at or about the time the said Bank stopped payment as aforesaid and for some time previous thereto were in the service of and employ of the said late Directors as agents or receivers or both, and had various accounts and transaction which are unsettled and received large sums in the bank notes of the said State Bank at Trenton and in other monies funds drafts and securities for monies belonging to the said State Bank and made various payments to or for them, that the said James Tunney received as aforesaid from the said State Bank and on their account the sum of one hundred thousand dollars or some other large sum and the said Charles Gordon received as aforesaid from the said State Bank and on their account the sum of Eight hundred thousand dollars or some other large sum making in the whole Nine hundred thousand dollars or thereabouts a part of which said sums they refuse to credit to the said State Bank and other xxx (parts?) have been appropriated and converted by them jointly or severally to their own use or to the use of one of them – and other parts have been wasted or mis-applied in or by the fraudulent breaches of trust or grofs (gross) negligence of the said late Directors or some or one of them-

                                                * And your orators further shew (show) that the said Lambert Richey during the time he was Cashier as aforesaid did also overdraw his account with the said State Bank and thereby received of the monies of the said Bank and at or about the time the said Bank stopped payment as aforesaid his said account was overdrawn the large sum of Fourteen thousand four hundred and seventy four dollars and ninety cents or thereabouts.  That the said Lambert Richey then and at one or more times previous thereto through the fraudulent breaches of trust or grofs (gross) negligence or both of the said late Directors or some of them got into his pofsefsion (possession) or under his control and converted to his own use or to some other unlawful purpose and otherwise mis-applied or permitted or suffered to be mis-applied divers (diverse?) large sums of money in the bank-notes or bills of the said State Bank and in other monies funds and securities belonging to the said State Bank with which the said Lambert Richey has never been charged in the Books of the said Bank or in any manner accounted the amount and particulars whereof is to your orators unknown and the said Lambert Richey as Cashier as aforesaid or otherwise also got into pofsefsion (possession) or under his controul (sp) divers (diverse?) large sums of money and funds arising out of the property of Chambers and Thompson who were indebted to the said State Bank and for the payment whereof the said money and funds were received as last aforesaid by the said Lambert Richey and by him converted to his own use the amount whereof is also to your orators unknown-

                                                And your orators further shew (show) that besides the accounts overdrawn as aforesaid sundry other dealers with the said State Bank at Trenton did overdraw their respective accounts and thereby obtained sundry large sums of * money belonging to your orators amounting in the whole at the time the said bank stopped payment as aforesaid to the large sum of Forty two thousand five hundred and sixty seven dollars and eighty nine cents or thereabouts as by reference to the said accounts and Books of the said Bank will appear and to which for greater certainty your orators pray leave to refer that all or nearly all the said several sums obtained by accounts overdrawn as aforesaid was or were over and above all credits given or which ought to be given and was or were so obtained or gotten by or through the fraudulent breaches of trust or grofs (gross) negligence or both of the said late Directors or some of them or after being informed thereof they acquiesced therein.-

                                                And your orators further shew (show) that the said late Directors of the said State Bank Lambert Richey John Davifson (Davisson) James Tunney Charles Gordon  The Trenton Banking Company and Pierson Hunt or some or one of them have made great or some gains or profit out of the Promifsory (Promissory) notes Bank-notes and bills monies funds and other property of the said State Bank or some part thereof obtained as aforesaid or in some such manner and your orators by themselves and others in xxx (pursuance?) of one or more resolves or otherwise have frequently and in a friendly manner applied to them respectively or to some of them to come to a just and fair account with your orators concerning the Premises and your orators well hoped they would have complied with such reasonable requests as in justice * and equity they ought to have done.-.-.-

                                                But now so it is may it please your Excellency that the said ^Abner Reeder Robert McNeely, Abner Reeder (2^nd Abner Reeder crossed out) James T. Clark, Benjamin Fish Jasper S. Hill, David Johnston Francis S. Labaw, Stephen Clark Evan Evans John Potts John R. Smith and Garret D. Wall survivors of the said John Bernard late directors Lambert Richey “The Trenton Banking Company” Pierson Hunt John Davifson (Davisson) Charles Gordon and James Tunney combining and confederating together and to and with divers (diverse?) other persons to your orators at present unknown but whose names when discovered your orators pray may be inserted herein and they made parties hereto with proper and apt words to charge them how to xxx (how? have?) to injure aggrieve and defraud your orators in the Premises the said confederates or some of them pretend and particularly the said surviving directors pretend that they have not and had not in their pofsefsion (possession) or under their controul (sp) all the property aforesaid of the said State Bank at Trenton in manner aforesaid or in any other manner that they are not and have not been guilty of or committed any fraudulent breaches of trust in the manner herein before stated and set forth, or in any other manner and are not liable to your orators or chargeable for all or any of the property of the said State Bank at Trenton whereas your orators charge that all or some considerable parts of the property real and personal aforesaid belonging or which did belong to your orators at or about the time the said Bank stopped payment as aforesaid except the said sum of sixteen dollars and eighty cents was in the * pofsefsion (possession) or under the controul (sp) of the said late Directors or some of them and has been mis-applied and converted to the private uses and purposes of the said late Directors in the manner herein before set forth or in some other manner and that they are liable and accountable to your orators for the same-

                        And the said late surviving Directors or some of them at other times admit that they received the said bills and notes discounted herein before mentioned or referred to in that respect and are ready and willing to account for the same but then they pretend they ought not to be charged with several of the said bills and notes for that the Drawers acceptors and Indorsers (sp) of many or some of the said bills and notes are insolvent  Whereas your orators charge that many of the said bills and notes from Citizens of this State were discounted by the said late Directors without two responsible names the drawer and indorser (sp) and other bills and notes from Citizens of other States were discounted as aforesaid without three responsible names the drawer and two indorsers (sp) in violation of and contrary to the Bye-laws rules and regulations or some or one of them aforesaid and you orators further charge that the money due from several of the said insolvent drawers and Indorsers might have been collected in case reasonable care and diligence had been used by the said late Directors but, which money they grofsly (grossly) neglected to collect and the said confederates or some of them also * pretend and particularly the said late surviving Directors pretend that they or some of them had entered into and were personally bound to individuals or bodies corporate in several or some engagements and contracts for money borrowed or otherwise for the use of the said State Bank to aid them and enable them to pay their bills notes and other demands on them which otherwise they were unable to pay that the said State Bank was under the necefsity (necessity) of borrowing money to fulfil (sp) their engagements and could not borrow upon their own credit without giving the personal security of the said Directors.  That having as Directors discharged their duty faithfully they ought to be indemnified and first paid that they had a right to resolve and accordingly on or about the time the said Bank stopped payment as aforesaid did resolve that the Cashier be directed to place in the hands of Robert McNeely and David Johnston such amount of notes due that bank and transfer such real estate as would amount to satisfying the debts due to individuals which they became indebted to for and on account of the said Bank or to that effect, and that in consequence of that or some other resolve the specie Bank notes of other Banks and part of the bills and notes discounted as aforesaid, and the said real estate were placed in the hands and pofsefsion (possession) of the said Robert McNeely and David Johnston for the purpose in the said resolve mentioned.  Whereas your orators * charge that if the said late Directors have become bound for your orators it was without their request or direction that no such resolve was lawfully pafsed (passed) or made by the said Directors,  that if however any such resolve is entered in their minutes and proceeding, the same is illegal and void.  That they had no right to be first paid and to pafs (pass) the said resolve or any other to appropriate the funds monies or securities of the said Bank to or for their own exclusive indemnity or security for debts contracted by them on account of the said Bank in manner aforesaid or in any such manner.  That such resolve was devised and contrived to defraud the creditors of the said State Bank and is void by the statute in such case made and provided.  That the said resolve is a preference of one Creditor over the other or whereby one or more shall be first paid or have a greater proportion in respect to his or their claim than another and is void by the statute in such case made and provided.  That the said resolve is a fraudulent breach of Trust in the said late Directors who at the time they received the said corporate property of the said State Bank and held the same and pafsed (passed) the said resolve were Trustees for your orators and could acquire no interest to their own use or transfer any right in the said property – by the said resolve or any such fraudulent breach of said Trust that the necefsities (necessities) of the said Bank to borrow money and raise funds * to meet their engagements arose wholly or chiefly from the grofs (gross) negligence or bad management or both of the said late Directors and by reason thereof the said State Bank was also injured in its credit and unable to borrow money without security to answer their said necefsities (necessities).  That the monies and funds or some part thereof borrowed by the said late Directors for the said State Bank was or were borrowed upon a rate of interest exceeding six per cent per annum upon extravagant premises usurious loans and illegal contracts and large commifsions (commissions) paid or allowed to Brokers and agents for negotiating the same-  That the said late Directors permitted or suffered sundry persons dealing and having accounts with the said State Bank from time to time and oftentimes to ^over draw their said account as aforesaid and thereby to receive large sums of money in the notes of the said Bank without paying any discount therefor (sp) and without furnishing the said Bank with the means of paying the said notes, that such practices were known to the said late Directors or some of them or could and ought to have been known to all of them upon an examination of the accounts of the said Bank which it was their duty to do and which they for a long time neglected to do.  That the said late Directors grofsly (grossly) neglected in violation of the rules and regulations aforesaid or * some or one of them to hold quarterly meetings at one or more quarterly meetings of the board (written verbatim), or when the same ought to be held to appoint three of the board of Directors to examine the monies in the vault of the said State Bank and compare the same with the account exhibited by the Cashier or to obtain any report reports thereof.  And the said late Directors also grofsly (grossly) neglected to examine or cause to be examined the cash and accounts of the State Bank as it was their duty to do and moreover kept imperfect or no certain or accurate account of the Bank-notes, post-notes, and bills of the said State Bank ifsued (issued) or in circulation and were unable to state within many thousand dollars the amount thereof- that they resorted to, adopted or approved uselefs (useless) and ruinous practice of attempting to circulate and force into circulation the Bank-notes and bills of the said State Bank beyond what could be redeemed or kept in circulation in the fair and regular course of businefs (business) and moreover sold or caused or permitted to be sold the Bank notes, Bank-bills and Post-notes of the said State Bank to a large amount at a great or some discount or lofs (loss).  That the amount of the notes of said Bank in circulation and the employment of unnecefsary (unnecessary) agents and persons as aforesaid to circulate and exchange * their said notes the means used for so doing and the expedients resorted to by the said late Directors and their agents to borrow money and raise funds for the said Bank and the unsatisfactory manner the engagements of the said late Directors were fulfilled contributed to impair and destroy the confidence of the public and particularly the creditors of the said Bank in its means and ability to pay their demands, that frequent xxx or demands had been made on the said Bank for the payment of their notes in specie, or in other bank notes, notwithstanding which the said Directors took no effectual measures to relieve the embarrafsments (embarrassments) of the said Bank, but continued their fraudulent breaches of Trust, grofs (gross) negligence and bad  management until the said Bank stopped payment as aforesaid and they were removed from their said offices of Directors aforesaid-

                        And the said Confederates or some of them also pretend and particularly The Trenton Banking Company and Pierson Hunt pretend that they had large demands against the State Bank at Trenton for their notes and drafts remaining unpaid and which had accumulated to a large amount in the fair and regular course of businefs (business) by indulgence without security to serve the said State Bank in their difficulties and without any gain or profit.  That before the said demands had * accumulated as aforesaid they had no notice or any reason to believe that the said State Bank was in failing circumstances, or that the said late Directors of that Bank or their Cashier or agents aforesaid had committed or were committing any fraudulent breaches of Trust, that it was lawful for the said late Directors to prefer one Creditor before another and that they fairly and lawfully received the discounted notes and other property herein before stated and referred to as security for their said demands, that they had neither sold or purchased any of the notes of the said State Bank, or if they had done so your orators had no right to complain concerning it, and that after they received the said discounted notes and property the said late Directors of said State Bank pafsed (passed) some resolve partly approving thereof or made some such pretences whereas your orators charge that the said demands of the Trenton Banking Company aforesaid and Pierson Hunt or one of them arose wholly or partly from large amounts of the Bank notes of the said State Bank received from the said John Davifson (Davisson) and Lambert Richey or one of them and from other dealings and transactions with them, or one of them upon some collusion or agreement or understanding or otherwise whereby the debts and liabilities to a large amount of the said John Davifson (Davisson) and Lambert Richey or one of them to the Trenton Banking * Company aforesaid and the said Pierson Hunt or one of them were materially lefsened (lessened) and thrown or placed upon the said State Bank.  That The Trenton Banking Company aforesaid and the said Pierson ^ Hunt or one of them had often and for some considerable time before the said State Bank stopped payment as aforesaid refused to receive the notes of the State Bank from many persons and dealers offering the same and doubted or suspected the solvency of the State Bank and therefore or for some other such reasons required and obtained as security the Promifsory (Promissory) notes obligations Securities and mortgages given up as aforesaid and also knew or had reason to believe, or might have known that the said late Directors of the said State Bank and Lambert Richey Cashier at or about the time the said Bank stopped payment as aforesaid or before had been and were as such Directors and Cashier committing fraudulent breaches of Trust and acts of grofs (gross) negligence amounting thereto in some of which the said John Davifson (Davisson) had been xxx partaking as aforesaid.  That The Trenton Banking Company aforesaid, and the said Pierson Hunt or one of them without lawful authority or thro’ fraudulent breaches of Trust got into their pofsefsion (possession) or under their controul (sp) in the manner herein before set forth, or in some such way, the discounted notes and property of the said State Bank and converted the same or some part thereof into money and therewith * or while they had the same as aforesaid at a large or some discount purchased for gain or profit the Bank-notes of the said State Bank.  That there is no such last mentioned resolve legally pafsed (passed) and entered in the minutes of the said late Directors, but if there is such a resolve the same is a fraudulent breach of Trust and is void for the same or similar reasons alleged against the other resolve aforesaid relating to the notes and property of the said Bank-  And the said late surviving Directors The Trenton Banking Company and Pierson Hunt or some of them pretend that they ought not to account for or be charged with several of the said bills and notes discounted which have been received by them as aforesaid, the drawers or endorsers or both being discharged therefrom for that the payment of the said bills and notes were not duly demanded nor due notice given of – the non-payment thereof – and payment of several of the said bills and notes cannot be obtained.  Whereas your orators charge, that if any such cases exist no credit or allowance ought to be made therefore, to the said last named confederates in as much as it was and is owing to their neglect default fraudulent breaches of Trust or other illegal conduct-

                        And the said confederates or some of them and particularly the said James Tunney and Charles Gordon pretend that they acted as agents or brokers in the city of New York for the said late Directors * and credited all the monies and funds received after deducting reasonable charges and commifsions (commissions) and made no other gain or profit thereby that as such Brokers and Agents they also aided and afsifsted (assissted) (sp) in raising funds and borrowing money for the said State Bank and was or were in no way concerned, or aiding or afsisting (assisting) in usurious loans, or illegal contracts or in any fraudulent breaches of trust, by the said late Directors or their Cashier and had no notice or reason to believe the said State Bank was insolvent or in failing circumstances.  Whereas your orators charge that large amounts of monies and funds of the said State Bank were sent to and received by the said Charles Gordon and James Tunney, or one of them and not credited by either of them.  That they or one of them made unreasonable charges and exacted large commifsions (commissions) and also made great or some gains out of the monies and funds in their hands belonging to the said State Bank, also aided and afsifted (assisted) in making usurious loans and borrowing money upon disadvantageous or illegal contracts.  That they sold the Post notes Bank notes and (and crossed out) or bills of the said State Bank at a great or some lofs (loss) or discount-  That on or about the seventh day of May in the year of our Lord eighteen Hundred and twenty five the sum of eighteen thousand five hundred dollars or thereabouts belonging to your orators, in the notes of the said State Bank were sold by them or one of them at * a lofs  (loss) of six thousand eight hundred and forty six dollars and sixty seven cents or thereabouts a part whereof to wit the sum of Five thousand dollars was sold at a discount or lofs (loss) of fifty per cent and that at and before that time they knew or had reason to believe the said State Bank was insolvent, or in failing circumstances and that the said late Directors and Cashier or some of them as such were committing fraudulent breaches of Trust.  that the said Charles Gordon and James Tunney or one of them in manner aforesaid or otherwise aided or afsisted (assisted) in the said fraudulent breaches of trust or some others of the like nature.  And the said Confederates or some of them and particularly the said Robert McNeely David Johnston The Trenton Banking Company and Pierson Hunt pretend that only small or inconsiderable sums of money have been paid upon the bills and notes discounted and by them respectively received as aforesaid-  That many of the said bills and notes remain unpaid, and that they are ready and willing to account for said money and give up the said notes upon xxx (having? hearing?) their demands allowed.  Whereas your orators charge that large sums of money have been received for principal and interest or might have been received without their neglect or default that some of the said bills and notes have been prosecuted and others transferred to some other person or persons and that if any just claims they have they ought to seek for * payment in common with the other Creditors of the said State Bank, or be postponed.

                        And some of the said Confederates also pretend that all or some of their accounts and transactions herein before stated set forth or referred to have been wholly or partly settled and finally closed with the said late Directors during their continuance in office and offsets were allowed large payments made in the notes of the said State Bank which were received and credited at their par value, as was lawful and right and in cases where ballances (sp) still appear due they have paid or are ready to pay in the notes of the said State Bank the whole or some part thereof-  Whereas your orators charge and insist that the said pretended settlements if any were made the better to conceal and confirm the fraudulent transactions and breaches of Trust aforesaid or some of them, and are of no binding force or authority – that for or against the fraudulent transactions and breaches of Trust aforesaid, no offsets ought to be allowed nor any credit given for the notes of the said State Bank or if any such credit has been or should be given it ought to be for such sums only as was actually paid for the said Bank-notes all or some of which have been purchased at a large or some discount.-.-

                                    And the said confederates or some of them also pretend that the matters and things herein before stated and charged against them are erroneous and untrue in many or some particulars  Whereas your orators charge and insist that the said matters and things or the most material parts thereof herein before stated and charged against the said confederates are true-  All which actings and doings of the said Confederates are contrary to equity and good conscience and  ^ tend to the manifest wrong and injury of your orators.-.-

                                                In tender consideration whereof and for as much as your orators are remedilefs (remediless) in the Premises at and by the strict rules of the Common Law and can have no adequate relief save only in this Honorable Court where fraudulent transactions breaches of Trust matter of account and of this nature are properly xxx and relievable.-

                                    To the end therefore that the said Abner Reeder, Robert McNeely James T. Clark, Benjamin Fish, Jasper S. Hill, David Johnston Francis S. Labaw Stephen Clark Evan Evans, John Potts, John R. Smith Garret D. Wall, John Davifson (Davisson), Charles Gordon James Tunney and Pierson Hunt may upon their several and respective corporal oaths and the ‘Banking Company” may under their common xxx (feal?) and their and each of their confederates when discovered may full true and perfect answer make to all and singular the Premises as fully and particularly as if the same were here again repeated and they and each of them particularly interrogated thereto paragraph by paragraph with dates sums and all * attending circumstances and incidental transactions according to the best of his and their respective knowledge information remembrance and belief.  And that the said Abner Reeder Robert McNeely James T. Clark Benjamin Fish Jasper S. Hill, David Johnston Francis S. Labaw, Stephen Clark, Evan Evans, John Potts John R. Smith, and Garret D. Wall and their confederates and each and every of them may be decreed to come to a just and fair account and make satisfaction for the bills and notes discounted monies funds and property both real and personal aforesaid belonging or which did belong to the said State Bank at Trenton at or about the time the said Bank stopped payment as aforesaid or before or after that time which was or were in their pofsefsion (possession) or under their controul (sp) of their or either of them except the sum of sixteen dollars and eighty cents received by your orators as aforesaid.  That they may deliver to your orators the said Book of minutes and proceedings, and all the other books and papers of the said State Bank withheld as aforesaid and that the afsignments (assignments) transfers and conveyances for all and every part of the said bills and notes discounted monies funds and property to any or either of the Defendants may be declared fraudulent null and void.  “That The Trenton Banking Company aforesaid and the said Pierson Hunt or one of them may be decreed to account and make satisfaction for all the * bills and notes discounted and property contained in the Schedule marked B and for all other property unlawfully received at the time or times last aforesaid.  That the several sums due upon the accounts overdrawn as aforesaid by some of the late Directors and by Lambert Richey and John Davifson (Davisson) may be decreed to be paid by them according to their respective liabilities-  That the said Lambert Richey, Jasper S. Hill, John Davifson (Davisson) Charles Gordon and James Tunney may account and make satisfaction for the several sums of money and funds belonging to the said State Bank by either of them received, which has not been charged or credited as aforesaid and that their respective accounts may be finally settled and paid under the order and direction of this Court.  That each and every of the said Confederates may account for all the interest rents gains and profits made by them respectively as aforesaid or that the defendants hereto may account and be charged and make satisfaction according to their respective liabilities and as this Court may see fit to direct.  That all the monies funds and property of the said State Bank at Trenton in question in this suit may be under the direction and controul (sp) of this Court and be paid to your orators or a receiver to be appointed if necefsary (necessary) after deducting all costs charges and expenses or otherwise as this Court may direct.-  That writs of xxx and Injunction may ifsue (issue) as occasion * may require and that your orators may have such further and other relief in the Premises as the nature of their case may require and shall be agreeable to Equity and good conscience.-.-

                                    May it please your Excellency the Premises considered to grant unto your Orators a Writ or Writs of Subpoena ifsuing (issuing) out of and under the seal of this Honorable Court to be directed to the said Abner Reeder, Robert McNeely James T. Clark, Benjamin Fish, Jasper S. Hill, David Johnston Francis S. Labaw, Stephen Clark, Evan Evans John Potts John R. Smith, Garret D. Wall John Davifson (Davisson) Charles Gordon, James Tunney Pierson Hunt and the Trenton Banking Company therein and thereby commanding them and each of them on a certain day and under a certain xxx therein to be inserted to be and appear before your Excellency in this Honorable Court then and there to answer all and singular the Premises and to stand to perform abide by and fulfill such order and decree therein as to your Excellency may  seem meet and shall be agreeable to Equity and good conscience.-

And your orators will ever pray & c- (seems to be used as etcetera)

Theo Frelinghuysen

xxx & of  Counsel

for the Complts (Complainants)

                                                                    

*page 36          *The Schedule annexed to the foregoing bill of Complaint and therein

                        referred to:-

                                                                        (A)

Drawers-                      Indorsers (sp)-             When due                     Amount-

John Abron (?)             “                       June     17, 1825          $180.00

Thomas Atkinson                      “                       July      9^th “                  84.40

Jacob Anderson                       “                                   7^th “                  200. “

A. P. Atkinson                          “                                   4^th “                  100.”

James Anderson                       “                                   7^th                    175.”

Andrew Allison                                     May     1^st                    107.54

John Anderson             “                       June     10^th                  550.”

James Anderson                       “                       Aug.     18^th                  150.”

Isaac Bamest (?) Wm. J. Brown- Joseph t. Thomson            Sept.    1^st 1817           500.”

L. & J. Buster                           “                       May     28^th 1825         525.55

Samuel Brittain             “                                   25^th                  200.”

Sarah Barnes                            “                       July      30^th                  678.”

Asa Belden                               “                                   20^th                  50.”

John Buchman                          “                       June     27^th                  13.”

Thomas Butcher                       “                                   2^nd                    61.79

David Bartive                           “                                   20^th                  100.”

James Brisdell (?)                     “                                   7^th                    281.38

William Butcher                        “                                   1^st                    100.”

H. Bostwick                             “                                   2^nd                    375.”

Daniel Baker                            “                       July      8^th                    40.”

David Bartive                           “                                   24^th                  750.”

Samuel Brittain             “                       June     27^th                  250.”

Asa Belden                               “                       July      1^st                    30.”

Richard L. Beattie (Beatty)     “                        Aug.     7^th                    145.”

John C. Bellevjeau                    “                                   5^th                    60.”

Drawers-                      Indorsers (sp)-             When due                     Amount-

Charles Burke                          “                                   17^th                  $18.”

Wm. Brittill                   John R. Smith               May     9^th1823            30.24

John Bernard                Check on Phila.            April     13^th1823          200.”

Asa Belden                   Sam. R. Hamilton         May     20^th                  150.”

Robert Bethell              Do (Ditto)                    April     21^st                  200.”

Joseph Bullock Lambert Richey                        19^th                  100.”

John T. Blackwell         Cashier             Sept. 15^th1821             100.”

Asa Belden                   J. R. Smith                    July 2^nd1825                 80.”

David Bellevjeau           G. D. Wall                    April 8^th1823                50.”

Charles Bonnell            Check on Easton Bank            May 1^st                        242.62

Richard L. Beatty         John Anderson Aug 30^th                       110.”

Ditto                             David McKean “ “ “                              240.”

John a Brittain                           “                       Dec. 18^th1823              250.”

George F. Bunce (?)     D. G. Barton (Bartow?)          Aug. 5^th                        400.”

                                                and others

Edward S. Bellamy       John Davifson               March 28^th                   300.”

Samuel T. Bellevjeau    Dan‘l Bellevjeau           July 30^th                       55.”

John Buchman              P. Hunt Cashier & others      June 6^th                        100.”

Daniel Baker                G. D. Wall                         “                              275.”

Nath. Brittain                J. C. Chambers            Feb’y 22^nd                    150.”

Joseph M. Bispham (?)          J. C. Chambers                        14^th1823          100.”

Wm. J. Brown              Sarah & Isaac Barnes   Sept1st 1817                500.”

Joseph Bullock John Bernard                Dec. 29^th                      200.”

Thos. Croxall (?)          Wall & Danbury           Aug 24^th 1815              150.”

Thomas Capner            May 1^{st (verbatim)} May 18^th 1825             100.”

Daniel Coleman                        “                                   24^th                  28.34

Charles Cain                             “                       June 21^st                       11.”

J. W. Coryell (?)                       “                                   3^rd                    200.”

David Cole                               “                                   17^th                  65.”

John Cavenagh             “                                   4^th                    300.”

Henry Clymer                           “                                   14^th                  60.”

James Cook                             “                       Aug.     3^rd                    650.”

Aug’ts Carroll Ag’t                 David McKean May 4^th 1821   75.”

Ditto                             George Holcombe        Nov. 11^th 1820            80.”

John Cavenagh                                     May 22^nd 1825             74.64

James Cromeline          Stephen Blackwell        Jan’y 8^th 1824              957.41

Abiel (?) L. Carroll       Sam C. Newell Dec. 10^th 1819             100.”

Augustus Carroll           Cashier             April 15^th 1822 2000.”

Richard Coxe               C. D. Coxe                              “                       1000.”

John C. Chambers        L. Richey                                  “                       1000.”

Peter J. Clark               Check                          April 10^th 1825 50.”

Daniel Coleman            D. Johnston                  May 11^th                      76.”

Tho’s.  Cunningham      President                      Aug’t 23^rd                     104.37

John H. Cooper            J. Davifson                   Oct. 3^rd            1821               285.”

Wm. Clofson (Closson)    T. R. Smith                   July 18^th 1820              140.”

Ditto                             Richard Imlay               April `5^th 1819             72.61

Drawers-                      Indorsers (sp)-             When due                     Amount-

Thomas Croxall            Francis Danbury           Oct. 12^th 1816             $100.”

Wm. Croxall & Wm. Griffith-Shippen & McChurtice (?)      Feb’y 8^th 1817             5000.”

Thomas Croxall            G. D. Wall                    June 9^th 1823               150.”

Ditto                             Ralph Hunt                   May 30^th 1819             134.02

George Dill                               “                                26^th 1825            100.”

Jeremiah Dinell             “                       June 20^th                      209.62

J. Dickinson                              “                       June 10^th                      52.18

John Dugdale                                                                12^th                  63.73

Ditto                                                                             12^th                  62.56

John Dickinson                                                 27^th                  100.”

Joseph M. Downing                                                      13^th                  200.”

John Davifson                                                               27^th                  107.80

Ditto                                                                 July 11^th                       90.40

Ditto                                                                             12^th                  83.55

Ditto                                                                             6^th                    108.06

Ditto                                                                             19^th                  104.70

Ditto                                                                             1^st                    100.00

Ditto                                                                             10^th                  90.40

Ditto                                                                             1^st                    500.00

Ditto                                                                             4^th                    107.40

Ditto                                                                 August 21^st                   581.00

Ditto                                                                 Oct. 7^th                                    200.00

Ditto                                                                             11^th                  600.00

Ditto                                                                 Sept. 21^st                     450.00

James Davifson             John L. McKnight         Oct. 8^th  1820              109.00

Barent (Barnt) De Klyne      Stephen Blackwell        May 4^th 1822               204.75

George Dill                                                                   20^th 1825         900.00

Barent De Klyne           G. D. Wall                    Nov. 7^th 1816              200.00

Ditto                             Thomas Grant               Oct. 23^rd                      800.00

Ditto                             James T. Clark Nov. 22^nd                     150.00

Samuel Disbrow           Charles Carson July 4^th 1821                400.00

John Davifson                                                   May 27^th                      70.00

Ditto                             5 Checks on the Trenton Bank}                        745.74

Thomas Drake              Daniel Drake                Jan’y 30^th 1825            300.00

Isaac Evans                                                      May 31^st                      45.38

Evan Evans                                                       June 24^th                      790.00

Rebecca Ely                                                     July 15^th                       100.00

John C. Ely                                                       do (ditto) 15^th              150.00

Daniel Fenton               D. Johnston & Co.                                           100.00

Aron (Aaron) Furman                                      June 5^th                        100.00

Benjamin Fish                                                   July 6^th                         312.54

Peter Forman                                                   July 31^st 1825               480.00

Benjamin Fish               2 Checks                      June 21^st 1824              790.00

Henry Gulic (Gulick)                                        Aug. 24^th 1825             221.61

G. P. Glentworth                                              May 18^th                      160.00

Drawers-                      Indorsers (sp)-             When due                     Amount-

Wm. Griffith                 James McIlvaine (sp?)                          $900.00

Charles Gordon            T. Gordon                    Dec. 17^th 1821             2000.00

G. P. Glentworth                                              June 25^th 1825             260.62

Wm. Garrison                                                               15^th                  300.00

Robert Gibson                                                  July 5^th                         300.00

Isaac Gulic                                                       June 10^th                      50.00

G. P. Glentworth                                              May 15^th                      185.00

William Gordon                                                            18^th                  300.00

James Heard                On Acc’t of                                                      50.00

Jasper S. Hill                                                    May 21^st                      291.51

John Hart                                                         June 14^th                      200.00

Benjamin Hayden Jun.                          May 19^th                      1100.00

Jacob Herbert                                                  June 18^th                      125.00

John D. Hisler                                                               21^st                  100.00

Jacob Hester                                                                24^th                  25.00

John Haley                                                                   10^th                  200.00

Oliver Hunt                                                       July 31^st                        800.00

Wm. Halsted Jun.                                                         9th                   150.00

John Hamilton               J. V. Smith                   Oct. 25^th 1823             978.00

Jacob Herbert              Timothy Corlies            July 3^rd 1823               132.48

N. P. Hanaly                John Hanaly                  Feb 16^th 1814              300.00

Ditto                             Ditto                             May 4^th                        300.00

John R. Hamilton          S. R. Hamilton          13^th 1817             140.00

John Hamilton               Edw’d Yard                 July 15^th 1821              106.08

George W. Halsted                                           Feb 16^th 1825              160.00

Joseph Hulme (?)                                              Aug. 22 1821               126.64

Benj’n Hutchinson        Joh’a Wright                 Nov. 16^th 1814                        69.00

Asher R. Hart               James F. Rock             Dec. 16^th 1822             50.00

J. D. Hutchinson                                               June 12^th 1825             87.50

J. Hendrickson                                                 July 10^th                       48.12

Bedford Jobs                                                    June 17^th                      130.00

Stephen Johnes                                     June 3^rd 1825               300.00

Bedford Jobs                                                                                        62.62

M. R. Ivins                                                       July 1^st                          50.00

Joshua A. Jones            J. R. Smith                    Dec. 14^th 1824             18.00

Joseph Jackson                                                                                    71.00

Bedford Jobs                Dft. on F. Smith & co. Nov. 18^th                      50.00

Joseph Imlay                Jos. Olden                    March 12^th 1817          350.00

Joseph Kirkbridge        Joh’a Hutchinson          May 21^st 1818             600.00

(Kirkbride?)

Barent D. Lalor                                                June 5^th 1825               80.00

(Barnt?)

Robert Letson                                                              24^th                  100.00

B. Lewis                                                           July 25^th                       70.00

Benjamin Lord                                                  1^st                    200.00

Drawers-                      Indorsers (sp)-             When due                     Amount-

J. W. Scott                                                                   1^st                    $200.00

A. Lambert                                                       Aug. 15^th                      167.47

Do (Ditto)                                                        Oct. 15^th                      167.47

John Lafaucherie                                               April 12^th                      45.00

Ditto                                                                             27^th                  169.43

Aaron Lambert                                                                         156.55

Lewis Lamand                                                                                      18.00

John Lafaucherie                                               July 1^st 1826                 96.00

Ditto                                                                 Jan 31^st                        33.11

Ditto                                                                 May 1^st                        45.17

Ditto                                                                 Dec. 17^th                      25.00

Thomas Langstroth (sp?)                                  Jan. 31^st 1825              500.00

Samuel Lenox               David Furman               April 14^th                      120.00

John Longstreth            John M. Milnor May 15^th 1819             400.00

Ditto                             Ditto                             Aug. 4^th                        700.00

Ditto                             L. Richey                                  9^th                    1000.00

John Lafaucherie                                                                                   58.00

Moore Brown & Lake  -William Roberson        Aug. 15^th 1816             50.00

Moore & Lake             Ditto                             Oct. 24^th 1824             200.00

John Mark                                                        May 27^th 1825             150.00

Robert McNeely & son                                                                        600.00

Alex. T. Moore                                                June 26^th                      50.00

Thomas Miles                                                               5^th                    75.00

C. G. McChesney                                                        3^rd                    300.00

F. Mahan                                                                     5^th                    200.00

Gershom Mott                                                              10^th                  120.00

Thomas Miles                                                               7^th                    150.00

Francis Mahan                                                  July 10^th                       145.00

Alex. T. Moore                                                July 20^th 1825              290.00

William McKnight                                                         1^st                    1100.00

Robert McNeely & son                                                1^st                    100.00

Joseph McChesney                                          Aug. 26^th                      430.00

John Milledge               John R. Smith               Sept. 23^rd 1822            50.00

Ditto                             Ditto                             Nov. 21^st                      50.00

Alex. T. Moore                                                May 21^st                      290.00

Joseph McChesney                                                                              430.00

Thomas Miles                                                                                       125.00

Isaac Merrain                                       Aug’t 13^th 1823            50.00

Robert McNeely          A. M. McNeely            July 22^nd 1825              1429.02

Edward McIlvaine (?)- P. Forman                                15^th 1821         200.00

John Manners               Cashier             Feb’y 26^th 1824           250.00

Gershom Mott              George Watson            Nov’r 27^th                    150.00

Musgrove V. Phillips                                         June 15^th 1825             300.00

James L. Manners        Abraham R. Suthen      April 7^th                        175.00

Moore & Brown & Lake-William Robinson      Aug. 15 1816               200.00

Drawers-                      Indorsers (sp)-             When due                     Amount-

John Noble                                                       July 31^st 1825               $135.00

Joseph Olden               Cashier             Aug. 26^th 1824             2000.00

Ditto                             E. S. McIlvaine June 5^th 1823               100.00

Ditto                             J. Richey Jun.               July 11^th 1824              50.00

A. W. Phillips               May 30^th 1825 (copied exactly)                       80.00

William Paff                                                      May 30^th 1825             400.00

William T. Purdy                                               June 29^th                      500.00

Daniel Philips                                                                3^rd                    400.00

Andrew M. Prevost                                          June 1^st             250.00

John Prall jun.               William L. Prall                                     100.00

Andrew M. Prevost                                          June 1^st             250.00

William Pearson                                                Aug’t 14^th                     17.00

John Philips                  Wm. Vanhart & J. R. Smith                28^th 1824         50.00

Nathan P.                     G. D. Wall                    June 23^rd                      100.00

R. H. M. Prevost                                                                                  200.00

Robert T. Purdy                                                                                   300.00

A. W. Philips                                                                                        80.00

Daniel Philips                                                                                        330.30

William Potts                                                                                        451.00

Joseph W. Philips         James H. Imlay July 5^th 1818                200.00

John W. Pearson          B. South                       Nov. 24^th 1826                        100.00

Joseph Potts                                                     March 26^th 1821          10.00

Joseph Phillips  Lewis Gordon              Aug. 3^rd 1815               150.00

William Pearson            Amos Hutchinson         Oct. 22^nd 1822             155.00

Asher Quigley                                                   June 13^th 1825             300.00

Ditto                                                                             2^nd                    200.00

Thomas Reding (sp?)    George Holcombe        July 28^th 1814              171.00

Geo. & John Rozell                                          June 17^th 1825             75.00

C. Redon                     P. S. Schenck                           18^th                  150.00

Andrew Rowen                                                July 9^th                         80.00

Lambert Richey            John Anderson April 25^th                      1800.00

Pearson Reading           John C. Moore             Aug. 25^th                      100.00

T. Renshaw                  J. Bernard                                                        750.00

Geo & John Rozell                                                                               81.00

Joseph W. Recklefs      Wm. McKnight            April 21^st 1821 290.00

(Reckless)

Geo. & John Rozell      Ellett Tucker                                                     305.00

Thomas Ryall                Cashier                                                 100.00

Lambert Richey            Evan Evans                                                       800.00

Ditto                             John Anderson                                     500.00

Ditto                             Ditto                                                                 500.00

Ditto                             Cashier                                                 1500.00

Joseph W. Rogers                                            Sept. 25^th 1824            38.00

Geo.  & John Rozell     L. Richey                      Jan. 20^th 1821              81.00

Zac. Rozell                   J. Olden jun.                 Feb. 10^th 1818             300.00

Drawers-                      Indorsers (sp)-             When due                     Amount-

John Richey jun.                                                                                   $1000.00

Peter Smich (?) Robert McNeely          May 20^th 1825             2000.00

J. R. Smith                                                                    30^th                  1425.00

Peter Smich                                                                                          50.00

John R. Savage                                                 24^th                  400.00

John R. Smith                                                               30^th                  850.00

E. Snowden                                                                  24^th                  160.00

L. H. Stockton                                                             27^th                  200.00

John R. Savage                                                 6^th                    250.00

J. H. Scattergood                                                         29^th                  63.10

John R. Smith                                                               27^th                  700.00

John Smith                                                                                            300.00

Sam. & T. J. Stryker                                                    19^th                  62.87

Scudder V. Reeder                                                       4^th                    460.00

John B. Sartori                                                 10^th                  50.00

John M. Simmons                                                         6^th                    50.00

L. H. Stockton                                                             3^rd                    200.00

Ralph H. Shreve                                               June 7^th 1825               50.00

James Slack                                                                 3^rd                    275.00

Joseph Smith                                                                4^th                    70.00

John B. Sartori                                                 31^st                  855.39

Thomas C. Sterling                                           July 1^st                          77.00

John H. Scudder                                                           1^st                    250.00

John R. Smith                                                                                       100.00

Ditto                                                                                                     1800.00

Ditto                                                                 May 19^th 1823             125.00

Nat. Smith & Wm. Danbury                                                                 400.00

John B. Sartori John Titus                     April 17^th 1823 200.00

Charles Smith                                                                                       200.00

John R. Smith                                                   May 20^th 1825             375.00

Ditto                                                                                                     700.00

Thomas Stout               George Dill                   June 3^rd 1823               68.00

Thomas C. Sterling       L. Fagioli                      Nov. 8^th 1824              100.00

Ditto                                                                                                     300.00

Ditto                                                                                                     385.00

Ditto                                                                                                     400.00

Ditto                             Checks                         March 23^rd 1828          960.00

Hugh xxx                      G. D. Wall                                                        400.00

Peter S. Schenck          Richard Hunt                Oct. 16^th 1824             350.00

Nath. Saxon                 John Anderson May 17^th                      215.00

James Schooley            Wm. Chapman Oct. 19^th 1822             50.00

Samuel Spencer            J. M. Milnor                             21^st 1823         150.00

Peter Smich                  T. L. Woodruff & E. Ryno     May 21^st 1825             50.00

John R. Smith Treas.- R. McNeely                   June 19^th 1821             125.00

Charles Sutterly                                                Nov. 24^th 1824                        60.00

Drawers-                      Indorsers (sp)-             When due                     Amount-

William Scott                Wm. L. Smith               Oct. 8^th 1816               $300.00

Ditto                             Ditto                             Nov. 12^th                     100.00

Ditto                             Ditto                                         18^th                  230.00

Ditto                             Cashier                                                 150.00

Ditto                             S. Wright Jun’r.            Sept. 25^th                     1000.00

William L. Smith           William Scott                Aug. 28^th                      300.00

Ditto                             Ditto                             Sept. 4^th                       100.00

Ditto                             Ditto                                         18^th                  150.00

Ditto                             Ditto                             Nov. 2^nd                       100.00

Ditto                             Ditto                                         10^th                  200.00

Speakman & Lay         Benj. Say & others       Sept. 6^th                       585.35

Ezekiel Smith                Jos. Bullock                  Aug. 17^th                      200.00

Ebenezer Stout T. Lafaucherie & T. Merrain  July 4^th 1818                370.00

Ditto                             J. Barnes Jun.                           11^th                  70.00

John R. Savage Joseph Gen                              24^th 1823         624.73

J. R. Tucker                                                                                         175.00

Ditto                                                                 March 23^rd 1825          100.00

John Titus                                                         June 17^th                      81.45

John R. Tucker                                                 20^th                  175.00

Ditto                                                                 Aug. 18^th                      187.97

Ellett Tucker                                                                                         300.00

John R. Tucker Geo. Dill                       May 16^th                      300.00

Ellett Tucker                 G. & J. Rozell               April 20^th 1821 380.00

Reuben D. Tucker        Cashier             Feb. 20^th 1819             72.00

William Vanhart            John R. Smith               July 15^th 1824              65.45

Ellett Tucker                 Cashier             March 30^th  1821         200.00

Joseph Vandegrift                                             July 8^th 1825                68.00

(Vandergrift?)

Ditto                                                                             16^th                  200.00

Vansyckle & Brittain     White-House                Aug. 7^th                        400.00

C. H. Vanderveer         J. J. Wilson                               9^th 1816           130.00

Joseph W. Vancleve                                                                             38.94

Alex’r Van Horn                                               May 27^th 1825             151.00

Thomas L. Woodruff                                                                            175.00

Isaac Wyncoop                                                            25^th                  125.00

Wm. Welling                                                                                        50.00

G. D. Wall                                                                    6^th                    1400.00

J. Welling Jun’r                                                 8^th                    150.00

D. R. Warford                                                  July 1^st                          50.00

Charles M. Wells                                                          9^th                    225.20

George Woodruff         Cashier                         21^st                  380.00

Wilkinson & Hunt                                             Aug. 28^th                      163.82

James J. Wilson            J. R. Smith                    Oct. 7^th 1823               10.00

John M. White              Robert L. Armstrong    July 13^th 1824              260.00

Thomas Wilner                                                                         1000.00

Drawers-                      Indorsers (sp)-             When due                     Amount-

John M. White              John Halmer (?)                        12^th                  $40.00

Thomas L. Woodruff-   J. C. Chambers            May 25^th 1825             300.00

Ditto                             J. Richey                                  31^st 1826         303.41

Robert Woodward       Antony Tonis (?)           June 1^st             700.00

Phineas Withington or xxx Bailey                       May 4^th 1825               193.00

Ditto                 or Capt. Vanderbelt                  April 23^rd                      100.00

G. D. Olden                 Jos. Olden Jun. Nov. 19^th 1822                        200.00

Ditto                             Check on the Trenton Bank   Jan’y 28^th                     100.00

G. D. Wall                    Check on Trenton Bank          Jan 27^th 1823               710.00

Jacob Wycoff Jun.                                            June 29^th 1825             64.94

James T. Wilson           J. Davifson                   Sept. 2^nd                       57.00

Ditto                             H. & Davifson                          30^th 1816         150.00

Ditto                             C. Ramsay                               9^th                    103.07

Robert H. Wright          Joshua Wright jun.        May 27^th 1825             500.00

David Wright                Cashier             July 18^th 1820              900.00

James J. Wilson            Barzillai Wright                                     100.00

Barzillai Wright D. Johnston & co.        Dec. 28^th 1816             200.00

John M. White              J. McIlvaine & L. H. Stockton –May 18^th 1823}        250.00

Ditto                             J. McIlvaine                  July 15^th                       2000.00

Ditto                             Ditto                             June 17^th                      400.00

J. J. Wilson                   J. R. Smith                    July 24^th                       70.00

Edward Yard                                                               1^st 1825           100.00

Jno (?) Yardley                                     Aug. 17^th                      40.00

Isaac Yard                   John R. Smith               March 18^th 1823          16.95

Edward Yard               Cashier                                                 1200.00

Joseph Yard Jun.          C. & Thomson (sp)     Jan. 5^th 1818                50.00

Chambers & Thomson (sp)    Jos. Olden jun. Oct. 25^th 1819             300.00

Ditto                             Ditto                                         21^st                  200.00

Ditto                             Ditto                                         18^th                  400.00

Ditto                             Ditto                                         25^th                  500.00

Ditto                             Ditto                             Sept. 23^rd                     400.00

Ditto                             Ditto                                         16^th                  800.00

Ditto                             Ditto                                         13^th                  200.00

Ditto                             Ditto                                         9^th                    900.00

Ditto                             Ditto                                         8^th                    500.00

Ditto                             Cashier                         2^nd                    1000.00

Ditto                                                                             6^th                    200.00

John R. Thompson        C. & Thompson           Oct. 28^th                      100.00

R. & G. Barton                                     July 1^st 1825                 500.00

R. Hubbard                                                                  5^th                    107.40

S. Echstein                                                                   7^th                    108.05

A. Grule (?)                                                                  11^th                  90.40

A. W. Hubbard                                                            13^th                  83.55

Ditto                                                                             20^th                  106.70

John Sykes                                                       Aug. 1^st                        500.00

Drawers-                      Indorsers (sp)-             When due                     Amount-

Peter Force                                                      Sept. 21^st                     $450.00

R. & G. Barton (or Bartow)                                                                 581.00

Ditto                                                                 Oct. 5^th                                    200.00

D. & G. Barton (or Bartow)                             Oct. 8^th 1825               600.00

A. Grule                                                                                               600.00

Sam. Echstein                                                                                       109.48

A. W. Hubbard                                                                                    85.75

Jas. R. Stewart                                                                                     35.27

Rich’d Coxe                                                                                         75.00

                                    Robert McNeely Esq.

                                                            Sir,

                                                                        Pursuant to the following resolution pafsed (passed) by the board of Directors of the State Bank at Trenton on the ninth inst. (instant) viz Resolved that Robert McNeely be served with a notice to restore to this Bank all the discounted notes belonging to it an that a list of the said notes be attached to the notice.  You are hereby notified accordingly with the list of notes so claimed annexed-

                        Trenton Dec’r 14^th 1825

                                                                                    Wm Potts Pres’t Pro-tem.

                        I James B. Coleman do certify that the above resolution is a true copy of the attached to the list of notes in the pofsefsion (possession) of Robert McNeely and which was served on him.

                                                                                    James B. Coleman.

Dec’r 14^th 182

B

                        *The Schedule annexed to the foregoing bill of complaint and therein referred to :-.-.-

(B)

Drawers-                      Indorsers (sp)-             When due                     Amount-

James Anderson                                               July 10^th 1825              $150.00

Samuel Anderson         Samuel Hill                   May 7^th                        150.00

Robert Bayly (sp)         P. Withington                May 7^th                        250.00

Charles Burk                G. D. Walls                              8^th                    200.00

D. & J. Bristor (?)        Thos. Langstroth           Aug. 20^th                      600.00

James Cook                 Rob’t T. Purdey (sp)                25^th                  200.00

J. M. Coryell                John Coryell                 May 27^th                      1000.00

John Cavanagh H. Slack                                                           450.00

John C. Chambers        B. Fish                                     8th                   1000.00

Drawers-                      Indorsers (sp)-             When due                     Amount-

John C. Chambers        Benj. Fish                     Aug.23                         400.00

Joseph M. Downing      B. Fish                         May 15                        476.00

George Dill                   J. R. Dill                                   27^th                  450.00

John Dugdale                T. C. Sterling                            1^st                    268.00

John Davifson               T. C. Sterling                            5^th                    2800.00

Ditto                             J. B. Sartori                              11^th                  200.00

Ditto                             T. C. Sterling                Aug. 21^st                      4000.00

Samuel Evans               Lewis Evans                 May 10^th                      200.00

Benjamin Fish               Asa Fish                                   25^th                  1000.00

Peter Fonnan (?)           E. S. McIlvaine             6^th                    375.00

Benjamin Fish               Asa Fish                                   24^th                  1000.00

J. & J. Gulic (sp)          J. Gulic (sp)                              26^th                  2000.00

William Garrison           Philip Marshall  Aug. 25^th                      400.00

G. P. Glentworth          P. F. Glentworth           May 30^th                      300.00

Wm. Gordon                John Clark                                29^th                  300.00

John Hart                     P. & Jos. Hart                          14^th                  500.00

Joseph G. Hunt Wm. Marshall                           20^th                  200.00

Richard Hill                  J. S. Hill                                   29^th                  1000.00

Ditto                             Ditto                                         1^st                    500.00

John Haley                   Bedford Jobs                July 20^th                       300.00

John Harcourt               Nath’l Harcourt            Aug. 10^th                      150.00

Richard Hill                  J. S. Hill                                   20^th                  2640.00

Bedford Jobs                Rob’t. T. Purdy            May 11^th                      1000.00

David Johnston D. Bartive                                 21^st                  575.00

Thomas Johnston          John Davifson                           3^rd                    100.00

William Ketcham          Wm. Marshall               July 24^th                       200.00

Thomas Langstroth       Joshua Wright                                                   1000.00

Aaron Lambert Jasper S. Hill                July 12^th 1825              152.25

J. M. Milne                   J. Thorn Jun.                 May 29^th                      1300.00

R. McNeely                 John Potts Jun.             7^th                    200.00

Wm. Norton                 J. Norton & J. S. Hill                8^th                    1000.00

John Norton                 Peter Smich                              24^th                  200.00

Robert T. Purdy                                               June 21^st                       350.00

Ditto                                                                                                     200.00

Ditto                                                                             2^nd                    100.00

William Potts                                                                                        1200.00

William T. Purdy                                               May 5^th                        250.00

John W. Pearson          Benjamin South            Nov. 27^th                     103.00

Robert Purdy                James Cook                 July 21^st                        300.00

Ditto                             Bedford Jobs                Aug. 25^th                      225.00

Ditto                             Asher Quigley                                                   300.00

John Potts                    Robert McNeely                      16^th                  2600.00

Asher Quigley               Wm. Butcher                May 15^th                      300.00

John R. Smith               L. Richey                                  24^th                  1500.00

L. H. Stockton             Wm. Rozell                              3^rd                    495.00

Drawers-                      Indorsers (sp)-             When due                     Amount-

J. R. Smith C’y Treas.-Robert McNeely           Aug. 18^th                      400.00

S. &. T. J. Stryker        R. Rowley                                                        1000.00

John R. Savage A. Holten & Mrs. Savage      March 24}                   600.00

Peter T. Smith              Cashier             July 1817 11^th 1818     1700.00

James R. Tomlinson      Lewis Evans                 May 21^st 1825             400.00

John R. Tucker George Dill                               18^th                  300.00

Charles M. Wells          W. & Leaming (?)                    6^th                    1000.00

                       

                        _______________________________

                                    A true copy

                                                            John Wilson. Clerk

(Document is bound with braided string and was folded in fourths.  Outside ¼ is used for description/filing information.  This writing is sideways which cannot be reproduced here.)

In Chancery New Jersey

Between

The President, Directors & Company of the State

Bank at Trenton

                        Complt’s                      Bill.

                        (Complainants)

            And

Abner Reeder & others

                        Defdts.

                        (Defendants)

Theo. Frelinghuysen

                                    Sclr (?)

Filed Nov. 3^rd 1825

John Wilson  Clk.

Copy

Office fees $10.88