And whereupon the said Thomas Jones by Robert
Carvile his Attorney saith, that the said John Penroy upon the
thirtieth day of April in the yeare of our Lord One thousand six
hundred Seventy nine being justly indebted to the said Thomas
Jones for storage & for necessary accomodacons of himselfe & his
Servants And for severall Sumes of tobacco paid for him & by his
order to severall persons & for severall Goods & Comdities sold him
the said John by the said Thomas And for horse hire & worke done
for him att severall dayes & tymes from the thirtieth day of August
One thousand six hundred Seventy Eight till the thirtieth day of
April One thousand six hundred Seventy nine aforesaid amounting
in the whole to the Sume of ffourteen thousand foure hundred thirty
five pounds of tobacco, towards paym^t & satisfaction whereof the
said John Penroy did pay & satisfie, & the said Thomas did receive
in goods & other payments the sume of twelve thousand two hun-
dred fifty seven pounds of tobacco So that there rested due to bal-
lance to the said Thomas the Sume of two thousand one hundred
Seventy Eight pounds of tobacco, as by a particuler accompt thereof
hereunto annexed may appeare In consideracon whereof the said
John did assume upon himselfe & to the said Thomas did faithfully
promise, that he the said John the said Sume of two thousand one
hundred Seventy Eight pounds of tobacco to him the said Thomas
when he should be thereunto lawfully required would well & truely
satisfie & pay Yet notwithstanding the said John his promise &
assumpcon aforesaid little reguarding, but deviseing & fraudulently
intending him the said Thomas in this behalfe craftily and subtily to
defraud & deceive, the said Sume of two thousand one hundred
Seventy eight pounds of tobacco to him the said Thomas though
often thereunto requested hath not paid or satisfied, but the same to
pay hath hitherto denyed & still doth deny & refuse to the damage