308 HIGH COURT OF CHANCERY.

purpose they were authorized to purchase and hold land in fee
simple or otherwise, not exceeding three hundred acres at a time,
and to erect thereon, all necessary buildings, with a capital of
one hundred and fifty thousand dollars, divided into fifteen hun-
dred shares, of one hundred dollars each.

That the company organized soon after the date of the char-
ter, and went into operation; the complainant at or about that
time, becoming their agent at its manufacturing establishment,
on the little Patuxent River, in Anne Arundel County—that
this agency was continued from that time, until the 6th of July,
1839, when he tendered his resignation, which was accepted,
and his brother, Cumberland D. Williams, was appointed in
his stead.

The bill alleges, that in June, 1839, the complainant became
afflicted with sickness, which entirely disqualified him from at-
tending to business of any kind, and that he remained in this
condition until the fall of 1844, when he was restored to health
in mind and body—that of the capital stock of the company,
which amounted to $108,100, the sum of $37,632 32 stood on
its books in the name of the complainant, and that his property,
including this stock, at the commencement of his sickness, was
probably worth over and above all his just debts, about $35,000

—that in this condition of his mental and bodily health, his
brothers, George Williams, Cumberland D. Williams, and Na-
thaniel D, Williams, addressed his, the complainant's son-in-
law, a letter upon the subject of making a will, to prevent his
property from passing out of his family, but being disappointed
in their views in this respect, by his refusal or neglect to com-
ply with their suggestions, they, the brothers, determined to
destroy that which they could not obtain, and reduced the com-
plainant to poverty, by the means and instrumentalities which
the bill then proceeds to point out—'these consisted, as set forth
in the bill, in instigating his creditors to sue him, and in a suit
which the Savage Manufacturing Company instituted against
him for an alleged indebtedness; the company at that time
being altogether controlled by his brother, George and Nathaniel

—that in consequence of these proceedings, thus instigated by