WILLIAMS VS. SAVAGE MANUFACTURING CO. 309

his said brothers, and at the suggestion of one of them, he, in
April, 1843, petitioned for the benefit of the insolvent laws, and
obtained his discharge in August, of the same year—that from
that time until early in the year, 1844, he remained undisturbed
by his creditors, but that, in the year 1844, Nathaniel Williams,
who had promoted the suit of the company, and which had
been referred to counsel, began to press the settlement of that
claim and by the contrivances which the bill details, succeeded
in obtaining in satisfaction of this pretended claim a transfer of
the stock of the complainant in the company to the amount of
$9632 32.

That the settlement, by which a transfer of this stock was
obtained, was founded upon accounts, one of which was pre-
pared by Cumberland D. Williams, in concert with his brothers,
Nathaniel and George, and the other by a clerk of said George,
who prepared the same under the direction of his employer.

The bill charges, that these accounts were false in many
particulars, and known to the trainers thereof to be such, and
are, therefore, fraudulent in fact, and in contemplation of this
court, and then proceeds to surcharge and falsify the same in
some of the most important items.

The complainant further alleges, that when restored to health,
bodily and mentally, in the fall of 1844, he found himself, who
had fallen sick worth about $35,000, an insolvent debtor, and,
that the active and prominent agents in reducing him to this
condition, were his brothers, George and Nathaniel, who,
during his state of imbecility, had put the machinery in opera-
tion to accomplish his ruin.

That after the institution of the first suit against him, to
wit, on the 15th of September, 1840, the complainant, at the
suggestion of his brother, Nathaniel Williams, executed a deed
of trust of all his property to Charles F. Mayer, Esq., and his
(the complainant's) son-in-law, George W. Burnap, and, that
the provisions of that deed, which will be noticed hereafter,
were advised by the said Nathaniel.

That, the claim set up by the company, against the com-
plainant, and, which had been exhibited by his said brother,