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To the Honorable, the Judge of the Sangamon County Circuit court in chancery sitting -
Humbly complaining sheweth unto your Honor your oratrix Maria S. Bullock that on the 20th day of August 1855 one William S. Viney made his two several promissory notes, of that date, both payable to your oratrix, both bearing interest at the rate of six per cent per annum from date until paid, each for the principal sum of eighty one dollars, one payable in one year and the other in two years after date, the same being to secure a part of the purchase money of Lots. 24. 25. & 26, in Block 1 in Bullock's Addition to the City of Springfield - that to secure the payment of said notes, the said Viney executed his mortgage deed of that date to and in favor of your oratrix, upon the lots aforesaid, which mortgage deed was afterwards duly recorded in the Recorder's office of said County of Sangamon; and which mortgage deed is herewith filed, marked (A) and prayed to be taken as part hereof - Your oratrix further states that afterwards, to wit, on or about the 5th day of November 1856, the said Viney paid and fully discharged the one note first falling due, of the two notes aforesaid; and that
the other of said notes remains wholly due and unpaid, and is herewith filed, attached to said mortgage deed - Your Oratrix further charges that said Viney has not fully paid the taxes upon said lots; but on the contrary, has permitted them to be sold for the tax of 1856, and allowed the purchaser to pay the tax of 1857, so that your oratrix, in order to preserve her security, has been compelled to redeem said lots from said sale, paying double the amount for which they were sold, and the single amount for 1857, amounting in all to the sum of Five dollars, and eighteen cents; and that, for the same object she has been compelled to pay the taxes for the year 1858, amounting to the sum of Three dollars and ninety nine cents, all which your oratrix claims she is in Equity, entitled to recover of and from said Viney-
In consideration of all which your oratrix prays that said William S. Viney be now defendant to this Bill; that the People's writ of Subpoena issue for him; that he be required to appear and answer all and singular the alle
gations of this Bill, and that on a final hearing your Honor will decree that your Oratrix recover of and from the said defendant, the amount of principal and interest which may then be found due on said unpaid note, together with the full amount she has paid as aforesaid, on account of taxes; that his Equity of Redemption in and to said lots be barred and forever foreclosed, and that said lots be sold to pay and satisfy said accord, together with all costs; and that your Honor will grant such other and further relief, as Equity may require,and, as in duty bound &c
Lincoln, for Complainant
Maria S. Bullock
vs.
William S. Viney
In Chancery to foreclose
I do hereby enter myself security for costs in this cause, and acknowledge myself bound to pay or cause to be paid all costs which may accrue in this suit, either to the opposite party or to any of the officers of this court, in [persuance?] of the laws of this State -
Dated this 8th Day of February A.D. 1859
A. Lincoln -
State of Illinois
Sangamon County
SS
Abraham Lincoln being first duly sworn, states on oath that he is informed, and verily believes that William S. Viney, the defendant in the foregoing Bill in Chancery, resides without the State of Illinois.
Subscribed and Sworn to before me
this 8th January AD. 1859
[illegible] Wright Clk
A. Lincoln -
181
Maria S. Bullock vs William S. Viney
Bill
Filed February 8, 1859
[illegible] Wright clk
Ap 3, 1859
Pat made