To The Worshipful, the Justices of the County Court of Morgan, sitting as a Court of Chancery, humbly complaining, show unto your Worships, your Orators, David Ambrose and George Ambrose, administrators of the estate of Matthias Ambrose deceased.

That a suit was instituted in the Superior Court of Berkeley, by Susanna B. Storm against George Riser administrator of Henry Ambrose, Sen'r deceased, upon which judgment was obtained at the September term of said Court 1814, for one hundred and fifty pounds, with interest from November 1, 1811 - upon which judgement, execution issued on the 10th of October, 1814 to debtor for the sum mentioned and interest and $15.51 costs, which was returned "No assets".

Your Orators, state that the said suit was brought upon a bond of the said Henry Ambrose, dec'd to the said Storm, for the sum of 300 lbs, penalty to be discharged by the payment of the said sum of 150 pounds, which bond was dated on the 1st day of October 1811, and bound his heirs. The proceedings in said suit are herewith filed as part of this bill.

Your Orators further, state that their intestate, Matthias Ambrose, dec'd, was one of the heirs of the said Henry Ambrose, Sen'r dec'd. There were three others, William Ambrose, Margaret Riser, formerly Margaret Ambrose and Catherine Clauver, formerly Catherine Ambrose who, with the said Matthias Ambrose, dec'd were children of the said Henry Ambrose, Sen'r dec'd.

They further state and charge, that the said Matthias Ambrose, dec'd obtained, by the payment of $200, an acquittance from the said Susanna Storm of all claims or demands, the above claim among the number, if there were others, against the heirs or personal representatives of the said Henry Ambrose, Sen'r dec'd, his father.

They further, showing, state unto your Worships, that the said Henry Ambrose, dec'd left a tract of land in the County of Morgan, situate on the south fork of Sleepy Creek, containing about 142 acres, which descended to his said heirs, & which was bound by the jud't aforesaid for the discharge of the debt aforesaid to the said Susanna Storm.

Your Orators state, that their intestate, the said Matthias Ambrose, dec'd, nor his heirs nor personal representatives since his death, have been reimbursed the said sum of $200, by the payment of which, as aforesaid -- the evidence whereof, marked A, is herewith filed as part of this Bill -- the said debt to Storm was discharged, and they are advised, that they are entitled to be substituted to the rights of the said Susanna Storm, as respects her lein upon the said real estate, by virtue of the judg't aforesaid, to the extent of three fourths of the am't of her said debt, or, at least to the extent of three fourths of the am't with interest, paid as aforesaid to acquit said debt.

They further charge that the personal estate of the said Henry Ambrose, Sen'r dec'd was insufficient to discharge any portion of the said debt to Storm, after paying other claims -- and that the rents & profits of the real estate descended would not pay off in a reasonable time the prin'l & In't thereof nor of the said sum of $200, with its interest, nor would they pay off the three fourths aforesaid of other accounts.

To the end, therefore, that the said William Ambrose, George Riser, Benjamin Riser, Resin Barnes & Catharine his wife, Jacob Portmess & Sophia, his wife, Richard Thralls & Anna, his wife -- the said George, Benjamin, Catherine, Sophia & Anne being children & heirs of Margaret Riser, dec'd, formerly as aforesaid, Margaret Ambrose, Henry Clauver, Peter, John, Jacob, Solomon, Henry, Samuel, Philip, William, Aaron, Margaret & Rosanna Clauver, children & heirs of Catherine Clauver, dec'd, formerly as aforesaid Catherine Ambrose, and John Yost & Susan his wife George Aulabaugh & Mary his wife, Matthias Ambrose, W'm Ambrose, George Durham & Rosanna his wife, John Kitchen & Hannah his wife, Henry Ambrose, Joseph B. Ambrose, Lucy Ambrose & Margaret Ambrose, who are, with your Orators, children & heirs of Matthias Ambrose, dec'd aforementioned, may be made defendents to this Bill & may upon their conformed oaths, full, true & perfect answer make hereto as fully as if specially here interrogated thereupon, that your Worships may devise a sale of the tract of land, aforesaid to discharge the amount due your Orators and that your Worships may grant such other & further relief in the premises, as may be equitable.

May it please all,
Pendleton, Special Commissioner