I have more on this family if anyone is interested...and I can find it. Audrey To the honorable the Chancellors of the State aforesaid. Humbly complaining shows unto your honor your orator William H. Pool and your oratrix Elizabeth Pool, his wife, that John Pool the father of your oratrix departed this life intestate in the summer of the year 1837 being seized in for at the time of his death in this district of a considerable real and personal estate to wit a tract of land containing about 280 acres whereon he resided adjoining lands of G.B.Riley William Pool and others. Also another tract on Reedy River bounded on the East by said river and on the other sides by lands of William Pool and containing about one hundred and three acres more or less. That said lands far exceed in value the sum of one thousand dollars and are subject to partition amongst the following persons as the only heirs at law of the said John Pool dec'd to wit Linny (PYLES)* Pool his widow who is entitled to one third thereof and the following children of the deceased, your oratrix, Elizabeth Pool wife of your orator William H. Pool, Sa! nford V. Pool, Francis M. Pool, John Pool Jr. and Malinda Pool who are entitled to the remaining two thirds share and share alike. That the said Linny Pool widow of aforesaid has had the use and occupancy of said lands _____________the death of her said husband and ought to account to your orator and oratrix for their share of such amount as well as to the other children of the deceased. That the said Linny Pool on the 20th day of February 1845 mortgaged amongst other property her undivided interest in said lands to one James Cunningham of said district to recuse the payment of three thousand five hundred and fifty three dollars to said Cunningham on or before the first day of February 1850 with interest thereon from the 1st day of February 1845. which mortgage your orator and oratrix ______ ________ is still unsatisfied. That the premises aforesaid have and are_________ going to waste and that it is necessary to prevent such waste and to enable your orator and oratrix to enjoy their interest in ________that said lands should be partitioned according to the provisions of the act of ________ in such case made and provided. That the said Sanford V. Pool, Francis M. Pool, John Pool and! Malinda Pool are all minors under the age of twenty one years and without any person legally authorized to represent them in this suit. All of which actings and doings of the said Linny Pool and her confederates are contrary to equity and conscience and _____ the injury of orator and oratrix. In tender consideration whereof and in as much as your orator and oratrix are without adequate and complete remedy by the strict rules of the common law and are liable only in this Honorable court when matters of this kind are properly cognizable and are liable to the end. Therefore that the said Linny Pool, James Cunningham, Sanford V. Pool, Francis M. Pool, John Pool Jr and Malinda Pool many upon their respective corporal _______ true and perfect answers make to all and singular the promises as fully as if the same _______ him again _________ and they thereunto specially interrogated, and that said lands may be partitioned according to the law under the ___________of this court between your orator and oratrix and the said Linny Pool, Sanford V. Pool, Francis M. Pool, John Pool Jr and Malinda Pool, that a unit in partition ; that a guardian ad litum may be appointed for the said Sanford V. Pool, Frances M. Pool, John Pool Jr., and Malinda Pool to represent them in this suit and your orator and oratrix ________ _________ honors for each other and further relief in the promises as may be consistant with equity and conscience and _______ that the said Linny Pool may be required to account to your orator and oratrix for the rest of the said lands as far as she is properly chargeable thereunto. May it please your honors to present unto your orator and oratrix the unit of subpeona ad ______ ________ of this court to be directed to the said Linny Pool, Sanford V. Pool, Frances M. Pool, John Pool Jr., Malinda Pool and James Cunningham requiring them and each of them to appear in this honorable court on a certain day therein to be specified and answer this bill according to the practice of the court and to stand to and abide each order and _____ in the premises as it may seem _____ for your ! Honors to make. _____ your orator and oratrix will _____ pray _______. ___ P. Sullivan counsl Sol. I Elizabeth Pool wife of Wm H. Pool Give my consent to the filing of this suit W.W. J. _______ Elizabeth Pool *I have added PYLES to Linny's name because that was her name. (Audrey)