Trustees for them, or some of them; under which Circumstances the said pretended Proprietors repeat their Suits against your Majesty's Petitioners, or some of them, even for the same Farms, if they happen not to be successful in the first Suit, and threaten to pursue in the same Method, until your Majesty's poor Petitioners are reduced to Poverty and Distress, and rendered unable to defend their just Rights, and so be obliged to surrender those Estates which they and their Ancestors have spent their Substance and Lives upon; the Loss of which, would prove a general Ruin to as many Families as make up seven Protestant Congregations, now settled on said purchased Lands.

That your Majesty's poor and distressed Petitioners, with long and expensive Law-suits for near about fifty Years together, in which they have spent many Thousand Pounds, and annually are obliged to be at vast Expence in Defence of their said Rights, are discouraged and quite wearied out, and are become (as they conceive) under the present Administration, remediless, without your Majesty's most gracious Royal Protection and Care.

And more clearly to evince the Difficulties and Matters above suggested, your Majesty's Petitioners would most humbly beg Leave to represent and numerate some of the Steps and Proceedings heretofore taken, and still carrying on against them, tending to their Distress, Loss and Ruin, (viz.)

That formerly the said pretended Proprietors, did take upon them the civil Government of the said Province of New-Jersey, and did actually erect Courts, and appoint Officers of their own, before whom your Petitioners Ancestors were sued. and by them unjustly condemned; particularly, in a Case brought by Lease of Ejectment by James Fullerton, claiming by Demise from the pretended Proprietors of East-NewJersey, against Jeffrey Jones, one of your Petitioners

Ancestors, wherein at a Court held at Amboy, the 14th of May 1695, the said Court unjustly gave Judgment in favour of the said James Fullerton; on which Judg ment, on Appeal of the said Jones to the King in Council, at the Court of Kensington, 25th February 1696, by his Majesty in Council, was reversed and set aside; and as your Petitioners said Lands are all under the like Circumstances, and held by the same Title, so they supposed and expected the Controversy about the same would have ceased; yet, nevertheless, the said pretended Proprietors, by the Improvement made by your petitioners Ancestors on the Premisses, more than any Foundation of Right, were and have been further tempted to molest, trouble and invade your Petitioners Property and Possessions; that therefore, since the Government of said Province hath been under the immediate Care of the Crown, the said pretended Proprietors many of them, have been Members of the Council, and Judges of the Courts in the said Province; and by this Means your Petitioners have been prevented from bringing or removing their Cause before the King in Council, in the common Course of Appeals.

In particular, that when Joseph Woodruff, one of Your Majesty's Petitioners Ancestors, by Writ of Error, brought his Cause before the Governor and Council of this Province, in the Fourth Year of the Reign of your Majesty's late Royal Father, in order to obtain a Judgment there; and from thence, if Judgment was given against him, he intended to have appealed to his said Majesty then King of Great Britain, &c. in Council; the said Governor and Council would never be prevailed upon to give a Judgment in the said Cause; but after about Ten or Twelve Years Delay, and a vast Expense in the Cause, the said Case dropt without being decided.

The present Governor of the said Province has for

merly been Agent for some of the said pretended Proprietors, and stands in a near Relation to several of the pretended Proprietors aforesaid; the present Chief Justice of said Province is Trustee and Guardian of several Orphans who are pretended Proprietors aforesaid; and the rest of the Judges and Members of the Council are in general interested, on the said pretended Proprietors Side.

That the Juries in the Counties where the said purchased Lands lye, are generally interested and engaged against your Petitioners; and the more effectually to secure all in Favour of the said pretended Proprietors, the Governor, Council and General Assemby of the said Province, have, by an Act passed in the Fifteenth Year of your Majesty's Reign, annexed part of your Petitioners Lands, which were before in the County of Essex, unto the County of Somerset, where the Juries are generally in the said Act, representing the Inhabitants as having prayed for the same; which your Petitioners believe to be a great Mistake.

That under all these and many other such like Disadvantages, Writs of Trespass, and Leases of Ejectment, in behalf said pretended Proprietors, are frequently commenced against some of your Petitioners, and thereon Verdicts and Judgments obtained; some of them for Six-pence Damage, and for Two or Three Hundred Pounds Proclamation Money Costs; others of your Petitioners are turned out of their Freeholds and Living, and large Bills of Costs taxed against them.

By Means whereof many of your Majesty's poor Petitioners are grieviously distressed, and others are daily threatened with the same Fate, and are daily under Expectation of being burthened with heavy Costs, great pretended Damage, and Loss of their Possessions and Inhabitants; which your Petitioners are advised, they do not suffer for Want of Justice;

and your Majesty's Petitioners are advised, that it's neither legal, equitable nor just, that the Titles to their said Lands should be tryed by the Judges, Jury and Courts of the said Province, in Regard they are Parties in Interest more or less in the Matters in Controversy, and ought not to hold Plea of your Petitioners said Lands.

WHEREFORE, Your Majesty's Petitioners most humbly implore your Majesty, the Fountain of Justice, that you would be graciously pleased to take them and their said Cause under your Majesty's Royal Care and Protection; and as there is no Prospect that your distressed Petitioners can find any Remedy of their Grievances in this your Majesty's Province of New Jersey that your Majesty in your most Honourable Privy Council, would be pleased to hear and determine their said Controversy; or, that your Majesty would be pleased to appoint disinterested Commissioners out of some of the Neighbouring Colonies, and by a Jury from thence also to be taken, to hear and finally decide the said Cause; or, that your Majesty would be graciously pleased to appoint Commissioners to hear, and enquire into, and determine said Controversy, or otherwise order for your Majesty's loyal, dutiful, poor, oppressed Petitioners Relief, as to your Majesty, in your princely Wisdom and abundant Goodness, shall seem meet,

And Your Majesty's Most Humble Petitioners, as in Duty bound, shall ever pray, &c. [July, 1744]

[Three hundred and nine names were appended which can be found in papers of F. J. Paris in Historical Society Library-Elizabeth-town Papers, Bundle L, No. 9.]

Memorial of the East Jersey Proprietors to Governor Morris-asking for the passage of an Act for running the Division Line exparte.

[From Papers of Ferdnand J. Paris, Book A, p. 137, în the New Jersey Hist. Soc. Library.]

TO HIS EXCELLENCY LEWIS MORRIS ESQ Captain General and Governor in chief of the Province of New Jersey and Territories thereon Depending in America and Vice admiral in the Same.

The memorial of the Council of General proprietors of the Eastern Division of New Jersey.

Humbly Sheweth

That by an Act of Governor Council and Assembly of the Province of New York pass'd in the year 1717 the Governor thereof was impowered to appoint Commissioners in behalf of that province to Join with such Commissioners as Should be appointed in behalf of the province of New Jersey for Runing and Ascertaining the Line of partition and division between the Said Two provinces; and a Sum of money was by the Said Act appropriated for that purpose.

That Soon afterwards another Act was pass'd by the Governor Council and Assembly of New Jersey impowering the Appointment of Commissioners for the Eastern and Western Divisions of the Province of New Jersey to meet with the Commissioners to be appointed for the province of New York to Execute the purpose aforesaid.

That in the year 1719, Commissioners having been