14

SUPREME COURT OF THE CANAL ZONE. Jan. Term,

Seymour, and said plaintiff, Antonio Andrade, on the twentyfirst day of July, 1905.
The said complaint alleges that the defendants, being copartners, conspired together, by tricks and artifices, to defraud and cheat the plaintiff out of a vast amount of propertv., to the value of $50,000.00, as appears from said pretended contract between the defendant Seymour and the plaintiff, a copy of which is filed with said complaint and made a part thereof; that the execution of said agreement was procured by false representations, prior to its execution, and by fraudulent representation as to what the terms of the contract, and the wording thereof, were; that the plaintiff relied upon the statements of the defendants, and believing the Same, and being carried away by the hurry and bustle of the defendant Popham, was induced to sign the contract m-ide a part of the bill of complaint. Plaintiff further alleges that he was not indebted to the defendant Seymour, or to any of the defendants, in any sum. The complaint further alleges that the defendant Seymour was engaged in running a roulette wheel and that the bills mentioned in said complaint are for gambling debts, and not collectible, nor enforceable, in the courts of the Zone; that the plaintiff could not read nor write the Greek, his native tongue, nor read, write or understand English, except by broken, desultory and disconnected words; that he was persuaded to sign his name to a paper which the defendants pretended contained the provisions which he desired, but which in fact did not, and attempted to extort from the plaintiff a vast amount of rum, the product of the plantation of the plaintiff and of which he was the owner; that by reason of divers false and fraudulent representations, plaintiff was induced to sign the pretended contract, and the plaintiff was denied the right of having the contract read to him by some one in whom he had faith; that ad-vantage was taken of a time when plaintiff's attorney was out of town, with intent to cheat and defraud the plaintiff; that the plaintiff does not owe the defendants or either of them anything- that the papers held in escrow are simply evidence of a scrambling obligation won by defendant Seymour from the plaintiff by means of a crooked and unfair wheel, called roulette wheel, and are without consideration, and in violation of law; that the plaintiff