received the said Bacon to carry and deliver as aforsaid + received the said price or reward of $75.00 for the carriage and delivery of the same. Yet the said Keith not regarding his aforsaid promise and undertaking so made in this behalf as aforesaid but contriving and fraudulenty intending craftily and subtilly to deceive and defraud the said Pltffs did not safely and securely carry and convey the aforesaid Bacon from the said town of Union to the said City of Richmond and there deliver the (sd) Bacon to the said ( ? ) Pullian + Swann in the City of Richmond within eighteen days after the 2nd day of May 1818 nor at any time whatsoever either before or since the said day when it ought to have been delivered; nor hath the said Keith yet safely and securely delivered the said Bacon or any part thereof to the said Pullian and Swann according to his promise and undertaking aforesaid (altho to to do this the said Keith was requested by the sd Pltffs afterwards to wit on the __ day of __ 181_ at the town of Union as aforesaid; but he to carry and deliver (the said Bacon) to the said Pullian + Swann in the City aforesaid the same or any part thereof ( ? ) to his promise and undertaking hath hitherto wholly refused and still refuses so to do.
And whereas the said keith afterwards to wit on the (same day and year aforesaid) 1st day of June 1818,