7 In the third place, the people called Quakers believe that the Scriptures are given by inspiration, and when rightly interpreted are unerring guides; and to use the language adopted by them, they are able to make wise unto salvation, through faith which is in Christ Jesus. They believe that the spirit still operates upon the souls of men, and when it does really and truly so operate, it furnishes the primary rule of faith. That the Scriptures proceeding from it, must be secondary in reference to this primary source, whence they proceed; but inasmuch as the dictates of the spirit are always true and uniform, all ideas and views which any person may entertain repugnant to the doctrines of the Scriptures (which are unerring) must proceed from false lights. That such are the doctrines entertained and adopted by the ancient Society of Friends, and that the same doctrines are still entertained by the Orthodox party aforesaid, to which party your orator belongs. That these doctrines are with the said religious society, fundamental, and any individual, entertaining sentiments and opinions contrary to all or any of the above mentioned doctrines, is held not to be in the same faith with the Society of Friends or people called Quakers, and is treated accordingly. And your orator further charges and shows, that the Hicksite party aforesaid, do not adopt and believe in the above mentioned doctrines, but entertain opinions entirely and absolutely repugnant and contrary thereto. In regard to the first religious doctrine above named, the Hicksite party aforesaid, believe that Jesus Christ was a mere man, divinely inspired, partaking more largely of divine inspiration than other men, but that others, by resorting to the same means, and using the same exertions, may receive the same portion or measure of divine inspiration. That Jesus Christ, as well as the apostles and prophets, never has been and never can be set above other men; and though of late, the said Hicksite party sometimes ascribe divinity to Jesus Christ, yet they do it only in a figurative sense, from the circumstance of his partaking more largely than other men of divine inspiration. In every other respect they consider him a mere man. They do not believe that he partakes of the divine as well as human nature, that he is of one and the same essence with God, with that Supreme and Omnipotent Being who presides over and governs the universe. In respect to the second religious doctrine above mentioned, the Hicksite party deny the doctrine of the atonement above set forth, and they contend and believe that man may have access to his God without any mediator. They contend that the crucifixion and sufferings of Christ, if an atonement at all, were an atonement only for the legal sins of the Jews. In respect to the third doctrine above mentioned, the Hicksite party deny the certainty and divine inspiration of the Holy Scriptures, and hold that they contain doctrines and injunctions which are incorrect, and that they are a mere shadow. That these discrepancies in religious doctrines, as above mentioned, between the Hicksite and the Orthodox parties, are radical, and all important in the opinion of your orator and his party, in reference to the principles and tenets of religion, as held by the ancient fathers of this religious society. The Orthodox party believing, as they firmly do, that the doctrines entertained by the Hicksite party, strike at the foundation and main pillars of the christian system; that in consequence of these differences in doctrine, the Hicksite party are not in the same faith with them and the ancient religious Society of Friends. And your orator further charges and shows, that during the Yearly Meeting of the Society of Friends, held in Philadelphia in the spring of eighteen hundred and twenty-seven, commencing on the third Monday of April as above mentioned, at the hour of ten in the morning, according to the constitution and rules of the society, the Hicksite party held several private irregular meetings, at which no one attended or was invited to attend, except their own party, in which, after adverting to the irreconcilable difference in opinion and doctrine between the two parties, and adverting to some confusion and disorder which they themselves had occasioned in the Yearly Meeting, but which they improperly ascribe to the Orthodox party, they stated, that the period had fully come in which they ought to look towards making a quiet retreat from this scene of confusion, alluding to the Yearly Meeting aforesaid, and they therefore recommended to the members of their party, deeply to weigh the momentous subject, and to adopt such a course as truth, under a solid and solemn deliberation should point to-that at this sitting, in the spring of eighteen hundred and twenty-seven, the said Yearly Meeting regularly closed its business, and adjourned to meet again the next year, at the usual time specified in its constitution, viz. on the third Monday of April, eighteen hundred and twenty-eight. And your orator further charges and shows, that in June, eighteen hundred and twenty-seven, the said Hicksite party, pursuant to the determination formed by them at their irregular private meetings, held during the sitting of the Yearly Meeting as aforesaid, held another private meeting of their own, none but their own party being invited to attend, at which they resolved upon, and prepared an address, for the members of their own party, proposing for the consideration of their own party, the propriety and expediency of holding a Yearly Meeting for Friends in unity with themselves, and they recommend to the Quarterly and Monthly meetings, prepared for such a measure, to appoint representatives to meet in Philadelphia, on the third Monday of October, eighteen hundred and twenty-seven, with other members favourable to their views, there to hold a Yearly Meeting; that some of the members of a number of Quarterly and Monthly Meetings, which were under the control and jurisdiction of the regular and constitutional Yearly Meeting at Philadelphia afore 9 said, which members belonged to the said Hicksite party, accordingly met at Philadelphia, on the third Monday in October aforesaid, and then and there, irregularly and contrary to the discipline, constitution, and government of the Society of Friends, formed a New Yearly Meeting of their own, which was adjourned by them to the second Monday of April, eighteen hundred and twenty-eight, just one week before the time for the sitting of the regular constitutional Yearly Meeting as aforesaid; that on the second Monday of April last past, the Hicksite party held their new Yearly Meeting, and the Orthodox party held the regular ancient Yearly Meeting on the Monday following, pursuant to the adjournment of the previous year; that the regular and ancient Yearly Meeting aforesaid, which is now continued and held by the Orthodox party as aforesaid, always has been, and still is recognised by the ancient and primary Yearly Meeting of London aforesaid, as a regular Yearly Meeting of the Society of Friends, and is in regular correspondence and fellowship with them, whereas the new Yearly Meeting, formed by the Hicksite party as aforesaid, is not recognised by the Yearly Meeting of London as aforesaid, as a Yearly Meeting of the Society of Friends, and holds no intercourse or correspondence with them. Thus the Hicksite and Orthodox parties aforesaid, are completely and absolutely divided and separated, not only in regard to fundamental religious doctrines, but also in government and in fact, as well as in religious belief. They no longer form two parties of the same religious society, but they now form two separate, distinct religious societies and communities. The schism is complete. The Hicksite party aforesaid, have seceded not only from the faith, but from the religious institutions and government of the Society of Friends, and the ancient Yearly Meeting of Philadelphia being continued by the Orthodox party aforesaid, they are identified with them in regular and due succession. And your orator further charges and shows, that these religious dissentions and divisions aforesaid, exist in the Preparative, Monthly, and Quarterly Meetings at Crosswicks aforesaid. That the Hicksite party and the Orthodox party aforesaid, there hold separate and distinct meetings for business and worship, the former being under the jurisdiction and control of the new Yearly Meeting of Philadelphia aforesaid, to which they have attached themselves, having renounced the jurisdiction and control of the ancient Yearly Meeting aforesaid, the latter being under the jurisdiction and control of the ancient Yearly Meeting of Philadelphia above mentioned, now held and formed by the Orthodox party as aforesaid, and which still continues to hold its annual meetings on the third Monday of April, the regular constitutional period as aforesaid, which Yearly Meeting disowns and does not recognise the said Preparative Meeting at Crosswicks, held by the Hicksite party aforesaid. 10 Under these circumstances, the said Thomas L. Shotwell sometimes pretends that he has a right in equity and good conscience to hold the said mortgage debt, as a fund under the control of the Preparative Meeting at Crosswicks aforesaid, composed of the party called the Hicksite party aforesaid, and to withhold the same from your orator, the contrary whereof your orator charges to be true. And your orator further charges and insists that the said Preparative Meeting at Crosswicks, composed of the Hicksite party aforesaid, having adopted opinions absolutely repugnant to the fundamental religious faith and doctrines of the ancient Society of Friends, and more especially having joined themselves to the new Yearly Meeting, thus irregularly and unconstitutionally formed as above mentioned, contrary to the established discipline and government of the ancient religious Society of Friends, and having themselves renounced the jurisdiction and control of the ancient Yearly Meeting of Philadelphia aforesaid, and being disowned by them, the said Preparative Meeting at Crosswicks is not of, and does not belong to the ancient and established religious Society of Friends or people called Quakers, and is not identified with the Preparation [Preparative] Meeting of Chesterfield aforesaid, which was in existence when the school fund aforesaid was created, and when the said bond and mortgage were executed to your orator; on the contrary, the Preparative Meeting at Crosswicks, composed of the Orthodox party as aforesaid, and to which your orator belongs, still adhering as above shown, to the faith of their fathers, and still continuing under the jurisdiction and control of the ancient Yearly Meeting of Philadelphia, are identified in regular succession and continuances with the old Preparative Meeting of Chesterfield, which was in existence when the said school fund was created, and said bond and mortgage were given, and are entitled to hold and enjoy the property held in trust as aforesaid for the Meeting of Chesterfield, and to the control of the said school fund. All which actings and doings and pretences of the said confederates, are contrary to equity and good conscience, and tend to the manifest wrong and injury of your orator. In tender consideration whereof, and for as much as your orator is remediless in the premises at common law, and can only get complete relief in this high and honourable court, where matters of this nature are properly discovered and relieved against. To the end therefore, that the said Thomas L. Shotwell and Elizabeth his wife, and their confederates, when discovered, may full, true and perfect answer make to all and singular, the premises, paragraph by paragraph, as fully as if the same were herein again repeated, and they were thereto particularly interrogated with all attendant circumstances and incidental transactions. And that he the said Thomas L. Shotwell, may be decreed to account with your orator for the principal and interest due him as aforesaid, on his said bond and mortgage, and to pay him, what upon such accounting, shall be found due, by a short day to be appointed by 11 this honourable court, and in default thereof, that the said Tho- G. WOOD, Solicitor, and of Counsel A true Copy.-JOHN WILSON, Clerk. To Isaac H. Williamson, Governor of the State of New Jersey, and Humbly complaining, SHOWETH unto your Excellency, your orator, Thomas L. Shotwell, of the township of Chesterfield, in the county of Burlington and State of New Jersey-That in the year 1792, certain persons, styling themselves members of the Preparative Meeting of the people called Quakers, at Crosswicks, in the township of Chesterfield, in the county of Burlington, and State of New Jersey, promised to pay on demand, and in specie, at the rate that it then passed, unto Samuel Middleton, then treasurer of the |