That your Petitioner as the time [..] being arrested on the Gold coast in Africa delivered to Captain Wicky
the Commander of the Rotterdam Man of Wa [..] which brought your Petitioner to England a List of the Evidences Material
for your Petitioner on the Trial of this Indictment whilst the said Captain Wicky remained on the said Coast, in his Majesties
Service, and requested they may be brought home the said Ship, in order to your Petitioners Trial, and which your Petitioner
humbly begs learve to shew he might have done, had he thought fitt

That in January Session last, an Indictment was preferred and found against your Petitioner on a Special
Commission issued for that purpose pursuant [..] Statute (the offence if any being committed in parts beyond the Seas) to
which your Petitioner pleaded not Guilty but on Account of your Petitioners Witnesses being absent as aforesaid in some of his
Majestys Forts on the Gold coast , his Majestys Attorney General on the part of Government undertook in the same Session to
send out a Ship for them, and the Gramfree Man of [..] was accordingly dispatched and is since returned without them, altho' your
Petitioner delivered at the same time into Court a list of the same Witnesses of which Captain Wicky had before had a Copy, when on
the Coast of Africa , and who your Petitioner verily believes may have been produced, had due diligence been used for that purpose

That the Witnesses named in the said Lists are material and of great Consequence on the part of your Petitioner,
and without whose Testimony he cannot safely take his Spital

That also from the length of time your [..] has been here, he has lost, by Death, one of his Material Witness es (Dorton Ormsby< no role > )
[..] ared to be Dangerous all of which how now [..] to [..]
Court, are facts.

And your Petitioner humbly begs leave [..] her to shew unto this honorable Court that he cannot but consider his case as
uncommonly hard and oppressive, his property having been a most violent manner Seized and Sequested, his Person imprisoned closely in Newgate
upwards of twelve Months his Witnesses who are material prove his Innocence, witheld by Negligence or design, and being entirely in the
power of his prosecutors may be the means of his Imprisonment for Life, the uncertainty of their Arrival being apparently a Letter your Petitioner hath
received a few days ago, from Philip Stephens< no role > Esquire Secretary to the Lords Commissioners of the Admiralty, in the Words and figures following
"Admiralty Office 12th, October 1784

Sir

"In answer to your Letter of the 7th. instant I am Commanded by my Lords Commissioners of the Admiralty to acquaint you that on the
"7th. of May last the Termagant was ordered to proceed to [..] in order to bring to Spithead the Persons you desired as Witnesses to attend your Trial

I am Sir
Your very humble Servant
Pht. Stephens< no role >

Capn . Kenneth Mackenzie< no role >
Newgate

That your Petitioner lastly begs leave to shew unto this Honorable Count that thro' his Sufferings and Confinement together with an Ill
State of Health, and violent Scorbutic and other disorders occasioned thereby your Petitioner hath been very near losing and is now in danger of
his Life and he humbly refers to Mr. Akerman for the Truth of this Assertion

Your Petitioner therefore humbly prays this Honorable Court to take this Case into Considertion and
to admitt him to Bail until the Spial of the said Indictments and until his Evidence shall
Arrives or to afford him such other Relief as the Justice and humanity of his Case requires
and as to this honorable Court shall seem meet

And your Petitioner shall ever pray Etc.

Kenneth Mackenzie< no role >