On board each a Pilot during the time he was engaged in saving said Forester and cargo and whom he had to employ for safety of each vessel. That said Libellant after having succeeded in transferring a part of said cargo from Forester to the Orleans made sail for the city of Apalachicola where he succeeded in bringing said cargo so saved and as soon as practicable returned with Orleans to said Forester still laying outside the bar. That on the tenth day of October the said Libellant with his men as aforesaid succeeded in lightening said schooner Forester and bringing them both alongside the wharf of the City of Apalachicola with the Cargo saved.
That the said Schooner Orleans at the time she went to the assistance of said Forester was in very bad repair, that she was constantly leaking so much so, that the men on board we obliged to have constant resort to her pumps after she commenced taking in said Cargo.
That in going outside said bar to the relief of said Forester she had to encounter a very heavy sea and violent winds which continued during the greater part of the time she was engaged in saving the said Forester and Cargo that the said Orleans was drawing light five feet water and her passage to the said Forester and while laying alongside repeatedly struck hard on the bottom and against said Forester so much so that great danger was thereby increased and the said Libellant was compelled to haul for said Orleans and continued resort had to be made to the pumps.
That said Schooner Orleans was [?] exclusively within the Bay of Apalachicola the mouth of the Apalachicola river that said policy of Insurance did not extend outside the said Bay nor did it allow her to go beyond the bar and that she suffered