Archive:REQ 2/284/30

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Archives > Archive:Probate Records > Archive:Records in The Catalogue > REQ 2/284/30

Sometime probably in mid 1589, Thomas Whitney of Castleton, Herefordshire brought suit against William Watkin Lewis and Evan Lloyd. It seems that about two or three years prior, Thomas had killed Howell Watkins, who was the husband of his brother Nicholas's daughter Margery. Thomas states that it was an unintended consequence that occurred when he and Howell were in an "affray", but William Watkin Lewis, brother of the deceased, claimed that Thomas had intentionally murdered Howell. A trial was held in the Marches of Wales in which a grand jury found Thomas innocent of murder, but it seems guilty of manslaughter.

This case concerns lands in Craswall that Thomas had used to guarantee payment to the family of the deceased. It seems that there was a disagreement on whether the money had been paid, and that William Watkins Lewis and Evan Lloyd had then attempted to take the property. Thomas then brought suit to recover the land. These lands in Craswell are probably the same as those conveyed to Thomas in the 1555 will of his father, Robert Whitney of Castleton.

The folios in this document are numbered in reverse chronological order, with folio 6 being the original complaint, folio 5 an edited copy of 6, folio 4 a demurrer by the defendants, folio 3 the answer of the defendants, folio 2 the replication of the complainant, and folio 1 an edited copy of folio 2. They are listed below in chronological order, rather than numerical order to assist in following the case.

See also various entries in REQ 1/15


Folio 6

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To the Queenes most excellent majestie

01 In his moste humble manner besecheth your maiestie your true and faiethefull subiecte Thomas Whitney of Castleton in the Countie of hereford / That wheras upon a soden __ affraye happened betwixte your said subiect and one Hoell Watkyns deceased __________ 02 03 04 05 06 07 08 09 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 29 30 31 32 33 34 35 36 37 38 39

Folio 5

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To the Queenes Moste Excellent Maiestie

01 In moste humble manner beseacheth your maiestie your true and faythfull subiect Thomas Whitney of Castleton in the Com of Hereford That wheras aboute three yeres paste upon a soden 02 Affraye happenynge betwene your said Subiect and one Hoell Watkins deceased noe former mallice or evyll will before being betweene them in which affraye the said Hoell by his 03 willfull and violent assaultinge of your Subiect receaved a wounde whearas he Languished for a tyme and afterwarde dyed After whose decease Albeit the widdowe and late 04 wiffe of the said Hoell Watkins was by apeale Entytled to call in qwestion the death of her said husband yet _____eles and William Watkin Lewis brother of the said Hoell beinge a 05 Craftie and subtill person and of greate frendes kyndred and alyans within the said Com of Hereford meanyng nought elles save only to extort from your Subiect being fearfull of Suyt some rewarde 06 or brybe did to that end gave out in speeches (though moste untruly) that your said Subiect had willfully murdred the said Hoell Watkins and threatened he would __ the same _____ your subiect 07 to be endicted and attayn_ed of willfull murder for that facte and for that purpose aforesaid shortly after did p__sse____te Jury to and move the corr_n___s enhaveste which wear then sworn impannelled 08 and charged supervise corporis to engwyer of the manner howe the said Hoell Watkins came by his death / to fynd that your subiect hadd willfully murthered the said hoell watkins g__inge 09 in evidens and producing before the said Jurye certen suborned wittnesses of me credyte to sweare the same accordingly and entered to have procured dyvers such other wittnesses to _____ his 10 to ___ whear by your Subiect notwithstanding his Innosonse should have ben drawen (though ___sely) into some danger and hazard of his lyff wheare upon dyvers of your subiectes 11 frendes ernestly advised your Said subiect rather to geve unto the said william watkin lewis a peace of money which was the only stope he shott at rather then by false wittnesses 12 to be brought in hazard to lose both lyff and landes and goodes by which perswasion and the Importenate entreatie of his frendes your said subiect yeelded without any cause or reson to enter 13 into compossicon and agreement with the said william watkin Lewis therby to procure safetie and qwietnes but your said subiect wherupon by mod____ of frendes It was at length 14 agreed betwixt your said subiect & said William Watkin Lewis that your said subiect should __spect of his qwietnes and to avoid trouble in the matters aforesaid satisffie and paye to the said Wm 15 Watkin Lewis the some of a hundred and fety poundes at certen dayes then agreed between them and that __ the assurans of the payment of the said some upon the same day as your said subiect should _______ in

16 mortgage to the said william watkin a tenement of landes of your subjectes called _ayr oyron ... 17 of the purificacion [ torn ] next _________ and to go ther with two sufficient Sureties ... 18 to the said wm w[ torn ]dingly Inconsideracion of all which the premysses It was ... 19 Lewis should [ torn ]ligacion in the some of three hundred poundes with ... 20

21 22 23 24 25

26 27 28 29 30

31 32 33 34 35

36 37 38 39 40

41 42 43 44 45

46 47 48 49 50

51 52 53 54 55

56 57 58

Folio 4

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Septum die Juny Ao R Rna Elizabeth ___ xxxi (7 June 1589)

The demurrer of William Watkin Lewis and Jevan lloyd to the Bill of Complaint of Thomas Whitney.

01 The said defendants by protestacion saye that the said Bill of Complaynt is exhibited against them and eyther of them of malice without any good Cawse or 02 Just matter To thintent to part theis defendantes dwellinge in the Cowntye of hereford on hundred and twentye miles of thereaboute from the Cyttey of Westminster where 03 this honorable Cowert is holden / to great and excessyve Chardge and other troubles and therby Utterlie to ympoveryshe them Whyche they most humblye praie 04 maye be Considered And for plea saye that the said Bill of Complaynt and the matters therein contreyved are altogether insuffycyent in the lawe to be Answered 05 unto, And that neither theis defendantes nor eyther of them are not by lawe nor by thorder of this honorable Cowert Compellable to make any Answere to the said insufficient 06 Bill ffor that aswell the said Complaynant as the said defendant dwell within the precynct of the Jurisdicion of the Lord President and Cownsayll in the marches 07 of Wales, And that yt so appeareth by the shewynge of the said Complaynant in the said Bill of Complaynt And for that also yt appeareth in the said Bill 08 (and so the trueth of the Cause is) that the same matters and causes nowe exhibited and _ferred by the said Complainant in his said Bill to this honorable Cowert have 09 beene heretofore exhamined by the said Lord President and Cownsell in the marches of Wales in Certen suyte dependynge before them in their Court in the said Marches 10 of Wales betweene this defentante and the said Complaynant and thereparcell of the said matters nowe yet paid(?) thye depend there to be hard this paste Trynitye terme 11 in the one and Thyrteth yeare of the Raigne of our Soveragne Ladye the quenes majestie that no__is And for that also the said Complaynant doth confesse 12 in his said Bill of Complaynt that Edward Havard named in the said Bill hath by order taken and made by the said President and Cownsell receved 13 from this defendant Jevan lloyd the possession of the said landes specifeid in the said Bill of Complaynt and therof dispossessed the said defendant Jevan lloyd 14 and so this defendant Jevan lloyd havinge payed the some of one hundred and forty powndes for the said landes specifeid in the said Bill of Complaynt And beinge 15 thereof dispossessed [.... torn ....] the said counsell And the said Complaynant having broken his covenantes in that behalf to this defendant made hath 16 good cawse to [... torn ...]tie of such landes as he hath of the said Complaynant And that he is not by any equitie to be stayed thereof And 17 the _ather for [... torn ...]of the said Causes preferred into this Cowrt depende before the said Lord President and Cownsell in the marches in the 18 of Wales and th[... torn ...]esseth in his said Bill that he cannot have any staye of the said suyte att the Commenlawe by Jurisdicion(?) or other Wyse before 19 the said President[... torn ...]th mainfestiye showeth that he hath no good cause to have any such staye for yfe he hade any good cause to staye 20 the said suytes noe ___[... torn ...] Cownsell beinge a Court of Equitie would staye the same suyte ffor which causes the defendantes demurre in lawe And 21 praye to be dysmyssed with _[... torn ...]able Coste for their J___st vexacion in this behalf.

Folio 3

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The Joynte and Severall Answers of William Watkin lewis and Jevan lloyde to the bill of Complaynte of Thomas Whitney

01 The said defendanntes savinge to them all advantages of excepcione to the ____tentie and insufficiecy of the said bill of complaynte for playne declaracione of the _____ and to lett this moste honorable 02 Corte understande howe wrongfully the said defendants are in this behalf impleadede by the complaynannte, they the said defendantes sayen and eache of them sayethe that the said Complaynante beange __ the said 03 Howell Watkins namede in the said bill mortall malice, Dyd of his pretendede and forfettyde malice att Gytcombe in the said Countie of hereford in or aboute the xxviijth year of the Raigne of our Soveraigne 04 ladye the Queens majestie that now __ not havinge the feare of god before hys eyes, but beinge provokede by the instigatione of the Dyvell most voluntaryly and willfully kill and murder the said howell watkins 05 in moste shamefull and detestable order, After whiche murder so had and perpetradyd the said complaynant knowinge in hys owne conscince that he was giltye thereof fledd the countrye And sayeth that one 06 Margerye daughter to Nicholas Whitney eldest brother to the complaynant was att the tyme of the said murder comyttede wiefe to the said howell watkins and therefore would not in any ____ _____ the appeale 07 agenste the said Complaynante, nor _______ in any sorte for the said murtheringe of her said husbande againste her said unite but within a shorte tyme after the death of her said husbande submytte her ______ 08 the __le govermente or directione of the said complaynante by reasone whereof the said detestable murder was like to have ben alltogether unpunishede And therefore this de__ william watkins brother of the saide 09 Howell Watkins soughte to have the said complaynante indytede of the said willfull and detestable murder and produced for that purpose sundry wittnesses before Thomas greene gent one of the co___ of the saide 10 county of hereford and _yth_rgh lewes associatede to the said coran~ by veartue and forme of the Queens maties comyssione from the Counsell of Wales to the said _yt_ergh in thwt behallf ________ to give evidence 11 to the Jurye before the said coren~ impanellede to enquire supervise corporis after the deathe of the said howell watkins And sayth that the said complaynante yo~ and all the tyme of the said ____ perpetratyde was a 12 gente in the said countie of verye greate and mightie Freendes and kynrede and by reasone there of your orator coulde hardely have due course of lawe ____ntede agenste the said complaynante one Sir James Whitney 13 knighte neere cousen to the said complaynante beinge the same tyme highe shyref of of the said countie of hereford and sawe and well perceavede that doe what he might doe yet was yt ____ like that the saide 14 murder shoulde be clokede uppe and theoffender therein escape unpunishede nevertheles the ffrendes and kinsfolke of the said complaynante made very greate me____ tot he _____________ william watkins 15 in thabsence of the said complaynante and to d__s of this defendantes ffrendes and specially to the said Ivan lloyde thother defendant to have the said offence compromytted to ffrendes and __ ____ and peace made betwene 16 them and other the brothers and sisters of the said howell watkins so murthered as aforesaid and accordinglie and accordinge to an Amounte custome in wales in that behalf ____ __ was agreed betwene 17 the fryndes of the said complaynante and this defendant william watkins that the said complaynante should yealde and paye unto thys defendant william watkins and to _______ watkins and John watkins brothers to the said 18 howell in respecte of the losse of theire said brother and of this defendantes william watkins costes and charges susteynede in the persequtinge of the said murder againste the said complaynante the some of one 19 hundrede and fortie powndes and this defendant william watkins and his said brothers knowinge well the crafte and subtilitie of the said complaynante and howe that he havinge once brought his liffe out of danger 20 woulde seeke all meanes possible to defraude this defendant william and hys said bretherne of suche money or other thinges whiche the said complaynante should p______ to them refusede att the agreemente aforesaid _o take in 21 any sorte of the said complaynante any other assurannce for paymente of the said some but eyther readye money or plate, And therefore the ffreendes of the said complaynante dyd ___ to this defendant Jevan lloyd 22 to disburse the [torn] some unto the other defendant william watkins, and to hys said twoo bretherne Lowes and John for the said complaynante and dyd promise and undertake to this defendant Ivan lloyd that the said complaynante 23 shoulde by suff[ torn ]veyannce and assurance in the lawe conveye and assure the said landes and tenementes specified in the said bill to this defendant Jevan lloyde his heires and assignes forever And shoulde allso enter 24 into good a[ torn ]de in the some of foure hundred powndes for performannce of the said bargayne and waramtie of the said landes and tenementes to this defendant and his heires and assignes forever, And sayth that 25 acordingly [ torn ] lloyde dyd paye unto the said william thother defendant and to his said twoe bretherne lewes and John the some of cxlli and sayth that after this pacificacone the said complaynante returned home 26 and in perfor[ torn ]__pront and promise made by hys ffrendes to thys defendant he the said complaynante dyd convey and assure by ceartayne wryttinges in that behallf made all the said landes and tenementes unto 27 this defendant[ torn ] and assignes forever And dyd covenante that he was rightfull and perfecte owner thereof in fee symple without condicione, And made diverse other covenantes amountinge to severall warantie ageinst 28 all md~n as by th[ torn ] thereof more att lardge mayd a_~ee the ceartaintye of whiche covenantes thys defendant Jevan lloyd not havinge the said wryttinges att the tyme of makinge of thys answere to showe 29 hys counsell _an[ torn ]ly pleade And the said complaynante for performannce of the said covenantes with suche good and sufficiente surtie as the defendant Ivan dyd then like bynde hym and them sellfe unto this complaynante 30 in the some of foure h[ torn ]wndes And the said defendant Jevan lloyde sayth that he beinge in neede of a peace of money to dischardge and paye the said debtes of the said complaynante and to paye unto one davyd thomas 31 willim the some of for[torn]wndes to whom the said complaynante had assured and conveyed the greateste parte of the landes in the bill mencionede in mortgadge for the said some of xlli ____ the defendant Ivan lloyde 32 dyd paye for the said complaynante unto the said Davyd thomas willim the said some of xlli and redeamede the premisses out of his handes before the assurannce made to this defendant Jevan lloyd dyd ca______ 33 suche assurannce and conveyannces as were made upon the said landes unto the said davyd thomas willim for securytie of the said some of xlli, And afterwardes and after thestate so aforsaid made by the 34 said complaynante to this defendant Ivan lloyde dyd upon goodnes of the same his assurannce conveye and assure parcell of the same landes unto the said davyd thomas willim and to his heires forever in mortgadge as aforsaide 35 for xlli and bonnde himsellf with sufficiente surties? in a bonde of lxxxli for the warantyse of the same landes unto the said davyd thomas willim and to his heires forever in mortgadge as aforesaide 36 And this defendant Ivan lloyd sayth that the estate title righte and intereste of the said complaynante att the makinge of the said assurannce was not good nor sufficiente but feeble in lawe as the said complaynante him sellfe 37 Dyd afterwardes in a suyte againste the said complaynante and this defendant Ivan lloyde and others thoccupiers of the same landes brought by Edwarde havard gent ageinste them for the title ________ of the said 38 landes before her maties counsell in wales confesseth and sayth that upon the confessione of the said complaynante before the said counsell made upon the com~te othe_ which confessione thys defendant Ivan lloyde knoweth 39 not whether were made by ffraude or colusion to defeate this defendant Ivan lloyd of the said landes or not but referreth the same to the indg___ of god without any further proffe of precondinges, this defendant Ivan lloyde and hys 40 undertenantes loste the possession of the said landes and the same was ordered by the said counsell to the said Ewarde havard by meanes whereof thios defendant Ivan lloyd havinge loste the said landes and disbursed his said money 41 as ys aforesaid and ys in Danger of the said bonde of lxxxli unto the said Davyd thomas willim ys instely in___uled to hys sutee att the comon lawe as well upon breache of suche covenantes as the said complaynante 42 made to this defendant Ivan lloyd as upon the forfecture of this said bondes whiche this defendant hopeth he instely maye doe without that that yt was agrede that the said defendant william watkins should enter in bande by obligacione 43 in the some of cccli with sufficiente sureties to the said complaynante that he the said william watkins his breetherne, nor kinred nor any of them should persequte or oughte to doe touchinge the said matter ageinste the said 44 complaynante __owe beyt they saye that sythens (i.e. since) the agreemente aforsaid neyther the said william, nor eny of his breetherne kinrede or ffrendes dyd eny further persequte the said murther againste the said complaynante And 45 without that that yt was further agreede that the said defendant william watkins should enter into the said bande for observacione of of the Queens majesties peace ageinste the said complaynante or againste harry pirre? in the 46 bill speciefiede or that the said william watkins should supp~sse canceale or deliver upp to the said complaynante the said deposicions and testimonies in the bill specifiede in maner and forme as in the said bill __ 47 untrewly surmised or that he the said william watkins gave any evidence againste the said complaynante after the composicione passed betwixte the said complaynante and the said defendant william touchinge the said murther And without 48 that the said defendant william watkins dyd promise that he would att hys owne costes and charges procure licence from her highnes counsell in the marches of wales in manner and forme _s moste untrewly in the said bill 49 surmiesed but the said defendantes will avowe and prove that Richard Whitney brother unto the said complaynant dyd promise to sowe further __ome to compounde and agree for the said murther _ordinge to the statute made in 50 Ao xxviijo henri viij in that case provided And without that that the said defendant Jevan lloyd broughte att the requeste of thother defendant william watkins eny indenture or wryttinge tot he complaynante to be seased & delivered to 51 the usee of the said defendant william and his heires ________ __ their to the ___ of the said defendant Ivan lloyd and hys heires forever in fee simple absolutely without any truste for~ the said defendant wm watkins and without 52 that the said defendant Ivan lloyd faythfully assured and promissed to or wth the said complaynante that the said defendant Ivan lloyd would procure the said defendant william watkins to seale and deliver the [ blurred ] obligacione [ blurred ] 53 complaynante used in manerand forme as in the said bill ys moste untrewelie surmisede, or that then the said defendantIvan lloyd dyd promise to reassure the said tenemente and landes tot he said [ blurred ] 54 and forme as in the said bill ys untrewlie surmised and without that that the defendant william watkins ys any suche craftie and subtill persone or one that wholye bestoweth him sellf [ blurred ] 55 of the poore sorte of his neighbors in any suche sorte as in the said bill ys moste fallsely and silannderouselye surmised and without that the said defendant william watkins refused to [torn] the said lande or [blurred] enytyme 56 required thereunto or that the said defendant william watkins contrary to the agreemente att the said nexte affices then helden in the countie of hereford or made eny perseynt ___[torn]he said Affices then and there 57 att all agenste the said complaynante in degree or willfull murther or in any other sorte after the composicione passed or gave eny evidence to the said grannde Jurye but will avowe and prove that he the 58 the said defendant william watkins was not p~_te in the same a____nes and without that the said defendant william watkins procured the said John watkins to assaulte and beate the said harry pr___ Or that the said 59 defendant william watkins receaved the xli in the bill specifid of the said harry aprice in manner and forme as in the said bill ys alledgede And without that that the said defendant william watkins confederated with Edwarde 60 havard gent in the bill namede to make title to the said tenemente and landes to theintent that the complaynante should be in danger of the forfeiture of the said bande of three hundred powndes to the deffendantes And 61 without that that any other thingespecifeid in the said bill and not before _mallye answerede confessed and avoydede traversyde or demode? ys trewe/ All whiche matters these deffendanntes are readye to avowe 62 and ____ ___ this honorable courte will awarde, and praye to be desmyssede with their costes for theire wrongefull vexacione in that behalf susteynede.

Folio 2

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xiiijth die Octobr Ao Rna Elizabeth xxxj

The replicacion of Thomas whitney gent to the wy__t and severall answers of william watkin lewis & Jevan lloyd

01 The said complaynant maynteyneth his bill and the matter therof to be good and true certen and sufficient 02 in the lawe to be answered unto, and saieth that the answer of the said deffendant are untrue, uncerten 03 and insufficient in the lawe to be replied unto, and the same will answer and prove as this 04 honorable cowrte shall adwarde. without that that this complaynante dyd beare any mortall 05 malice to howell watkin in the bill & answers named or did of his pretended or forsetled 06 malice willfullie kill or murder the said howell in any shamefull or detestable order or 07 that this complaynante knewe in his consciens that he was guyltie of the said supposed 08 murder, or en. fledde the countrey, or that margerie wief of the said howell watkins had 09 cause to presennte the appeale for the said supposed murder against this complaynante, or did 10 submytt herself to the rule governement or dyrecion of the complanante, or that the supposed 11 detestable murther was unex~ayed, or that this complaynante is a gentleman of such frindes 12 or kynred as in the answer is surmised, or that by the meanes in thanswer specified the said 13 murder was like to be cloked up in the manner & forme as in the said answer in surmised. And 14 without that that the defendant william watkin lewis or his said brother in the answer named, refused at 15 the supposed agrement therin specified to take of the complaynante any other assurance for payment 16 of the said Cxll therin specifyd, but money or plate, or that the ffrindes of the complaynant did 17 labor to the deffendant Jevann lloyd to disburse the said some unto the deffendant william watkin and to 18 brethren lewis & John in the answer named or to any of them, or did promise or undertake 19 to the deffendant Jevann lloyd that the said complaynante [crossed out] shoulde enter into any bonde 20 in the some of foure hundred poundes or in any other some for _____ man~ne of the said bargane 21 or warrentie of the said landes & tenementes to the defendante Jevann lloyd and to his heires & assigned 22 foren. or that the defendante Jevann lloyd did pay unto the said def william or to his said brethren 23 or to any of them the some of Cxll or any pec_ or parte therof or payd to David Thomas 24 William in the answer named the some of xll> therin specifyd or any parte therof, or redeemeed 25 the promisses ___ of his handes before the assurance made to the defendante Jevann lloyd, or did cancell 26 such assurances or conveyances as were made upon the said landes unto the said David Thomas 27 William, or that the def jevann lloyd bound himself with eny suerties unto the said David Thomas 28 William for warrantie of the said landes unto the said David Thomas wm & to his heires in 29 morgaige in manner & forme as in the said answers are untrulyie declared. And without that 30 that the estate right title or interest of this complaynante at the makinge of the said 31 assurance was not good nor sufficient or was ffeeble int he lawe, or that this complaynante 32 did so confesse in eny sinte before the Connsaill in Wales, or that upon eny such confession 33 there passed eny such order before the said Connsaill as in the answer is surmised, or that there 34 was eny ffrawde or collusion betwine this complaynante & Edward Havard in the answer 35 named to defeate the def Jevann of the premisses, or that the said Jevann lloyd or his under tenantes 36 lost the possession of the premisses by eny lawfull meanes, or that the same was lawfullye 37 ordered to the said Havard, or that the said Jevann lloyd hath lost the said landes, or 38 disbursed the said ______ or eny parte therof or is in danger of eny bond to the said 39 David Thomas Williamm, or is in____ _____ to his said bonde either upon brech of the said 40 covenante, or upon forfecture of the said bond or otherwise in manner & forme as in the 41 said answer is Surmised, and without that that eny thinge ells not_______ & is true 42 All with matters __ ___ _____ demandeth judgement & prayeth as in his Byll C____ 43 he hath prayed

Folio 1

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xxiiijto die Novembr Ao Rna Elizabeth xxxijdo

The replicacion of Thomas Whitney gentleman Complaynante to the Joynte and severall Answers of William Watkin Lewis and Evan lloyde Defendantes

01 The saide Complaynante avoweth Justyfieth and maynteyneth his saide Bill and all & only the matters thearin Conteyned to be true certayn & in the lawe suffyciente 02 and that the Joynte and severall answers of the saide defendantes are very untrue and Insufficient to be answered unto, The benefytt of excepcion to the insufficioncy therof beinge 03 unto this Complaynante saved and reserved for the Replycacion he the same playntiffe sayeth as in his Bill before he hath saied without that this Complaynante did comytt 04 any such murther Kyllinge of the said Howell Watkins in manner as in the said answer is moste untruly alleged And without that this complaynant ever fledd the 05 Contery for the same in manner also as in the said Answers untruly suggested and without that also the appeale for the Death of the saide Howell Watkins was 06 _rbo end to be sued by the Wyddowe and late wife of the said Hoell in respect of any kynred betwene her and this complaynante in such manner as the defendante 07 in their answer have untruly pretended And without that the said defendante William Watkyns for any such cause as in the answers is alleged did take in hande the prossequcion 08 of the same facte againste this Complaynante or did or could produce and honeste or true witnesses for proofe of the facte in any such degree as the defendantes 09 have drawen hit unto Albeit the saide defendante william watkins did by & all synyster And Indirecte meanes Labor and procure to have the offens to be untruly presented 10 and _oward to be murther of sett purpose to entrappe this complaynante and to wreste him thearby to submytt him self to composycion which was the only scope 11 and marke that the defendante ever sought for or required to have, and without that also the playntyffe was a gentleman of so greate frendes and kynred in the 12 saide countye as that by resen therof the said defendantes coulde hardly have due coursse of lawe exected againste this complaynante in maner & forme as _____ 13 saide answers is sirmysed or that by the meanes of Sir James Whytney then being highe Sheeriffe of the said countie of the saide supposed murther was lykely to 14 becloaked upp and to escape unpunisshed in maner also as in the saide answers is alleged; And without that also the frendes of the playntyffe in his absens did make 15 any meanes to the said defendantes of their frendes to have the said supposed offens compromytted to frendes in manner also as in the saide answer is untruly suggested 16 And without that yt was agreed betwene the frendes of this complaynante and the said defendante William Watkins that the said Complaynante should paie unto the saide defendante 17 William Watkins and to Lewis Watkins & John Watkins brothers to the said Howell Watkins in respecte of the losse of their said Brother & of the saide defendante William Watkins charge 18 in the prosse quitinge of the said supposed murther againste this Complaynante the some of one hundred & forty poundes in manner as in the said answer is also alleged And without that 19 the said defendantes did refuse to take any securytie fore the paymente of the saide some but only plate or money or that by reson therof this complaynante or his 20 frende did labore the said defendante Evan lloyd to disburse the said some unto th other defendantes fore the said complaynante or did permyte or undertake to the 21 defendante Evan lloyd that the playntiffe should by suffycient conveyans & assurans in the lawe convey & Assure the saide landes and tenementes tot he saide Evan lloyd 22 his heires & assignes fren~, or should also enter into good and suffycient bond in the some of fowr hundred poundes fore performans of the said bargayn in manner also as in the saide 23 answers is moste untruly alleged And without that the said defendant Evan lloyd did paie accordingly unto the said william th other defendant & this said two bretheren the some of 24 Cxll or any parte therof in manner & forme as is also very untruly alleged. And without that the said Complaynante in performans of the promyse made by his frendes to the saide defendant or fore the 25 causes in the saide answers or in eyther of them alleged did convey and assure all the saide landes & tenementes to the said Evan lloyd in manner also as in the said answers is very falsly alleged 26 And without that the said defendant Evan lloyd being in neede of a peece of money to discharge & paid the dette of this complaynante or to paie one David Thomas William the some of forty poundes 27 did assure and convey the greateste part of the said landes in mortgage fore the said some of Xl? of that the said defendant Evan lloyd did paie fore the redemcion of the said landes the said __ty 28 poundes fore the said complaynant in mannew as in the said answers in very untruly alleged And without that after the estate soe made by this complaynant to the said defendant 29 Evan lloyd he did uppon goodnes of the same his assurans convey & assure parcell of the said landes unto the said David Thomas William and his heires forever in mortgage 30 for fortie poundes of bonnd him self & sufficient sureties in a bond of fower score poundes for the waranties of the same landes but the said David Thomas William in manner also 31 as is in the said answers is very falsly syrmysed And without that this complaynante did confesse before the counsell of the Marches that his tytle was not 32 good or that by meanes thereof loste the possession of the saide landes or that the saide defendante is __s_ely Intytuled to his suyt at the common lawe againste this 33 complaynant in manner as in the said answers is very fryvolently surmysed And without that that any thinge elles in the said answers contayned matters all 34 or effect_ all to be replyed unto and herein not suffycyently replyed but confessed and avoyded traversed or denyed is true All which matters to 35 this compllaynantes layment is redy to avow & parove as this court shall award, And prayeth as be_ed in his Bill he hath prayed.

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