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Contents Page > 1618 Chancery Petition: Robert Barker v Bonham Norton And John Bill > (2) The Reply Of Bonham Norton And John Bill
 

C2/JASI/B17/56   [IMAGE]

 

1618 CHANCERY PETITION: ROBERT BARKER v BONHAM NORTON & JOHN BILL  •  DOWNLOAD PETITION (PDF 328 KB)

 

(2) THE REPLY OF BONHAM NORTON AND JOHN BILL [Endorsed] vterque iurat xiiio die maij 1618 Richard Moores Clapham Sr

 

 

 

The Ioynte and seuerall Answeares of Bonham Norton And John Bill Defendants

To the Bill of Complainte of Robert Barker Complainant

 

1.  The defendants sainge vnto them selues nowe and at all times hereafter all and all manner of Aduantages of Exception to the manifould imperfections contraieties and vncertainties of the said Bill for A full and direct answeare to all and euerie the materiall things therein conteined doe ioyntly and seuerally Answeare as followeth |

2.  And first the said Bonham Norton sayeth that about ffive yeares since or somewhat more the said Complainant did verie often and earnestly treate wth him the said Bonham Norton for A match or Contract of mariage to be had made and solemnized by and betwene the said Christofer Barker the said Complainants sonne in the Bill |

3.  mencioned and Sara Norton one of his the said Bonham Nortons daughters And for the Effectuatinge of the said match the said Complainant made many profers to the said Bonham Norton vnto wch motions soe made the said Bonham Norton supposing then that the said Complainant was of a better estate then [2 words illegible] |

4.  to be And that he would truly and faithfully performe his promises in that behalf made did at length Condescend and agree that the said Χρofer Barker should marie <marrye> or take to wief the said Sara And it was agreed by and betewene ye said Complainant and the said Bonham Norton that the said Complainant [word illegible] |

5.  the said mariage soe had made and solemised by and betwixt the said Χρofer and Sara as aforesaid by good and sufficient Conuenants in the Lawe graunt Conuey and assure vnto the said Bonham Norton and others his friends to be nominated by him diuerse Leases of Lands to the ?ioynturshippe [word illegible] |

6.  amountinge to the Cleere yearly valewe of 400li per annum, and alsoe by like good conueniance to graunte assign assure and estate the Inheritance of diuerse and sundrie the lands of the said Complainant vppon the said Christofer and Sara and the heires of their two bodies And likewise to graunte commit |

7.  and assign as aforsaid to some persons to the vse of the said Christofer certaine Leases for tearme of yeares then and nowe in-duringe wch the said Complainant then had of the tithes of datchett and of the fishinge there and of a house Called northumberland house Situated and being in St Martinns Lane |

8.  And whereas the said Complainant had procured from his matie att his Coste and Charge a graunte in reuersion of the Office [word illegible] of his Mats Printer vnto the said Christofer Barker during the naturall lief of him the said Christofer to Comence after the death of the said Complainant who had a former estate in the |

9.  said Office duringe his the said Complainants lief the said Complainant was vppon the said Inter mariage to release to the said Χρofer all such right vse truste and confidence wch he had or could haue or claime to the said Office soe graunted in reuersõn as aforesaid And alsoe the said Complainant |

10.  was to assigne or Conuey vnto the said Χρofer all the implements goods Chattles and other things belonginge to his the said Complainants then Printinge house or office of printinge to haue the same after the death of the said Complainant And the said Complainant did further agree to and wth the said Bonham Norton also |

11.  diuerse others to paye yearly vnto the said Χρofer Barker duringe his the said Complainants naturall lief 400li of good and lawfull money of England at the fower vsuall feasts in the yeere by euen portions, And after the first 3 yeeres next and imediatly ensuinge the said Inter mariage to |

12.  pay ouer and besides the said 400li anuitie as afore said 100li anuitie more of like lawfull money of England duringe the naturall lief of the said Complainant, the same to be paid likewise at the ffower vsuall feasts by euen portions as aforesaid vppon wch Covenants and Condicons to be performed once the |

13.  Complainants parte the said defendant Bonham Norton promised to giue in mariage wth his said daughter 1600li portion out of his owne estate beside 200li wch was left her as a legasie the said 1800li to be paid in maner followinge viz 800li thereof vppon the mariage day as the assignments were made |

14.  of all and singulor the premises before mencõned to be performed on the Complainants parte in respect of the said mariage asforesaid and 500li to be paid that day twelue moneth after the mariage and Assurance as a fore said And the residue one yeare after the said day of payment as a fore said vpon |

15.  these promises and agreements his said daughter was to his greate grief as the sequell nowe proueth maried about three yeares since to the said Χρofer Barker And this defendant confesseth that the said Complainant hath passed vnto him the said Bonham Norton and some others diuerse Leases to and for the |

16.  Iointer of the said Sara But as this defendant is informed the lands not Conueyed as aforesaid are not of that Cliere yearly valwe of 400li per annum as was Couenanted Besides this defendant feareth that the said lands soe Conuyed as afore said are much incumbred by reason of the |

17.  Complainants many ingagments for greate sommes of money and other wayes <And> besides the said Complainant hath not made payments of the said annuities of 400li per annum and <of> one hundred pounds more per annum after the said first 3 yeares after the intermariage as afore said as this defendant hath bene informed |

18.  both by his sonne in Law and daughter and as he verily beleeueth And <this defendant  saith that since the said marriadge> in default of meanes for their maintenance this defendant Bonham Norton hath supplied the necessarie wants and occasions of his said sonne in law and daughter diuerse times then word illegible neither hath the said Complainant |

19.  performed diuerse other of his promises and Couenants agreed and condiscended to by him vppon the treatie of the said mariage And although that in respect thereof this defendant as he hopeth is not bound to make payemente of the said sommes of money soe giuen and [conjectural: set out for] |

20.  his <his> daughters portion as is afore said yet not wth standinge he hath since that time viz vpon the 20th of october 1615 paied to Thomas Bennett of London Alderman 1666li 13s 4d for the true sale and proper debt of the said Complainants in parte of his the said |

21.  defendant daughters portion And for the residue of the said 1800li this defendant Bonham Norton hath bene and wilbe readie to make paymente thereof when and as soone as the said Complainant shall and will performe all and singuler the conuenants on his the said Complainants parte to be |

22.  performed as afore said and vntill that time the defendant hopeth that he shall not be enioyned to disburse any more, in respect of the said mariage espetially seaing the said Complainant hath since the same intermariage taken such Courses and meanes to ingage and disable the said Christofer Barker [word illegible] |

23.  this Defendant hath most iust Course to feare that the same will tend to the vtter ouerthrowe and Ruine of the said Christofer Barker and of this the said defendants daughter and of their Issue if they shall haue any and as touchinge the Jewells and the valewe of their mencõned in the said |

24.  Bill of Complainte giuen by the said Complainant, to the said Defendants daughter he this Defendant Bonham Norton confesseth that before the said intermariage the said Complainant bestowed some Jewells vpon her wch the said Complainant did vse as baytes to drawe good liking to his sonne [words illegible] |

25.  valewe of them the defendant verilye beleueth that they are not woorth the 3d parte of that whereat the said Complainant estimates them And as concerninge the 6000li pretended by the bill to be giuen since the said intermariage by the said Complainant to the said Christofer Barker for the aduantage [2 words illegible] |

26.  maintenance of him and his wief this defendant verily beleeueth that it is a most false suggestion and hath not soe much as any Color or shewe of any probabilite or truth and these defendants ioyntly and seuerally say that true it is that the late Queene Elizabeth did for diuerse yeares since graunt |

27.  vnto the said Complainant for tearme of his naturall life the office of printer vnto the said late Queene her heires & sucessors by her Letters Pattente vnder the greate seale of England And that the Kings most excellent Matie that nowe is did some yeares since by his letters Pattente vnder the greate seale of England |

28.  grant vnto the said Χρofer Barker the said Office of his Mats Printer for and duringe his naturall leif in reuersion after the death of the said Complainant as is before aledged And that afterwards of late yeares the said Kings most excellent matie did by his Letters Pattente vnder the greate seale of England |

29.  graunte vnto Robert Barker the said Complainants sonne mencioned in the bill the said office of his Mats said Printer in reuersion for diuerse yeares after the expiracõn of the <2> former Pattentes of the said Office, and these defendants doe beleeue that the said seuerall graunts as afore said made by the kings most excellent matie then that now is vnto the said |

30.  Complainants sonnes as afore said were procured and obteined by the said Complainant of his matie that nowe is And the said defendants doe further ioyntly and seuerally say that after the said intermariage soe had as a fore said about 3 yeares since as these defendants doe nowe remember the said Complainant often times instanced [word illegible] sayd defendants [word illegible] of him |

31.  the said Complainant all his the said Complainants estate right title and interest of in and to the office of the said Printer wch he the said Complainant had by vertue of the said late Queenes Letteres pattents soe made to him as aforesaid amongst diuerse other things belonginge to and vsed wth the said office, desiringe these defendants to admit and |

32.  take into their Copartnership touchinge the said office the said Χρofer Barker wch they accordingly did and for the said Complainants estate and vppon a promise from the said Χρofer that if the sayd Χρofer should happen to surviue the said Complainant that then the said defendants duringe their liues should enioy two partes of the said office in three partes to  |

33.  be deuided duringe the said Χρofers leif if the said defendants or either of them liued soe longe They the said defendants did well and truely pay vnto the said Complainant 5000li of good and lawfull money of England at seuerall dayes wthin one yeare accordingly as the same was appointed to be paid <[words illegible]> And vppon the said sale the said [3 words illegible]  |

34.  correct Courses procure out of the ioynte Stock of the said Office diuerse sommes of money and other goods to the somme and valewe of aboue 300li And afterwards for 2 yeares or thereabouts the said defendants and the said Χρfer Barker traded together in Copartnership in managinge performinge exercisinge the said office |

35.  wherein the said defendants did from time to time supplie the said Χρofer wth money out of their priuate estates for the makinge vp of his the said Χρofers proportionable parte of the stock wch was vsed in the said Copartnershipp And from time to time as long as the said Copartnership endured before the said [2  words illegible] |

36.  said Χρofer they made and gaue vnto him weekly a true and iust accompt touchinge the said Copartnershipp and afterwards vpon a iust and true accompt the Χρofer was found in debt 600li for his proportionable 3d parte of the said ioynte stocke wch ?moneys afterwards the said defendants [4 words illegible] |

37.  of others vppon the bonds of him the said Χρofer and of these defendants wch, the said defendants <afterwards> afterwards payed [20 words illegible] And the said sale of the said office  so made by the said Robert Barker [2 words illegible] |

38.  was absolutely and freely made by the said Complainant for the Consideracon before expressed wthout any Condicõn limitacõn vse or trust whatsoeuer and after <afterwards> wards about one yeare since the said Χρofer Barker beinge ingaged by the said Complainant in diuerse greate sommes of money for the said Complainants debts and the said Complainants |

39.  beinge likewise much indebted to diuerse persons in greate sommes of money, he the said Complaianant and the said Χρofer and Robert Barker the said Complainants sonnes did proffer vnto diuerse persons to graunte and passe away vnto them all their Ioynte and seuerall estates rights titles interests and [4 words illegible] |

40.  said Office of his Maties Printer by vertue of <all and the aforesaid euery the aforesaid> the said seuerall letters Pattents [3 words illegible] aforesaid together wth the sale of all implements and things belonginge to the said office And the lease of the said house Called northumberland house and also the stock which the said Χρofer Barker had And [3 words illegible] |

41.  at the time of the said sale in the said Copartnership wch they refusinge then the same was proferred to the defendants And vpon the first proferringe thereof to the said defendants they were verie vnwillinge to enter into any treatie or Comunicacõn about it But afterwards the defendant Bonham Norton vnderstandinge |

42.  that the said Χρofer was ingaged for his father aboue 5000li in debts and perswadinge himself that these things so proferred to sale as aforesaid would be <a> meane to free his said sonne in Lawe out of debt These defendants after many intreaties made on the [word illegible]<word illegible> of the said Complainant were contented to |

43.  enter into a treatie and Comunicacõn about the same and after diuerse parties <parlies> betwene the said defendant Bonham Norton and the said Complainant [3 words illegible] said defendant Bonham Norton sayth that about the beginninge of July last as he nowe remembreth he made a full and absolute agreement to and |

44.  [word illegible] the said Complainant and his said sonnes for and Concerninge the premisses offered to be sould as aforesaid for and in the name and behalf of the said Bonham Norton and the other defendant John Bill wthout any Condition vse or trust or confidence And it was agreed then [3 words illegible] |

45.   [word illegible] these defendants should discharge the said Complainant of 200li wch then he Owed the said John Bill And that they should discharge Χρofer Barker of 200li wch he owed vnto the stock of Copartnershipp [7 words illegible] [word illegible] should <that the [word illegible]> [word illegible] |

46.  Complainant <for the some> 6500li in manner followinge Viz: 1500li vppon the passinge <of> the Conueyance wch was intended and agreed to be made wth all Conuenient speede And 1000li vppon the feaste of All Saints then next ensuinge And 200li on the first of may last past And 200li vpon [3 words illegible] |

47.  feaste of all Sts next and imediatly ensuinge and this Contract or agreemente was sett downe in writinge or Articles of Agreemente and the one parte of the said writinge or Articles of agreement was signed by the said Complainant and his said sonnes and the other parte concerninge vnto the said [word illegible] |

48.  [word illegible] by him the said Bonham Norton And in the sayd Articles of agreemente there is no word nor mencõn of any Condition vse truste Confidence And the said defendant Bonham Norton saith that it was agreed vppon the said last menõned contract between the Complainant [words illegible] |

49.  and Χρofer amongst diuers other things that the debts wherein Christofer Barker was ingaged for the said Complainant together wth some of his owne proper debts should be discharged and payed out of the said 6500li And these defendants further say that afterwards viz vpon the 20th day of Nouember last past [word illegible] |

50.  the Complainant and his said sonnes did by their debts indented vnder their hands and sealed ioyntly and seueraly ffreely absolutly wthout any condition vse trust confidence or limitacion graunt Assign and Conuey vnto the said defendants <all> and singuler their parte and seuerall estates rights [5 words illegible] |

51.  [word illegible] and to all and singuler the premisses before offered to be sould as aforesaid As in and by the said deeded Indentures more fully and at large apeareth vnto wch these defendants touchinge the said sale refer them selues And these defendants further say that before the date of the said ?Deed [4 words illegible] |

52.  said defendants or one of them had payed or caused to be payed vnto the said Complainant and diuerse other persons for his the said Complainants and the said Christofers debts the sum of 2562li 14s 2d the particulers whereof the said defendants at the time of the said Assignment gaue and deliuered vnto the said Complainant and his sonne  |

53.  [word illegible] And the same accompt and payments so made by the said defendants as aforesaid was then accepted of and allowed, and at the same time there was deliverd vnto the said Complainant such bonds of his and his said sone Christophers wch the said defendants had payed and discharged And these defendants further say that since [2 words illegible] |

54.  [word illegible] of nouember last past they the said defendants or one of them gaue payed or caused to be paied vnto diuerse persons heareafter particulerly named to and for the vse and behoofe of the said Complainant & the said Χρofers sonne or one of them or otherwise sufficiently discharged the said Complainant and the said [3 words illegible] |

55.  either of them of those somes of money and debts hereafter followinge viz: paid to Christofer Barker about Christmas last 21li 3s 7d Item paid to the said Complainants wief by the Complainants direction in and vpon the 22th day of Nouember last past 100li Item paid to the said Christofer Barker by [4 words illegible] |

56.  ?the ?xviith of December laste 100li Item paid to Mr Bankwoorth in Nouember laste 50li To Sr William Crauen in December last 75li Item the said Χρofer Barker is discharged of a debt of 635li wch the said Χρofer owed mr ?Durie Item paid to the executor of one ?Cap[---]  ?6li -1s -?d Item paid to |

57.  [---]well Bishopp 110li -2s-6d Item paid to Mr ?Beanion 110li-2s-6d Item paid to Mr Watson 109li-7s-6d Item the said Complainant is discharged of a debt of 224li-15s-6d wch he owed vnto one Mr ?Roland Item paid to Mtres Handes nowe the Ladie Burton 227li-15s-6d Item the said Complainant and his sone Χρofer are |

58.  discharged of a debt of 230li owinge by them to one Mr Weststrowe Item paid to Henrie Carter 112li-11s-4d Item <Item> these defendants have vndertaken forthwth to satisfie Sr Tho: Contele of a debt of 218li-6s-8d wch the said Complainant owed him whose promise in [word illegible] behalf  the said Sr [word illegible] |

59.  Thomas Co<n>tele hath accepted Item paid to Coghill 112li-15s-6d. Item  paid to Mtres Turner 110li Item the said Complainant is is discharged of a debt of 238li-18s-4d for a debt <being for> soe much owinge by him to Mr Wall Item paid to Mr Bankwoorth the 12 day of this month this May 50li ?s ?d the said [word illegible] |

60.  Complainant oweth vnto these defendants for bookes 8li 10s ?8d Item paid for Charges in Lawe Concerninge some actions brought against the said Complainant and his sonne or one of them and for things vpon Attachments 9li-16s-5d Item paid to the said Χρofer Barker the 16th of December last 20 [3 words illegible] |

61.  [word illegible] 8 of Januarie last 20li paid to him more the 10th of ffebruarie last 20li Item these defendants craue allowance vpon this their accompt after the rate of xli per Centum for payinge diuerse the sones debts before the day <of payment> at wch these defendants ought to make payment [word illegible] |

62.  according to the said agreemente wch allowances the Complainant promised them to make and after that sale the allowance comes to 15li or thereabouts Item the said defendants have vndertaken to pay to the ladie Harte 200li presently for soe much debt the said Complainant oweth her if the said Complainant |

63.  will give them directions to doe the same wch the ladie Hart hath accepted: all wch sommes of money <paid since the said 20th Nouember last> owes ?unto 3259li 16s 4d soe that the said defendants haue paid of the said 6500li to be payde for the said Office and stock the premisses as afore said 5822li 10s 6d great parte thereof beinge ï

64.  paid before the said dayes of paymente for the said Office and other the premisses as afore said And the said defendants doe further say that the said Complainant hath as those defendants imagine acknowledged a Tolerable debt of ?5080 unto the said Robert Barker the said Complainants sonne and one Christopher ï

65.  who haue of late Caused the said debt to be attached in the said defendants hands accordinge to the [word illegible] Custome of the said Cittie of London And the said defendant John Bill saith that about Easter last past hauinge bene formerly entreated to come vnto the said Complainants house to confer with him about some business he the said John Bill came to the sayd Complainants house to confer ï

66.  with him about some business he the said John Bill came to the sayd Complainants house And there after many speeches passed betwixt him and the said Complainant concerninge What disbursments had beene made for the said Complainant and his sonne Xrofer by those defendants as also touching some money [word illegible] ï

67.  [word illegible] said Complainant desired the said defendant John Bill to pay vnto him to supplie his wants promisinge that it should goe in parte of paymente of the remainder of the said 6500li And that he the said Complainant would allowe for the payinge before the day, he the sayd John Bill answerd to this purpose ï   

68.  that he would shortly meete wth the said Complainant if he pleases and bringe vnto him an accompt in particuler of what had bene paid And would then make him  an answeare what money he would pay him before the day and vpon what Condicõns he would doe the same And accordingly wthin [word illegible] |

69.  [word illegible] afterwards viz in Easter week last the said defendant John Bill mett the said Complainant and diuerse of his friends and there acqainted him the said Complainant in particulers wthmoste of the aforesaid disbursments And shewed vnto him the said Complainante his the said Complainants and his sonne Χρofers bondes wch |

70.  were taken vp vppon the discharginge of the said debts And the disbursments then soe made and particulerly shewed vnto him the said Complainant as aforesaid did amount vnto aboue 5000li as he the said John Bill nowe remembreth and at that time the Complainant acknowledged the said particluler debts so paid for him and his said sonne Χρofer as aforesaid |

71.  were the true and proper debts of him the said Complainant and his said sonne or one of them Only he then tooke exception that some fewe of the said debts were payed wthout his speticall warrante in that behalf And that he was <then> contented to allowe thereof if he might haue 500li  in parte of payment of the remainder of the said 6500li promisinge to allowe and |

72.  Condicõn for the paymente of the said 500li before the day And this defendant John Bill then offered the said Complainant that if the said Complainant would discharge him the said John Bill of the debts wherein he stad bound for the him the said Complainant all the residue of the sayd 6500li should be presently paid him allowinge him Consideracõn |

73.  [2 words illegible] paid before the day and the said Complainant beinge then not able to discharge the said debts wherein he <he> the said John Bill stood <bounde> for him as aforesaid he the said John Bill was contented vppon the said Complainants earnest entreaty to pay vnto him wthin a short <short> time 300li or thereabouts in parte of payments of the [word illegible] |

74.  remainder of the said six thousand fiue hundred pounds hauinge allowance for the payments before the day as aforesd And afterwards the said John Bill sent vnto the said Complainant a letter wherein was set downe the particulers of the accompts to that day wch accompts the said defendant John ê

75.  Bill made vp and sent in the absence of the said other defendant Bonham Norton who for the most parte dealt in that Busines and therefore the said John Bill added a prouisoe or Clause in his said Accompt to adde to the accompt or defaulte from the sonne if ?their [word illegible] ?first |

76.  [word illegible] since wch time the defendants haue payed more sommes of money for him the said Complainant and by the Complainants direction as is before mencõned And these defendants further say that before the said deede indented was sealed and deliuered as aforesaid the same was shewed [word illegible] |

77.  [word illegible] Complainants direction to one Mr Banckwoorth A Scrivener of London to whose Care and trust as it seemed, the said Complainant comitted the pervsall thereof wch the said Mr Bankwoorth pervsinge, Certified the Complainant as these defendants are informed that the some was [word illegible] |

78.  [3 words illegible] ?more and therevpon afterwards the same was sealed and deliuered as aforesd together wth A Bond on the graunt as parte of 3000li for performance of Couenants on their partes and these defendants say that they take it they [word illegible] |

79.  [2 words illegible] consent sett forth what the vallew of those things are wch they for vallewable Consideracõns haue absolutly wthout any Condicõn vse trust or limitacõn bought Neither are they bonds as they Conceiue  in Lawe to set fforth what ?promisses they have ?made ?since |

80.  [2 words illegible] soe to get Neither indeed can they sett fforth the vallewe of the said office, for it stands vppon a greate number of particularities & Casuallyties <casualties> And hithertoo the said deffendants haue not receiued any profitt by itt but are at greate losse |

81.  [3 words illegible] Complainant had ill managed the said Office when he had the disposall of it. And the said defendant John Bill denieth that euer he made any such protestacõn vppon his knees,  or that he had any such power ouer the said Bonham Norton |

82.  [2 words illegible] vsed any such threateninge speeches to the said Complainant Or vsed such speeches of the said Christofer to his remembrance as is most falslye and friuolusly alleadged And the said John Bill Confesseth that whereas he [word illegible]  together  |

83.  [2 words illegible] Complainant and his sonne Χρofer in an Obligacõn vnto the said Weste owe in fower hundred pounds for the payment of 210li due the 3d of ffebruarie 1616 wch was for the true sole and proper debt of the said Complainant |

84.  [4 words illegible] or one of them, and whereas he the said John Bill and the said Bonham Norton stood bound with the said Christofer Barker to the said ducie in 1000li for the payment of 630li vppon the 25th |

85.  [2 words illegible] Nouember 1617 beinge for the true sole and proper debte of the said Christofer and whereas for the first Somme John Bill had A Counter bond from the said Complainant [word illegible] said sonne to saue him ?harmlesse |

86.  and for the other the said defendants had a Counterbond from the said Christofer to saue them harmlesse, and whereas since that time neither the said Complainant & his sonne or either of them haue satisfied the said debts [word illegible] |

87.  Bill [2 words illegible] said all Attachments to be made in his & the other defendants hands for the discharge of the said seuerall debts and therevpon Iudgments are giuen And the said Bonham Norton for himself sayeth that he [word illegible] |

88.  [2 words illegible] from the said Christofer to pay his debts vnto his Creditors whereof and Mr ?Carter And one Mtres Turner were some, who cominge to this defendant Bonham Norton for the seuerall debts owinge them by the said [word illegible] |

89.  he the said Bonham Norton beinge doubtfull what was best for him to doe in this Case wente too, and acquainted one Mr Stonne who was of his Counsell therewth who aduised so for his more securitite [word illegible] |

90.  [5 words illegible] seuerally to attach the said debts in the hands of the said defendants accordinge wthe Custome of the Citie of London, wch aduise he this defendant [word illegible] might knowe after wards [2 words illegible] |

91.  [9 words illegible] for the said debt And therevpon they made seuerall Attachments in the said defendants hands and had seuerall Iudgmentes therevppon And the said [2 words illegible] |

92.  [6 words illegible] in the former accompt And this defendant Bonham Norton sayeth that he neuer made any such promise to giue 2000li to the said Complainant as a portion in marriage [2 words illegible] |

93.  [2 words illegible] falsley alleadged in the said Bill neither did he promise that his sayd daughter should haue for her portion in mariage the said 200li legacie in any otherwise than wth the 1600l as is [word illegible] |

94.  [4 words illegible] the said Χρofer out of dores refused at any time to shewe vnto the said Christofer any Accompts Touchinge the said Copartnershipp duringe the time of their tradinge together [word illegible] |

95.  [3 words illegible] And the said defendants denie that there was at any time duringe the said Copartnership any wronge hard or vniust dealinge offered to the said Χρofer by the said defendants or any [3 words illegible] |

96.  [3 words illegible] falsly alleadged in the said Bill or that they promised vpon the said last Contract or at any times before or after the said Contract that they would pay [2 words illegible] |

97.  [3 words illegible] of Stationers as is pretended in the bill And the said Bonham Norton denith that he perswaded his said sonne in Lawe to perswade the sayd Complainant to sell vnto him [3 words illegible] |

98.  [2 words illegible] Office and premisses as aforesaid Or that he made any promise vnto his said sonne in lawe to perswade the said Complainant to doe the same as is alledged in the Bill Neither did he [4 words illegible] |

99.  [word illegible] in Lawe Conceale from the said Complainant any hard measure wch he the said defendant had offered vnto his said sonne in Lawe as is most falslye suggested ?neuer ?haue the said defendants [word illegible] |

100.  [2 words illegible] any such speeches as <are> layde downe in the Bill And these defendants say that true it is that the said Complainant wth in some shorte time after the said sale so made by the sayd Complainant and his sonnes as afore said |

101.  [3 words illegible] of his Mansion house Burnt But they doe not beleeue that any writings touchinge any of the agreement or Contracts mensioned in the said Bill, were thereby burnt And these defendants are |

102.  [word illegible] to giue vnto the said Complainant true Coppies of all and euerie such writinges whatsoeuer in their Custodie or wch they <can> [word erased] Come by <wth a sayle in law> wch doe in anywise Concerne any matter or thinge layde [2 words illegible] |

103.  [word illegible] that the Complainant wilbe at the Charges of the Coppying thereof Wthout that that they <did> discurage or diuert any from dealinge wth the said Office, And wthout that that the sayd Office wth the |

104.  [2 words illegible] furniture was worth 30000l And wthout that that they promised to be true Accomptantes vnto the said Complainant and his said sonne Χρofer of all the profitts of the sayd office [2 words illegible] |

105.  lands of the said Complainant and his sonne Χρofer and the longest liuer of them And wthout that that they promised and agreed at any time that after the ?sealing up of the said Bargaine the [word illegible] |

106.  [3 words illegible] yere and a day after the Assiginge of the said Office give a true Accompt to the said Complainant for all recknings betwene them and of the said yeares profitt of the same Office |

107.  [2 words illegible] ?satisfie the said Complainant and his sonnes to make their best benefitt thereof And wthout that that they made any promise to giue accompt vnto the said Complainant and his sonne Χρofer of the |

108.  proffitts of the <last> office from the time of the said Contract or Articles of agreement, vntill the <said> Assignemente soe made, And wthout that that they [word illegible] made any repeticion of false |

109.  resitall of the said assignement, and wthout that that he the sayd Complainant and his sonnes sealed the said <last> Assignemente wthout readinge it [severall words illegible] And [word illegible] out |

110.  that that the said Indenture of <the said> Assignemente was sealed by the said Complainant and his said Sonnes vppon trust <or> and Confidence, And wthout that that they haue refused to pay [word illegible] |

111.  such monies as are due vnto the said Complainant and to his sonnes And wthout that that they practised wth any person or sought any to make attachments in London of any Sommes of money in their |

112.  handes and suffered Iudgments in the said Attachments other and in other wise, manner, and forme then is before in that behalf expressed by the said defendants seuerally as afore-sd And wthout |

113.  that that they haue defaulted out any sommes of money Colorablie pretendinge the same to be due when they are not And wthout that that they haue or doe refuse to performe the true |

114.  meaninge of such promises and agreements as they haue made And wthout that that they made Anye promise to reasigne wthin one yeare & a day the said Office & stock & furniture |

115.  therevnto belonginge or any of them vnto the said Complainant and his sonnes or any of them And wthout that that they haue Conspired to damnifie or descredit the said Complainant [word illegible] |

116.  and wthout that that the said Complainant [word illegible] And his sonnes Can make 10000li [word illegible]and vpwards of the said office more than the said deffendants paid for the same And wthout that that |

117.  any other matter or thinge mencõned or Contained in the said Bill of Complaint intreatie for these defendants or either of them to Answeare vnto before not denied |

118.  trauersed Confessed and avoyded is true, and these Defendants doe pray to be dismissed out of this honorable Court wth their Costs and Charges in that behalf expended |

119.  and susteined

 Henden

 

 

[FINIS]

 

 

 

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