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Contents Page > 1618 Chancery Petition: Robert Barker v Bonham Norton And John Bill > (3) Robert Barker's Replication
 

C2/JASI/B17/56   [IMAGE]

 

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

 

(3)  Robert Barker’s Replication

 

 

The Replicacõn of Robert Barker esquier complainant to the said answeres

of Bonham Norton ï & John Bill defendant

 

1.  The sayd Complainant for replycacõn sayeth that he will averr maintaine & proue his said bill of Complaint into this honorable Court exhibited & euery matter & thinge |

2.  therein conteyned to be certaine true & sufficient in the lawe to be answered vnto by the defendants & devised & exhibited into this honorable Court vpon good & iust |

3.  cause of suite as in & by the said bill of complaint is most truly sett forth & alledged And  this complainant further sayeth that the sayd answere of the sayd defendants is very uncertaine |

4.  vntrue & insufficient in the law to be replied vnto Neverthelesse the aduantage of excepcõn to the manifest incerteinetyes & insufficiencye there of to this complainant nowe |

5.  & at all times hereafter saved for further replicacõn there vnto sayeth in all & euery thinge as in his sayd bill of complaint he hath allready sayed wth this that this Complainants |

6.  estate is farr the worse by the defendants harde dealings & theirs farr <better> & much raysed by this complainant & that  this defendant hath performed the ioynture wch was agreed vppon |

7.  & this complainant hopeth to make it appeare that the ioynture wch this complainant hath made vnto the sayd Bonham Nortons said daughter doth farr exceed the porcõn |

8.  wch the said defendant Norton hath or did either paye or promise vnto this complainant in marriage wth his sayd daughter, wth this that this complainant vpon latter agreements did paye |

9.  for the said Christopher & to his vse greate summs of monye in lieu & recompence of the said tithes & fishinge & of the sayd house  called Northumberland house |

10.  & wth this that the lands conveyed in ioynture vnto the sayd defendant Nortons daughter are aboue the cleere yearely valewe of foure hundred pounds per annum accordinge |

11.  as was promised or covenanted & this complainant hath payed & allowed vnto the said Christopher for his & his sayd wifes maintainence aboue fiue hundred pounds per annum And |

12.  this complainant sayeth that in respect of one thousand sixtye sixe pounds thirteene shillings foure pence payed payed  vnto Thomas Bennett of London alderman this |

13.  complainant hath given vnto the sayd defendant Nortons daughter before & since her marriage wth the sayd Christopher this complainant sonn divers iewells & other things amountinge to |

14.  aboue foureteene pounds or fifteene hundred pounds by wch meanes this complainant hath gott by the sayd Norton in respect of the sayd marriage three or foure hundred |

15.  pounds <?like then nothing besides one hundred pounds> per annum  wch this complainant allso gaue at the sayd Nortons request during this complainants & his wiues life & yett this complainant will bee contented to repaye the sayd one |

16.  thousand three score & sixe pounds sixteen shillings & foure pence vnto the sayd defendant Norton if soe be the said Norton will reassigne the said ioynture & this |

17.  complainant will keepe the sayd Nortons daughter gratis in good sorte like his sonns wife & this complainant sayeth that he did not give any direction to haue the said |

18.  deed indented shewed vnto the sayd Mr Bankworth neither doth this Complainant knowe howe he liked the same wthout that that any other matter or |

19.  thing matteriall for this Complainant to replie vnto & not herein & hereby sufficiently replyed vnto confessed or avoyded traversed or denied is true All |

20.  wch this complainant is ready to averr & proue as this honorable Court shall awarde & humbly prayeth as he before in his bill of complaint hath § |

21.  allready prayed.

 

 

 

 

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