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CHANCERY PETITION JOHN BILL v. BONHAM NORTON  •  DOWNLOAD PETITION (PDF 256 KB)

(1) John Bill’s petition (no reply from Bonham Norton has been found) [Endorsed] 26th November, 1619

The Right Honorable Frauncis Lord Verulam

Lord Chauncello^r of England.

1.  Humbly Complayning, Sheweth to yo^r Hono^ble good Lo^p, yo^r Lo^ps dayly Orator John Bill Cittizen & Stationer of London, That whereas for diuerse yeares last past Bonham Norton cittizen & stationer of London And yo^r said Supp^liant as Copartners vsed, traded & dealt together [large hole] buying bringing |

2.  & feching of diuerse bookes, mapps, papers or other Stationery Marchandizes & wares, in, out, & from diuers partes beyond the seas into this Realme of England, & in the selling & vttering of y^e said bookes & other y^e said Marchandizes & stationary wares againe, as also <in> the Science [large hole] bookes [large hole] y^e seas during |

3.  w^ch tyme of  y^e said Corts [word illegible]  yo^r Lops said petitioner did offen tymes goe beyond ye Seas vnto France the Low Countries Germany and other more remote places, to buy bookes, & other y^e said Stationery wares to & for the vse, benefitt & advantage of y^e said Copartnership, in w^ch said iourneyes [large hole] such peticon [hole] aduise, Coun[hole]  |

4.  sell & other good [2 words illegible] in ye managing of y^e said Trade, the said Bonham Norton during y^e Copartnership hath receaved some thousands of pounds of lawfull money of England out of y^e increase of y^e said ioynt stock ouer & besides his y^e said Bonham Nortons purported [large hole] Queen Elizabeth of famous |

5.  [7 words illegible, conjectural: did some yeares since by her letters Patent vnder] y^e greate Seale of England grant vnto Robert Barker now of Dochet in y^e county of Bukingham esquier y^e Office of Printer vnto her Highnes her heires and sucesso^rs of all & singular Statute bookes, Acts of Parliamen^t , proclamacõns, Iniunctions, Bibles, & New Testamen^ts whatsoeuer in y^e English tongue [large hole] w^thout notes then before imprinted |

6.  [4 words illegible] printed by y^e commandemen^t & authority of y^e said late Queene her heires & successors, & also of all & singular other bookes whatsoeuer, w^ch y^e said late Queene her heires & successors for y^e service of God in y^e Church^es of this Realme of England either had commanded to be vsed, or from thenceforth shou[ld] command to be [large hole] |

7.  what name [2 words illegible] the same then were named or called or from thenceforth should be named, called or deemed w^ch then were imprinted or from thenceforth should be put in print by y^e authority of y^e Parliamen^t of y^e said late Queene, either in y^e english tounge, or in y^e english tounge mixed w^th any other tongue whatsoeuer amongst other things for & during yo^r naturall life |

8.  y^e said Robert Barker as in & by the said lettres Pattentes y^e same doth & may more plainely & at large appeare, And whereas also y^e Kinges most excellent Maiestie y^t now is, did some yeares since by his lettres Pattentes vnder y^e greate seale of England (after his Ma^tie had in y^e said lettres Patentes recited y^e former grante made by the said late Queene of y^e said Office [large hole] |

9.  vnto Christofer Barker sonne of y^e said Robert Barker, the Office of Printer to his Ma^tie his heires & successors of all & euery y^e premisses, for & during his y^e said Christophers naturall life, after y^e death of the said Robert his father, as in & by y^e said last recited lettres Pattents it also doth & may amongst other thinges more plai[nely] [large hole] |

10.  seised of y^e said Office for terme of his life as aforesaid, and y^e said Christopher Barker likewise hauing a graunte from his Ma^tie of the said Office during his life after his fathers death as is before mencõned, the said Robert Barker having before married y^e said Christofer Barker his sonne, to y^e daughter of y^e said Bonham Norton [large hole] |

11.  his Mat^ies raigne ouer England ffrance & Ireland & in the 48^th yeare of his Highnesses raigne ouer Scotland for 5000^li of lawfull money of England paid him by yo^r said Supp^liant, & the said Bonham Norton assigne & sett ouer vnto y^e said Bonham Norton, Christofer Barker, & yo^r said Supp^liant, the said Office amongst other [large hole] |

12.  ssoe granted vnto him in & by y^e said lettres patentes as in & by y^e said deede more plainely & fully it doth & may appeare, Vpon w^ch said Assignemen^t so made, y^e said Bonham Norton , Χρofer Barker & yo^r said Sup^liant entred into Copartnership touching y^e said Office & y^e managing & y^e executing thereof  & each of them is [large hole] sume of 4000 [hole] |

13.  said Copartnership & in y^e ordering & executing of y^e said trade to y^e best aduantage & good of y^e said Copartnership amongst other thinges, as in & by certaine Indentures of Couenantes in y^t behalf made it likewise doth & may more plainely & at large appeare, and for y^e performance of y^e said couentes, yo^r said Supp^liant & y^e said Bonham Norton & Xrofer [hole] |

14.  lawfull money of England, and y^e said Χρofer was also bound to yo^r said Supp^liant & y^e said Bonham Norton in a bill obligatory of y^e like summe, & so condicõned as y^e former made to him as aforesaid, w^ch Copartnership touching y^e said office for some space afterwards endured betwixt yo^r said supp^liant, & y^e said Bonham Norton & Χ[ρofer] [large hole] |

15.  where y^e said Office of y^e printing & y^e bookes & other goodes belonging to y^e said office of his Ma^tes Printer, were kept & during all y^t time y^e bookes & oth^er thinges belonging to y^e said office, & y^e monyes w^ch were from time to time receaued by reason of said office & y^e bookes therby printed, & y^e accountes from time to time concerning y^e  said [large hole] |

16.  y^e said Χρofer Barker keeping y^e key of one of y^e said lock so that nothing could be done by yo^r supp^liant concerning y^e goods & monyes in y^e said roomes, or touching y^e office, w^thout y^e priuity & consent of y^e Χρofer & of y^e said Bonham Norton, And yo^r said supp^liant during all y^e said time did direct for y^e best benefitt of y^e said ioynt [large hole] |

17.  he was therto required did weekely make in y^e presence of y^e said Χρofer Barker or of some deputed for him and in y^e presence of y^e said Bonham Norton or of some for him, iust & true Accountes of all matt^ers concerning y^e said office & y^e said Copartnership w^ch notw^thstanding yo^r supp^liant was oftentimes w^thout any iust cause so calumniated & [large hole] |

18.  said Copartnership of y^e said Χρofer Barker, And at length yo^r said petitioner vnderstanding y^t y^e said Robert Barker & Χρofer Barker & one Robert Barker y^e sonne of y^e said Robert Barker (to whom y^e King most excellent Ma^tie that now is had by his lettres patents vnder y^e greate seale of England (after his highnes had therein recited y^e former grauntes [large hole] |

19.  Robert Barker y^e father & of y^e Χρofer) would sell their present & future estate in y^e said office amongst other thinges concerning y^e same, treated w^th y^e said Bonham Norton, demanding of him whether he would ioyne w^th yo^r supp^liant in buying of y^e said Barkers estates, whereunto y^e said Bonham Norton condescended promising yo^r petitioner [large hole] |

20.  moytie thereof & all y^e said Barkers estates in y^e said office, And because y^e said Bonham Norton was allyed vnto y^e said Barkers by marriage as aforesaid, y^e Bonham Norton for most part treated w^th y^e said Robert Barker, & his said sonnes about y^e buying of their said estate in y^e said office And after diuers conferences betweene them had [large hole] |

21.  & his said sonnes about y^e said office, & that y^e said Robert Barker & his said two sonnes were contented in consideracõn of 6500^li of lawfull money of England to be paid vnto y^e Robert Barker y^e father & his assignes & of discharge of a debt of 200^li owing by y^e said Robert Barker y^e father to yo^r said supp^liant & of y^e discharge of a debt of 200^li [large hole] |

22.   sell vnto y^e said Bonham Norton, & yo^r said supp^liant, and their assignes, all y^e present & future estate of them y^e said Robert Barker, Χρofer Barker & Robert Barker of in & to y^e said office, & all thinges thereunto belonging, And also his ye said Χρofer Barkers purpartie in ye said ioynt stock touching ye said office as aforesaid w^th generall releases [large hole] |

23.  vnto y^e said Bonham Norton & yo^r said supp^liant but y^e said Bonham Norton at y^t time told yo^r said supp^liant, that he would by no meanes condescend y^t yo^r supp^liant should be ioynted w^th him therin vnles yo^r supp^liant first by writing would  couenant & graunt to him y^e said Bonham Norton that in case yo^r said supp^liant dyed w^thout yssue male lawfully begotten ye said Norton and his [large hole] ½

24.  to him & to yo^r said supp^liant for 2000^li to be paid vnto yo^r supp^liants executo^rs or administrato^rs at seuerall paymen^tes w^thin 3. yeares after yo^r supp^liants  death, & then y^e said Bonham Norton promised that if yo^r supp^liant would yeeld thereunto, yo^r supp^liant should haue cleere & an absolute moytie in y^e said office w^th him y^e said Bonham Norton, & be no further mol[ested & trou]bled w^th y^e said [large hole] |

25.  supp^liant & y^e said Barkers or any of them And that whereas formerly y^e said Bonham Norton had diuers times in his fury reviled yo^r supp^liant w^th termes vnbefitting he y^e said Bonham Norton confessed that from thence forth he would vse no more evell language or misdemeaner to yo^r supp^liant vnto w^ch proposition of y^e said Bonham Nortons touching ye said Couenant to petiti[oner] [large hole] |  

26.  concienable [word illegible] seeing yo^r supp^liant was to pay half y^e money for y^e said office, & because yo^r supp^liant [7  words illegible] <hath not had, by his now wife, (vnto whom he hath bene married many yeares) any children, nor is like to haue any by her:> & for y^t yo^r supp^liant might dye w^thin short time, & because y^e said office was then, & for some yeares then to come would be little worth by reason that y^e said Robert Barker whilst he executed y^e said office had very much [large hole] |

27.  Dyson a scriuener  whom yo^r supp^liant much respected & trusted, to vse perswasions to yo^r petitioner to yeeld thereunto, And thereupon y^e said Humfry Dyson had diuers conferences w^th yo^r said supp^liant about it, wishing yo^r petitioner to make y^e said couenant saying then & at diuers times since y^t y^e said couenant would not be nor was good & in ye lawe [large hole] |

28.   made by y^e said Bonham Norton before mencõned & vpon trust & consideracõn y^t  y^e  said Bonham Norton would performe y^e same y^e supp^liant did make, seale, & deliuered a deede of Couenant to y^e said Bonham Norton to y^e purpose aforemencõned And likewise y^e said Bonham Norton promised both before and at y^e tyme of y^e sealing & deliuering of  y^e said deede writ  vnto y^e said [large hole] |   

29.  [3 words illegible] deeds to any person  or persons whatsoeuer & that none but he & y^e said Dyson should know therof least y^e same should be a dispute & hinder y^e copatacõner of yo^r said supp^liant who by reason of his many ymployments w^ch & great trading then had office not hath occassion to borrow great  summes of money of  others wch [large hole] |

30.  did w^thout any consideracõn given vnto him in that behalf y^e said Bonham Norton make, seale & deliuer y^e said deed of Couenants <and vppon those terms also w^th the former & vppon trust & confidence that the said Bonham Norton would performe the same according to his promise yo^r supp^liant deliuered the said deede <[3 words illegible]> And yo^r said supp^liant further sheweth that y^e said Bonham Norton having thus obteyned his desire from yo^r‑ said supp^liant did conclude w^th the said Robert Barker & his said sonnes for their estates in y^e said office & [large hole] |

31.  aforesaid consideracõns before mencõned & [word illegible] <afterwards> y^e said Robert Barker Χρofer Barker & Robert Barker by their deede vnder their hands & seales bearing date y^e 20^th day of Nouember in y^e yeere of o^r Lord god 1617 in consideracõn of 2500^li of lawfull money of England then paid vnto y^e said Robert Barker by y^e said Bonham Norton [large hole] |

32.   y^e said Robert Barker y^e father by y^e Bonham Norton & yo^r said supp^liant w^thin y^e space of one yeere then next & immediately ensuing and in consideracõn of y^e discharge of y^e said 200^li  & debtt owing by y^e said Robert Barker y^e father to yo^r said supp^liant and of y^e discharge of y^e 200^li debtt owing by y^e said Χρofer to y^e said stock according to [large hole] |

33.  Barkers & y^e said Bonham Norton, & yo^r supp^liant did give, grant, bargaine, sell, assigne & sett ouer vnto y^e said Bonham Norton  & yo^r said supp^liant & their assignes all  their said present & future estates, titles, interests & demands of, in, & to y^e said office And likewise y^e said Χρofer by y^e said deede for diuers good consideracõns did grant to ye said Bonham Norton & y^e said suppliant [3 words illegible] |  

34.  &  demandes of in & to y^e said ioynt stock touching y^e said office, & likewise by y^e said deede y^e said Robert Barker, Χρofer Barker & Robert Barker did for diuers good consideracõns ioyntly & seuerally remise, release & quit claime vnto y^e said Bonham  Norton & yo^r said supp^liant all and all manner of actions, debtts, accounts & demands whatsoeuer  w^ch they or either of them had against Bonham Norton |

35.  & yo^r said supp^liant or either of them for or concerning any matter or thing whatsoeuer from y^e beginning of y^e world vnto y^e day of y^e date of y^e said deede, as in & by y^e said deede amongst other things doth & may more largely & more plainely appear w^ch said summe of 4000^li <was> after y^e date of y^e said last mentioned deede acording to the dayes of paymen^t [2 words illegible] truely paid |

36.  to y^e said Robert Barker y^e father & his assignes yo^r said supp^liant paying y^e one moytie of y^e said 6500^li, & y^e said Bonham Norton y^e other, And y^e said Χρofer Barker at that time <when the said assignement was made> did deliuer vp to be cancelled vnto y^e said Bonham Norton & yo^r said supp^liant that deed indented of  Copartnership touching y^e said office & y^e bond thereupon w^ch y^e Bonham Norton & yo^r said [4 words illegible] |

37.  Χρofer Barker as aforesaid, and y^e said Robert, Χρofer, & Robert Barker sealed & deliuered vnto y^e said Bonham Norton & yo^r said supp^liant a bill obligatory of 5000^li of lawfull mony of England for y^e performance of y^e graunts & convenants mencõned in their said last Assignment w^ch said bonds y^e said Bonham Norton promised vnto yo^r said supplian^t safely to keepe and yo^r petitioner [3 words illegible] |

38.  that when y^e said Bonham Norton & yo^r said supp^liant first contracted w^th y^e said Robert Barker y^e father concerning y^e first sale of y^e said office w^ch was in y^e yeare of o^r lord god 1614, y^e said Bonham Norton intreated yo^r said supp^liant that he yo^r supp^liant would become bound  together w^th him y^e said Bonham Norton & y^e said Robert Barker y^e father vnto divers persons [2 words illegible] |

39.  y^e said Bonham Norton promising vnto yo^r said supp^liant that he y^e said Bonham Norton would from thence forth from time to time discharge, aquite and save harmless yo^r said supp^liant from all such bonds & bills obligatory whatoseuer wherin yo^r said supp^liant together w^th y^e Bonham Norton & y^e said Robert Barker y^e father did either then  stand bound from [3 words illegible]  |

40.  bound & obliged to any person or persons whatsoeuer And y^e said Bonham Norton did at that time by his writing vnder his hand acknowledge that those debtts wherein y^e said Robert Barker was ioyned w^th him, the said Bonham Norton & yo^r said supp^liant were none of yo^r said supp^liants debtts, & that yo^r said supp^liant should not be charged w^th any such debtts [2 words illegible] |

41.  by y^e said Bonham Norton to yo^r said supp^liant yo^r said supp^liant at y^e request of y^e said Bonham Norton became bound together w^th y^e said Bonham Norton, & y^e said Robert Barker y^e father in a bill obligatory of 2000^li of lawfull money of England vnto one M^r Banckworth of London w^ch condicõn for  y^e paymen^t  of 1100^li of like lawfull money at a day [4 words illegible] |

42.  was ?presented into as aforesaid for 1000^li lent by y^e said M^r Banckworth, w^ch money by y^e appointmen^t of y^e said Bonham Norton was deliuered vnto y^e said Robert Barker y^e father & as y^e said Robert Barker affirmeth y^e said 1000^li was in part of paymen^t of 2000^li w^ch y^e said Bonham Norton was to giue vnto y^e said Robert Barker for his ye said Bonham Norton[s] [2 words illegible] |

43.  portion in marrying w^th  y^e said Χρofer Barker, w^ch said summe of 1000^li before some moneys due for y^e forbearance of y^e said 1000^li since y^e same was first lent, is yet due & vnpaid to y^e said M^r Banckworth, And yo^r said supp^liant vpon y^e said promise so made vnto him by y^e said Bonham Norton as before mencõned did also some [6 words illegible] |

44.  become [3 words illegible] w^ch y^e said Bonham Norton & y^e said Robert Barker y^e father in a bill obligatory of 3000^li of lawfull money of England vnto one M^r Alderman Craven of London vpon condicõn for y^e paymen^t of 1575^li of like lawfull English money at a day long since past w^ch said last mencõned bond was so entered into for 1500 principall money w^ch y^e said [2 words illegible] |

45.  [3 words illegible] y^e said Robert Barker y^e father receaued by y^e appointmen^t of y^e said Bonham Norton, & y^e same is yet due & owing for vnto y^e executing of y^e last will & testamen^t of y^e said M^r Alderman Craven who is since deceased, besides some moneys due for y^e forebearance of y^e said 1500^li for some part of y^e time since y^e said summe was lent And yo^r said [word illegible] |

46.  w^ch that y^e said Bonham Norton did since y^e yeare of o^r lord god 1617 contrary to his former promises made [hole, conjectural: on y^t ] behalf diuerse & sundry times giuen forth many contumelious sland^rous & reprochfull speeches and reports of yo^r said supp^liant oftentimes coming into yo^r supp^liants house & then & there euen sometimes in y^e presence & hearing of yo^r [2 words illegible] |

47.  [word illegible] offer vnto yo^r said supp^liant such vnsufferable wrongs & abuses as y^t yo^r said supp^liant perceauing y^t his trading together w^th y^e said Bonham Norton in y^e buying of bookes and other stationary wares beyond y^e seas, and selling them here againe was y^e occassion of y^e ill language & vsage w^ch he almost dayly receaued from y^e said Bonham Norton [2 words illegible] that [word illegible] |

48.  [5 words illegible] of y^e said Copartnership betwene him, & the said Bonham Norton touching y^e said trade, but not concerning y^e office of Ma^ts printer, y^t rather, because yo^r supp^liant  verily beleueth [hole] [---]wise he should now liue in quietnes & rest by y^e meanes of y^e said Bonham Norton where upon yo^r supplian^t offerred vnto y^e said Bonham Norton that [word illegible] yo^r suppliant |

49.  for his y^e said Bonham Nortons moytie in their ioynt trading copartnership stock, & debts owing vnto them of, touching, & concerning all things whatsoeuer other than y^e  office of his Ma^ts said printer, or else he y^e said Bonham Norton should buy yo^r petitioners moytie therin, And to y^t purpose yo^r petitioner offerred to y^e said Bonham Norton  [2 words illegible] |  

50.  [word illegible] for his y^e said Bonham Nortons moytie w^ch said offer was so reasonable as that yo^r said supplian^t offered to take y^e like summe of y^e said Bonham Norton for yo^r  y^e  supplian^ts moytie therein, w^ch offer y^e said Bonham Norton refused, affirming that he would sell & not buy, & that he would not giue so much to yo^r supplian^t for his moity by some thousands and as [3 words illegible] |

51. [word illegible] for his y^e said Bonham Nortons moytie although they had both equall shares & moities therein, wher upon yo^r supp^liant being so contuinually vexed by y^e said Bonham Norton as aforesaid did for y^e buying of his quiett & peace offer vnto y^e said Bonham Norton for his said moitie a far greater summe of money then yo^r supp^liant would haue taken for his said moyetie viz 1300^li ?in money |

52.  ?besides discharging him y^e said Bonham Norton of debt of some thousand of pounds wherin y^e said Bonham Norton stood bound but not  ?w^th y^e said Robert Barker W^ch said offer y^e said Bonham Norton accepted, & y^e said Bonham Norton for y^e consideracõns aforesaid, did promise to giue, grant, bargaine, sell, assigne & sett ouer vnto yo^r said supp^liant all his y^e said Bonham Nortons estate [2 words illegible] |

53.  [word illegible] whatsoeuer of w^ch to y^e said ioynt stock & Copartnership, & y^e debts due to y^e said Bonham Norton <[insertion erased]> And yo^r said supp^liant by reason of y^e same, as also all y^e moneys w^ch then were or from thenceforth should be in y^e said ioynt stock other then y^e office of his Ma^ts printer, & other then y^e ioynt stock betwene y^e said Bonham Norton & yo^r said supp^liant concerning y^e said office at his Ma^ts ?printer |

54.  y^e said agreement was made in y^e presence & hearing of y^e said Humfry Dyson who was to put y^e same agreemem^t in writing indifferently betweene them, And yo^r supp^liant also sheweth that y^e kings most excellent Ma^tie that now is did some yeares since by his letteres Patents vnder y^e greate seale of England grant vnto y^e said Bonham Norton y^e office of printer to his highness his heirs [conjectural: & successors] ?of ?all books [word illegible] |

55.  greeke & lattin to be imprinted w^thin this Realme, by reason whereof y^e said Bonham Norton at his owne costs and charges was from time to time in imprint such of y^e said bookes in y^e said languages as should be allowed & commanded to be imprinted by his Ma^tie or y^e State, After w^ch grant so made vnto y^e said Bonham Norton as aforesaid these bookes hereafter following amongst others were so [hole] ?co[mman]ded to be imprinted [words illegible] |  

56.  Bradwardines de causa Dei & y^e Archbishop of Spalatoes works, w^ch bookes or Copies amongst other Treatises in latin & greeke so commanded to be printed y^e said Bonham Norton conceaving that y^e printing therof would not yeeld him any benefit but rather some losse, refused to print y^e same, and he likewise refused buy such things as were fitting & necessary for y^e printing of such books vnless yo^r suppliant would therein ioyne [2 words illegible, conjectural: w^th y^e] |  

57.  said Bonham Norton such was y^e said Bonham Nortons obstinancy & contempt therin as that his Ma^tie & y^e State hath therw^th ben [3 words illegible] <not a litle> displeased, & y^e right hono^ble M^r Secretary Winwood in his life time requiring y^e said Bonham Norton to buy some things necessary for y^e printing of such like bookes by his Ma^ts commande, y^e said Bonahm Norton refused to doe y^e same, Whereupon for y^e ?appeasing of y^e iust ?and ?pleasure of his ?law |

58.  &  of his ?hauing ?of Office of ?State & in due obedience to his Ma^tie & y^e State yo^r supp^liant was contented to ioyne and did ioyne w^th y^e said Bonham Norton in y^e printing of y^e said bookes to yo^r supp^liants losse, Now so it is may it please yo^r hono^ble good lo^p that it appeareth by a Bill exhibited in y^t behalf into this hono^ble Court (since y^e said last assignemen^t made by y^e said Barker of y^e office as aforesaid) by y^e said Robert Barker y^e father ?against yo^r said Bonham Norton |

59.  & yo^r said supp^liant & by y^e proceeding ?therein & decree therevpon made that y^e said Bonham Norton both at & before y^e said signing of y^e said articles, & likewise both before, at, & sithence y^e making, sealing & deliuering of y^e said assignemen^t in Nouemb^er 1617 professed & promised to y^e said Robert Barker y^e father that y^e things therein & therby granted should be for y^e good & benifitt of him y^e said Robert Barker & his children, & that y^e said Robert Barker y^e father would hold ?y^e |

60.  office againe or at any time w^thin a yeare after y^e said Assignmen^t y^e same should bereassigned thereupon to y^e said Robert Barker vpon y^e repaymen^ts of y^e monyes disbursed for y^e same, & that there should be a true account of y^e maine profitt of y^e said office made to y^e said Robert Barker, But it did not appeare by any depositions that yo^r supp^liant was privie to y^e said trust or any y^e promises so made by y^e said Bonham Norton to y^e said Robert Barker as aforesaid [2 words illegible] |  

61.  thereof doth manifestly appeare in y^e proceedings of yo^r said cause that yo^r said supp^liant was a puchasor of y^e said office & stock bona fide, and that yo^r supp^liant neither before nor at y^e time of y^e subscribing of y^e said Articles, nor before nor at y^e time of y^e making, sealing, & deliuering y^e said assignemen^t did euer know or heare of any such trust or promises so made, but y^e said articles of agreemen^t & assignemen^t were subscribed sealed & deliuered by y^e said Robert Barker [word illegible] |

62.  said  somes vnto yo^r supp^liant as ?theire deede absolutely w^thout any trust confidence, condicõn or promise whatsoeuer foranything that yo^r said supp^liant heard or knew to y^e contrary, And yo^r said supp^liant by reason of y^e said promises so made by y^e said Bonham Norton to y^e said Barkers as aforsaid, hath ben driven to expend diuers great summes of money in defence of yo^r said supp^liants iust title, And yo^r said supp^liant by reason of y^e said Nortons ?promises made [word illegible] y^e said Barkers [2 words illegible] |  

63.  ?aforesaid is still molested & troubled & sued by y^e said Barkers And notw^thstanding  y^t y^e said decree made in that hono^ble Court in y^e said cause betwene y^e said Barker & y^e said Bonham Norton & yo^r said Supp^liant doth now onely extend, to y^e said Bonham Norton: yet by reason of an agreemen^t since made by y^e said Robert Barker y^e father & y^e said Bonham Norton y^e said Bonham Norton hath caused y^e said RobertBarker y^e fath^r & his said sonns to make new demaunds of yo^r said supp^liant & to ?raise [4 words illegible] |  

64.  ?namely y^e said Robert Barker y^e fath^er pretends y^t yo^r said supp^liant doth owe vnto y^e said Χρofer Barker about 1200^li vpon an old account touching y^e said Copartnership of y^e said office, & also 1200^li to y^e said Bonham Norton vpon y^e said account, w^ch said summe of 1200^li pretended to be due as aforesaid vnto y^e said Bonham Norton by yo^r said supp^liant y^e said Bonaham Norton hath assigned ouer vnto y^e said Robert Barker in some part of recompence & satisfacõn of that w^ch was prooued against him y^e said Norton [4 words illegible] |

65.  times said that he would be glad that y^e said debtts might be prooued to be due by yo^r said supp^liant, & that he would giue to any person or persons whatsoeuer 50^li to proue y^e same, And furth^er y^e said Bonham Norton for y^e consideracõns aforesaid, or for some oth^r cause hath assigned or promised to assign vnto y^e said Robert Barker y^e father y^e said couenant so made by yo^r said supp^liant vnto y^e said Bonham Norton [word illegible] Bonham Nortons having againe y^e said office for ?2000^li in ?case yo^r said supp^liant ?died w^thout yssue [word illegible] |

66.  manner & formes as is before mencõned And thereupon y^e said Robert Barker hath to yo^r supp^liants disrepute, and to y^e much impaying of yo^r petition^ers creditt giuen forth speaches w^ch are come to y^e eares of yo^r supp^liants creditors y^t yo^r supp^liant hath but an estate during his life in y^e said office, And y^e said Robert Barker doth demand of yo^r said supp^liant 4000^li to deliuer vp to yo^r said peticõner to be cancelled, yo^r supp^liants said couenant, And y^e said Bonham Norton being trusted by yo^r supp^liant w^th y^e said Χρofer  Barkers ?deede of 4000^li & [word illegible] |

67.  of y^e said Robert Barker Χρofer Barker & Robert Barker of 5000^li y^e rather to encourage & y^e better to enable y^e said Barkers to sue & molest yo^r said supp^liant, hath deliuered vp, & giuen vnto y^r said Χρofer Barker y^e said bond of 4000^li, & to y^e said Robert Barker, Χρofer Barker, & Robert Barker y^e said bond of 5000^li, so y^t vpon y^e whole matter & by y^t word illegible <diuerse> practises & confederacies had & made by & betwene y^e said Barkers & y^e said Bonham Norton, y^e said promises so made by y^e Bonham Norton to y^e said Barkers [5 words illegible] |

68.  & defraude yo^r said supp^liant & to weary him out of y^e said office of his Ma^ts printer And y^e said Bonham Norton hath diuers times since y^e said couenant so made to him by yo^r said supp^liant as afore said contrary also to his promise in y^t behalf  amongst others made as is before mencõned, come into yo^r said supp^liants house & in a most furious & violent manner hath giuen to yo^r petitioner many vile & scanderlous charges, as calling yo^r said supp^liant beggar, rouge, rastall and knaue, & one y^t ?was <wise ?not [word illegible] supp^liants[2 words illegible]> [4 words illegible] |

69.  amongst other such vnbeseeming & reviling words and not onely so, but also hath assaulted & offered violence to yo^r said supp^liant as taking & pulling yo^r said supp^liant by y^e beard in his yo^r said supp^liants owne house, And furth^r so it is may it please yo^r good lo^p, y^t y^e said Bonham Norton contrary to his said promise in y^t behalf formerly made doth refuse to discharge yo^r said supp^liant of y^e said seuerall bonds wherin yo^r said supp^liant together w^th him y^e said Bonham Norton & y^e said Robert Barker [3 words illegible] and bound [word illegible] |

70.  Banckworth & to y^e said M^r Alderman Craven in y^e said seuerall summes in manner & forme as y^e same in y^t behalfe is before sett forth & expressed, And yo^r said supp^liant since y^e 2^d day of Nouemb^er  in y^e yeare of yo^r lord god 1618 hath paid y^e said M^r Banckworth for y^e use of y^e said 1000^li principall money lent, 100^li, & to y^e executing of y^e last will & testamen^t of y^e said Alderman Craven deceased for y^e vse of y^e said 1500^li principall money lent,  150^li, And y^e said Bonham Norton doth [5 words illegible] |

71.  shall pay one half of y^e said seuerall debtts now owing vnto y^e said M^r Banckworth & to the executors of y^e last will & testamen^t of y^e said Alderman Craven deceased & [word illegible] y^e purpose & for y^e avoyding of y^e promises w^ch he y^e said Bonham Norton hath made vnto yo^r said supp^liant for y^e discharging of y^e said debtts as aforesaid he y^e said Bonham Norton hath vsed diuers indirect ?to venous & subtile tricks that namely amongst oth^ers he hath caused y^e said seuerall bonds so made by ?him ?y^e ?said [4 words illegible] |

72.  supp^liant & y^e said Bonham Norton since y^e first entring thervnto, to be in all their names renewed thereto hoping to defeate yo^r said supp^liant of y^e remedy w^ch he might haue at y^e common law against him y^e said Bonham Norton by reason of y^e said writing & other y^e promises w^ch he made to yo^r said supp^liant as is before mencõned because y^e said bonds so renewed doe beare date after y^e said Couenant in writing & <since the time of the> promises so made as aforesaid, And such [4 words illegible] |

73.  that since y^e said agreemen^t by parcell made by & betweene yo^r said supp^liant & y^e said Bonham Norton touching yo^r said supp^liants buying of his y^e said Bonham Nortons moytie of, in, & to y^e said ioynt stock & Copartnership betwene y^e said Bonham Norton & yo^r said supp^liant, & of y^e monyes then remayning in y^e said ioynt stock amongst other things other then concerning y^e said office of his Ma^ts printer so bought from y^e said Barker and his said sonns as is before mencõned [4 words illegible] |

74.  & parcell & vse [3 words illegible] sett downe in wryting by y^e said Humfrey Dyson as aforesd, y^e said Bonham Norton having occassion to vse some monies, & knowing y^t yo^r said supp^liant had some monyes in his hand w^ch before y^e said agreemen^t by parcell did belong vnto y^e said ioynt stock so passed by parcell to yo^r said supp^licant from him y^e said Bonham Norton as is before mencõned, did come vnto yo^r said supp^licant intreating yo^r said petitioner to lend vnto him y^e said Bonham Norton 150^li of [5 words illegible] |

75.  [word illegible] handes so past vnto y^e said Petitioned from y^e said Bonham Nortonvpon these great consideracõns before expressed y^e said Bonham Norton then faithfully promising & protesting vnto yo^r said supp^liant, that he would well & truly repay vnto yo^r said supp^liant all y^e said summe of 150^li of good & lawfull money of England at, or before y^e first day of paymen^t of y^e said 5300^li, so to be paid by  yo^r said supp^liant vnto y^e said Bonham Norton as is before mencõned & [5 words illegible] |

76.  [word illegible] of yo^r said Humphrey Dyson And ther vpon yo^r said supp^liant hauing affyance in his y^e said Bonham Nortons promise, did lend vnto y^e said Bonham Norton 150^li of lawfull money of England, to be repayed vnto yo^r said supp^liant in manner & forme before mencõned, & afterward viz^t y^e 9^th day of July last y^e said Humfrey Dyson did set downe in writing by way of Indenture of Couenant y^e said agreemen^t betweene yo^r said supp^liant & y^e said Bonahm Norton [3 words illegible] |

77.  [5 words illegible]  by yo^r said supp^liant & y^e said Bonham Norton y^e one to the other but in y^e said  Indentures there are as y^e said Bonham Norton now pretends such generall words as y^t by y^e rigor y^e common laws of this kingdome they doe cutt off & depriued yo^r supp^liant not onely of all remedy w^ch yo^r supp^licant can haue for y^e recouery of y^e said 150^li, but also for y^e recouering of 40^li, of lawfull English money owing to yo^r said petitioner [4 words illegible] |

78.  [5 words illegible] & enioying of diuers books printed at y^e costs & charges of yo^r said supp^liant as aforesaid, w^ch were made by y^e Archbisho^ps Bradwardine & Spalato <amongst others> being worth aboue 300^li, w^ch said last mencõned Indentures of Couenants if they doe so depriue yo^r supp^liant of y^e said sumes of money & other things due to yo^r said supp^liant as is before alleadged the same was vtterly against y^e true intent & meaning of yo^r said supp^liant & against y^e said [word illegible] promisses [2 words illegible] |

79.  [4 words illegible] & Humphrey Dyson & ?hoping that he should haue & enioy all the said things for w^ch he paid so deare a price, & being vnskillfull in y^e point of law did seale & deiluer vnto y^e said Bonham Norton y^e said Indentures of Couenants wherein if that be true w^ch y^e said Bonham Norton before affirmes & challenges in y^t behalf y^r said supp^liant is circumvented by y^e said Bonham Norton <& Humphrey Dyson> contrary to [2 words illegible] |

80.  [3 words illegible] supp^lliants whose estate ?was also estate of diuers of his friends who stand ?enagaged [2 word illegible] doe depend vpon y^e equity of y^e promises, & that yo^r supp^liant hath noe invoices to be releeved but in this hono^ble Court against y^e said deeds so made by him vpon trust, confidence, conditions & promises as is before mencõned, and because yo^r supp^liant hath noe meanes at y^e common law to recouer y^e said debt & other [2 words illegible]    |

81.  [5 words illegible] before alleadged and for y^t yo^r supp^liant cannot sufficiently proued as he should y^e matters before by him alleadged against y^e said Bonham Norton & y^e said Humfrey Dyson, because they were for y^e most part donne in priuate by & betwene yo^r said supp^liant, & y^e said Bonham Norton & Humfrey Dyson, w^ch yo^r said supp^liant hopes y^t y^e said Bonham Norton & y^e said Humfrey Dyson will confesse [5 words illegible] |

83.  [6 words illegible] by & betwene y^e said Barkers & y^e said Bonham Norton & the said Dyson to vex, molest, and defraude yo^r said petitioner of & concerning those things w^ch yo^r said supp^liant hath so dearely bought, and of and concerning other y^e promises wherof yo^r said supp^liant hath not as yet sufficient notice and knowledge, but hopeth that y^e said Bonham Norton & Humfrey Dyson [3 words illegible] |

85.  [5 words illegible] may then so it please yo^r hono^ble good Lo^p to grant vnto yo^r said Supp^liant his Ma^ts most gracious Writte of Subpœna directed vnto y^e Bonham Norton & Humfrey Dyson, commanding them and euery to appear before yo^r hono^ble good Lo^p at a certaine time & place, and vnder a certaine payne therein & thereby to be ?bound & ?appoint that |

86.  [5 words illegible] seale & every y^e said promises, and to stand to abide and performe such direction and order concerning the premises as to yo^r lo^p in yo^r greate and hono^ble wisdome shalbe thought meete, and to be consonant, and to stand w^th equitie and good conscience And? yo^r sayd Supp^licant, according to his bounden duetie will euer pray for yo^r [conjectural: Lops] long [conjectural: life].

  Henden  

[FINIS]