C3/334/73   [IMAGE]

CHANCERY PETITION: JOHN BILL v. BONHAM NORTON [1621]  •  DOWNLOAD PETITION (PDF 424 KB)

(1) John Bill’s petition

To the Right Hon^ble & Right Reuerend ffather in God John Lord B^p of Lincolne

Lord Keeper of the great Seale of England

1.  In a Humble maner Complayninge, showeth vnto your good Lo^p, your Lo^ps dayly Orator John Bill Citizen and Stacõner of London, That whereas in the yeare of our Lord God 1603 Bonham Norton of London Esquier, John Norton Citizen and Stacõner of London & your said suppliant became Copartners |

2.  & Ioynt traders together in the art or trade of a Stacõner or Bookseller & in buying and bringing of bookes maps and other Stacõnary wares & merchandizes, in & from ffrance Germany & other parts beyond the seas into England, and in selling the same againe & in printinge of diuers bookes here in Englande |

3.  and beyond the seas, ffor the better managinge of which Ioynt trade there was a Ioint stocke raysed vpon the first entring into the said Copartnership w^ch did consist only of bookes, ffor all w^ch bookes by Agreemen^t betwixt the said Bonham NortonJohn Norton and your said suppliant then made [word illegible] |

4.  said to be paid or answered out of the said Ioynt stocke vnto them the said Bonham Norton& John Norton 4400^li in Eleuen yeeres next ensuing the entringe into the said Copartnership, The same to be paid by 200^li euery half yeere, equally to be diuided betwixt The said Bonham Norton & John Norton |

5.  [word illegible] which bookes (being priced by the said Bonham Norton & John Norton at the said some of 4,400^li [)] were notwithstandinge those dayes of payment giuen for the same as aforesaid very much ouervalued, And at the time of the enteringe into the the said Copartnershippe, It was further agreed vpon by and betwixt the said |

6.  Bonham Norton  John Norton and your said suppliant That the said 4,400^li being so paid out of the said Ioynt stocke & tradinge as aforesaid, The residue of the stocke which should then remayne w^th the increase and proceede thereof should be equally diuided betwixt the said Bonham Norton John Norton [word illegible] |

7.  and suppliant,  After w^ch Copartnershipso entred into, they the said Bonham Norton John Norton & your saide suppliant did accordingly trade together As Copartners vntill the moneth of Nouember 1612, At or about which time, the John Norton (hauing made the said Bonham Norton the sole executor of his |

8.  last will & testament) departed out of the mortall life during the time of which said Copartnership, there was paid out of the said Ioint stocke & the increase thereof according to the said Agreement euery halfe yeere 200^li to the said Bonham Norton & John Norton Which said halfe yeerly payments |

9.  in all amount vnto 3600^li, And during all the time of the said Copartnership y^e said supliant went twice every yeere at the least vnto divers parts beyond the seas, as namely into ffraunce Germany Spaine Italy and diuers other places to furnish the said Ioynt trade w^th bookes maps & other Stacõnary merchandizes, In w^ch Iurneyes the |

10.  said supliant oftentimes hazarded his life, & by y^r said supliants well & profitable managing of the said trade, both beyond y^e seas & heere in England, duringe the life time of the said John Norton; the saide Ioynt stocke was so much aduanced y^t a little before y^e saide John Nortons death, It was agreed vpon betweene the said Bonham Norton John Norton & y^e said supliant, That y^e executors |

11.  or Administrators of any one of the said Copartners w^ch should first dye, should be paid by y^e suruiuing Copartners 3000^li out of the said Ioint stocke w^thin 4 yeeres next after the death of any of the said Copartners w^ch shuld so first dye as aforesaid, The same to be paid by 375^li euery half yeere in full satisfaccõn of all such right title Interest and demande which |

12.  the executors or Administrators of y^e said deceased could in Lawe or Equity Clayme out of the said Ioint stocke, Vpon the death of which said John Norton the said whole Ioint stocke came by survivorship, & by the said last Agreemen^t, vnto y^e said Bonham Norton & to your said supliant w^ch together w^th the encrease & proceede thereof was and ought to be equall |

13.  diuided betwixt y^e said Bonham Norton & y^r said supliant, And from & after the said John Nortons death, y^e said Bonham Norton & your said supliant, continued Copartners in the said trade vntill the 9^th of July 1619, And out of the said Ioint stocke there was paid vnto y^e said Bonham Norton after y^e death of  y^e said John Norton as well the said ?600^li |

14.  beinge residue of the said 4400^li As also the said 3000^li w^ch was by vertue of the said Agreemen^t, alotted to be the share of the said John Nortons executor: at the dayes in that behalf before mencõned for y^e paymen^t of the said seuerall somes, And for fiue yeeres next after y^e death of y^e said John Norton, y^e said supliant wholely execute y^t trade & by y^r supliants [word illegible] |

15.  meanes, labor Industry & Endeauours, y^e said Ioynt stocke did duringe y^e said fiue yeeres space so much encrease, That at sundry times from the 14^th day of ffebruary 1614 vntill the 27^th of July 1617 there were paid out of the said Ioynt stocke ouer & besides y^e said 3800^li diuers somes of money amounting in the whole vnto 4970^li or thereabout vnto the said |

16.  Bonham Norton & to diuers other persons for his the said Bonham Nortons particuler vse & behoofe, Besides diuers other somes of money paid out of the said Ioynt stocke for y^e Bonham Nortons particuler since y^e said 27^th of July 1617 & before the 9^th of July 1619 And y^e orato^r further sheweth vnto y^e good Lop, That from & after the said 27 of July |

17.  1617 & vntill about y^e 9^th of July 1619, The said Bonham Norton (hauing taken into his posseson the bookes of Accounts touchinge y^e said trade & therby knowing what the said stocke was woorth better then y^e said suppliant, & perceiuing that y^e trading in y^e buying & selling of bookes began then very much to decay) did many times vse y^r said supliant in most Contemptible & |

18.  vnsufferable maner, threatening, y^t h^e would turn^e y^e said supliant out of y^e house wherein he then dwelt, & take away from y^e said suppliant all the Estate he had pretending y^t y^e said supliant owed him many thousands of pounds vpon accoun w^ch being examined: proued to be false, W^ch ill vsage y^e said Bonham Norton offered to y^r said suppliant of purpose as the |

19.  sequel shewed to y^e intent to make y^e said supliant weary & vnwillinge to contynue y^e said Ioynt Copartnerahipany longer, w^th him y^e said Bonham Norton. And in hope, therby to drawe y^e said suplicant (y^e rather for the procuring of his peace & quiet[)] to buy of him y^e said Bonham Norton, his the said Bonham Nortons moyty in y^e said Ioynt stocke at such prices |

20.  as he the said Bonham Norton would demand for the same , ffor accordingly the said Bonham Norton, did in or about March 1618 persuade y^e said supliant to buy of him his said moytye, w^ch y^e said supliant at first refused, offering to sell to the said Bonham Norton his moytye, alleadginge that it was more fitting that the said Bonham Norton should |

21.  buy y^e said supliants moyty then y^e said supliant should buy his, for many respects amongst others for y^t y^e said Bonham Norton had diuers sonnes who might manage the trade after him, whereas y^e said supliant had not any children, The said Bonham Norton hauing receive^d this answeare from y^e said suppliant, did notw^thstanding persist in his former [word illegible] |

22.  to drawe y^r said suppliant to buy his y^e said Bonham Nortons moytye, and for y^e better effecting therof he the said Bonham Norton did practise w^th one Humphrey Dyson of London Scriuenor (in whom y^e said Bonham Norton well knewe y^e supliant did repose a great confidence) That he y^e said Dyson would persuade y^e said supliant to buy the said Bonham Nortons |

23.  moyty in the said stocke at the price hereafter in that behalf mencõned, & the rather to draw the said Dyson therevnto, the said Bonham Norton did promise to give him y^e said Dyson a large Reward vpon y^e conclusion of the said  bargaine, Wherevpon the said Dyson did vndertake to doe the same and accordingly by & vpon y^t Combinacõn betweene the said Bonham |

24.  Norton and the said Dyson, he y^e said Dyson vsed many persuasions vnto y^e said supliant to buy y^e said Bonham Nortons moyty, at the price hereafter mencõned telling y^e said suppliant amongst other motiues, That it was of a farre greater value then in trueth it was & y^t y^e said supliant should get a great deale of money by it & by y^t meanes |

25.  should liue in peace w^thout further molestacõn from y^e said Bonham Norton or words to y^e effect, Vpon whose persuasions y^r said supliant (being ignorant of the true value of y^e said stocke, by reason y^t y^e bookes of Accounts were in y^e Custody of the said Bonham Norton & by him deteyned as aforsaide) was drawn to treate w^th y^e said Bonham Norton  |

26.  about the buying of his parte or moytye, who demanded of y^e said supliant for the same, That y^e supliant should discharge him the said Bonham Norton of 5700^li principall debts & of the vse thereof w^ch came to 570^li or thereabouts for w^ch principall debts & vse, the said Bonham Norton & y^e said supliant did then stand ioyntly engaged  vnto |

27.  divers persons  for there Ioynt debts. And y^t y^e said supliant should release or discharge the said Bonham Norton of 490^li w^ch he the said Bonham Norton did owe vnto y^e said supliant, And y^t y^e said supliant should likewise pay to him y^t said Bonham Norton 5000^li in fiue yeeres then next ensuinge, The same to be paid by 500^li at euery half yeeres |

28.  [word illegible] & the rather to induce y^e said supliant to accept of the said offer, the said Bonham Norton did tell y^e said supliant & confidently affirme & promise to y^e said supliant that y^e said stocke (consisting at y^t time of bookes bound &  in quiers heere in England of diuers debts owing to y^e said stocke, of a share or porcõn, w^ch y^e said Bonham Norton & |

29.  [hole] y^r said supliant had in a Ioynt stocke of bookes & printing beyond the seas in Copartnership, together w^th diuers strangers borne, dwelling in ffranckford & other places, & of certaine leases of the house & shop wherein y^r said supliant then dwelt, & of a tenemen^t & two shoppes on the bankside of the said house ) was well worth 18000^li or  |

30.  thereabouts Which offer y^r suppliant did at first vtterly refuse, telling the said Norton y^t he should haue y^r the said supliants moyty in the same stocke for a farre lesser price & vpon farre longer dayes of paymen^t of the whole summe, But the said Bonham Norton & Dyson persisting in their said persuasions, y^r said supliant desired of y^e said Bonham Norton y^t he might acquire |

31.  some others therw^th & haue their aduise thervpon, whervnto the said Bonham Norton would by no meanes condestend, Affirming y^t he would haue none to meddle or haue anything to do in or about the driuing or setting downe of the said bargaine but only y^e said Dyson, wherw^th at length y^r said supliant was contented in regard of the |

32.  [2 words illegible] he held of y^e said Dyson, & of y^e trust & Confidence he respected in him, no way suspecting y^t he would haue bin any meanes to wronge or ouerreach y^r said suppliant, And after many meetings & Conferences in that behalfe made, your said suplicant relying vpon the protestacõns of the said Dyson & vpon y^e faithfull promises of y^e said Bonham Norton |

33.  that y^e said stocke was worth 18000^li , & y^t y^e debts then owing to the said stocke would prooue to be good (w^thout entring into y^e examinacõn of the trueth of y^e particulars whether the stocke was so much woorth as it was affirmed & as y^e said Bonham Norton required for the moyty or no) did agree w^th the said Bonham Norton vpon y^e 9 day of July  1619 |

 34.  & buy of him his moyty in the said stocke, at y^e said price, w^ch he y^e said Bonham Norton demanded for y^e same as is before menconed; W^ch bargaine being so concluded: vpon y^e said premises so made & vpon y^e said confidence & trust, your said supliant desired that the same might be set downe in writinge But y^e said Bonham Norton knowing y^t in [word illegible] & vppon  |

35.  examinacõn of the particulars It would manifestly appeare y^t he had exceedingly & vnconscionably ouerreached and oppressed y^r said sup^liant, w^th y^t bargaine, in causing him to pay many thousands of poundes more then it was woorth, Would by no meanes have it entirely & fully set downe in writinge, but would have y^t part of the said Bonham Nortons |

36.  [word illegible] that y^r sup^liant was to discharge him y^e said Bonham Norton of the said 5700^li principall debts w^th y^e vse therof & of the said 490^li to be concealed & not set downe, in wriying, And to y^t end caused the said Dyson w^thout y^e priuity of y^r said orato^r & w^thout any direccõn from him, but by directions & Instructions only from y^e said Bonham Norton |

37.  to drawe an Indenture of Couenants betweene him y^e said Bonham Norton & y^r said sup^liant bearing date the 9^th of July 1619 purtporting in effect, y^t y^e said Copartnership betweene the said Bonham Norton & y^r said sup^liant determined vpon y^e 14^th of March 1618, & y^t y^e said Bonham Nortons moyty in y^e said stocke amounted to 5000^li & y^t y^e said Bonham Norton did assign ouer [word illegible] |

38.  make to y^r said sup^liant w^th a promise that the same should not extend to the office of his mat^yes printer amongst other things. W^ch said Indenture of Couenants was enterchangeably sealed & deliuered by y^e said Bonham Norton & y^r said sup^liant, y^e said sup^liant sealing & deliuering the said Indenture neither aduising nor <considering> hereof but he did in wryting [word illegible] |

39.  vpon the said faithful promises so made by y^e said Bonham Norton vnto y^r said sup^liant, & vpon y^e said confidence & trust, y^t said stocke was of y^e value aforsaid, y^e said promises being then reiterated  & confirmed by y^e said Bonham Norton vnto y^r said sup^liant, & y^e said stocke the remayning in diuers parts of y^e Xtian world, y^r orator was inforced to rest & rely [2 words illegible] |

40.  ?promise for y^t he could not in a long time discouer the truth of th^e value therof, And for y^e paymen^t of y^e said 5000^li vnto y^e said word illegible Bonham Norton by y^r said supliant, the said Dyson by the said Bonham Nortons direccõn did drawe ten seuerall writings or billes obligatory bearing all dates the said 9^th of July 1619, By euery of w^ch [word illegible] |

41.  writings or billes obligatory, It was mencõned that y^e sup^liant stood bound vnto y^e saidBonham Norton in 1000^li, The 1^t of them being on Condicõn for the paymen^t of 500^li the first of May <Nouember> 1619, The 2^d on Condicõn for the paym^t of 500^li the first of May 1620, The 3^d for the paym^t of 500^li 1 of Nouember 1620 The [conjectural: 4^t ] |

42.  for the paymen^t of 500^li of 1 of May 1621 The 5^th for y^e paymen^t of 500^li 1 of Nouember 1621, The 6^th for y^e paymen^t 500^li 1 of May 1622 The 7^th for y^e paymen^t of 500^li 1 of Nouember 1622, The 8^th for the paymen^t of 500^li 1 of May 1623, The 9^th for y^e paymen^t of 500^li 1 of Nouember 1623. And y^e 10^th vpon the like condicõn for y^e paymen^t of 500^li |

43.  vpon the first day of May 1624, w^ch <said> ten seuerall writings or billes obligatory, yo^r said sup^liant vpon y^e said promises so made by y^e said Bonham Norton vnto y^r said supliant as aforsaid, & vpon the said Confidence & trust did seale & deliuer vnto y^e said Bonham Norton vpon the said 9^th day of July 1619 After w^ch bargaine ?so ?made |

44.  [word illegible] thereof so set downe  in writing as aforesaid, y^e said supliant did discharge the said Bonham Norton of the said 5700^li principall debts & of y^e vse thereof by paying the said debts & the vse thereof, & did likewise discharge him of the said 490^li, & hath since paid vnto y^e said Bonham Norton 1500^li vpon the [2 words illegible] |

45.  [word illegible] ?388^li besides But yo^r said Orator finds howe intolerably he was ouerreached & oppressed in the said bargaine hath forborne to make any further paymen^ts, for so it is, if it may please yo^r Lo^p, that for the space of one yeere & a half or thereabouts after the said bargaine so made as aforsaid, y^r said sup^liant [word illegible] |

46.  managed y^t trade & stocke, w^ch formerly was in copartnership betweene y^e said Bonham Norton & yo^r said supliant as aforsaid, during all w^ch time, he could not get in & receiue so much money by the sale of bookes or other stacõnary wares out of the said stocke & of diuers other bookes w^ch he brought from beyond the seas |

47.  [2 words illegible] bargaine to furnish & Continue the said stocke & of those who were indepted vnto yo^r said sup^liant for bookes or other stacõnery wares at any time before belonging to the said stocke as would discharge 2 of the first said paymen^ts vpon y^e 2 first bonds so made as aforsaid, W^ch one, who §§§ [word illegible] therevpon his |

48.  moneyes §§ y^e supliant receiued during y^e said space of one yeere & a half considering & weighing w^th himself, did, (being thervnto moued in Conscience as y^e sup^liant conceiues) acquaint y^e said Bonham Norton therw^th, telling him y^e said Bonham Norton, y^t yo^r said supp^liant was so much ouerreached or oppressed [conjectural: by] |

49.  ?y^e ?said bargaine, y^t he could by no meanes performe the same, or vsed words to that Effect. Wherto the said Bonham Norton §§§§ would not §§ make any answeare, more then this w^ch he hath often since affirmed that it was a bargaine & y^t it was nothing to him what y^r Orator lost by it |

50.  [2 words illegible] y^r supliant perceauing that he was not able to keepe the said stocke in his owne handes or to manage the said trade, did in or about the moneth of December 1620 offer to sell vnto the Company of the Stacõners of London the said Leases and the residue of the said whole stocke |

51. [1 word illegible] bookes w^ch yo^r sup^liant had then bound: some English bookes in quires y^e debts w^ch were owing to the said stocke & y^e said parte or share w^ch yo^r said sup^liant had in the said Ioint stocke, of the said bookes and printing w^th y^e said outlandish Stacõners only foreprised & excepted But the said Company of Stacõners & yo^r said sup^liant [3 words illegible] |

52.  [2 words illegible] price, y^r sup^liant demanded for the same bookes, w^ch he offered to sell to y^e said Company as aforesaid, The said differences by consent of all parties were first heard before y^e nowe most Reuerend father in God y^e L^d Archbishop of Canterbury, After w^ch hearing y^e composing therof & setting downe, Aswell of an Equall indifferent price for the same |

53.  wares bookes & maps belonging to the said stocke, w^ch y^e said sup^liant offered to sell to y^e said Company as aforsaid, As also of y^e dayes of paymen^t of y^e somes of money: at w^ch y^e said Leases bookes & maps should be valued & priced, Was by the mutual consent of the company & of y^e said sup^liant referred vnto foure of y^e Company of y^e said Stacõners [2 words illegible] |

54.  [2 words illegible] by the said Company & y^e other two by yo^r said sup^liant. Who after they had seene the said house tenemen^ts & shops & all the said bookes heere in England & y^e catalogue of y^e bookes w^ch were beyond y^e Seas, & y^e said maps so offered to be sold by your said sup^liant to y^e said  Company as aforsd & had deliberately & duely considered of y^e value therof did vpon |

55.  [3 words illegible] 1620 order arbitrate & set downe y^t y^e said company should pay vnto yo^r said sup^liant for y^e said Leases 616^li 13^s 4^d & for the said bookes & maps 3804^li. 18^s.  6^d. in maner following, y^t is to say 1000^li vpon yo^r said supliants deliuery of such of y^e said bookes vnto ye said Company as y^r said suplian^t had in England 216^li 13^s 4^d vpon yo^r said sup^liant assigning |

56.  [2 word illegible] Leases vnto y^e said Company 200^li at 4 monethes next after y^e assigning of y^e said leases, 200^li at y^e end of 8 monethes next assigning of y^e said leases, and the residue of the said 4421^li 11 10^d in 6 yeeres next ensuing y^e deliuery of yo^r said suplian^ts bookes then remanying in England 6 & 6 monethes to be equally diuided into 12 |

57.  [2 words illegible] to be paid half yeerely The first paymen^t therof to begin y^e next 6 monethes next ensuing the deliuery of y^e said bookes & of y^e Catalogue of the said bookes beyond the seas, W^th w^ch order & arbitracõn so made as aforsaid  ?Aswell y^e said Company of Stacõners as yo^r said sup^liants were well contented acknowledging y^e same to be equally |

58.  [2 words illegible] & made & set downe by y^r said Arbitrators Although y^r said supliant relying vpon y^e promises in y^t behalf made vnto him by y^e said Bonham Norton did beeleeue before y^e said viewe and apraismen^t made by y^e said Arbitrators, of y^e said bookes & maps w^ch yo^r saidsup^liant  sold to the said Company, Y^t y^e said bookes & maps would have conteyned farre more Reames |

59.  [conjectural: than they were] found to contayne & yo^r said sup^liant should haue receiued <after> 10^s the Reame at y^e least for y^e said bookes & maps, wheras y^e said Arbitrato^rs valued them but at viii^s the Reame, & the same to be paid at y^e said longe dayes of paymen^t, yo^r said sup^liant finding himself deceiued touching the quantity of y^e Reames of y^e said bookes & of the value thereof  |

60.  [3 words illegible] strickt examinacõn, what y^e residue of y^e said stocke w^ch was in Copartnership betweene the said Bonham Norton & yo^r said sup^liant , at y^e time of y^e said Bargaine & sale so made by y^e said Bonham Norton vnto y^r said sup^liant as aforsaid, & excepted in yo^r orato^rs sale to y^e Company was truly woorth, And after a long & laboriouse search in that behalf |

61.  [?yo^r said] sup^liant found y^t all y^e debts owing or belonging to the said stocke at y^t time when y^e said Bonham Norton sold his moyty of the said stocke vnto y^r said sup^liant as aforesaid, & at the time when the said sale, by relacõn & retrospect was to take effect, aco^rding to y^e said Indenture of Couenants, did amount in y^e whole but to 534^li or thereabouts of w^ch ?duly |

62.  [2 words illegible] supliant hath done his vtmost endeauo^r to recouer & get in y^e same, & hath bin at a great deale of labo^r & expence in y^e attempting therof, yet he hath not bin able from the time of the said sale so made by y^e said Bonham Norton vnto y^r said sup^liant as aforsaid to retreiue or recouer of the said debts aboue 1200^li And yo^r said supliant [word illegible] ?sealed |

63.  [2 words illegible] y^e said debts will proue to be vtterly desperate, as for y^e bookes w^ch were bound & y^e English bookes in quiers, w^ch  were belonging to the said stocke at the time of the said sale, so made by the said Bonham Norton as to yo^r said sup^liant as aforsaid, they were not woorth to be sold for ready money aboue 1000^li & as for y^e said sale made to the said |

 64.  [2 words illegible]  law to y^or said sup^liant had in y^e Ioint stocke w^th y^e said outlandish Stacõners at y^e time when the said Bonham Norton made y^e said sale vnto yo^r  said sup^liant as aforsaid, yo^r said sup^liant cannot haue y^e same (although he hath done his vtmost endeuo^r to get so much for y^e same as he could) so much money as since y^e said sale made to the said |

65.  [2 words illegible] hath paid out, in furnishing & supplying the said stocke, so remayning in copartnership and Ioint trading betweene yo^r said sup^liant and y^e said Stacõners so barne & dwelling beyond y^e seas as aforsaid, So y^t whereas y^e said whole stocke, w^ch was in copartnership betweene y^e said Bonham Norton & y^e said sup^liant, at y^e time of y^e said sale so made by y^e said |

66.  [2 words illegible] y^r said sup^liant as aforesaid should haue bin in all equity & good conscience truly woorth 17250^li, In regard y^e said Bonham Norton demandeth of y^r sup^liant, 8625^li for his moyty thereof as aforsaid Of w^ch said some of 8625^li yo^r said sup^liant hath since y^e 9^th day of July 1619 paid vnto  y^e said Bonham Norton and to diuerse others |

67.  [3 words illegible] Bonham Nortons proper debt, 5513^li as aforsaid. Your said sup^liant can make it manifestly apeare to y^r good Lo^p, That y^e said moyty of y^e said stocke at y^e time of y^e said sale so made to y^r said orator was not woorth aboue 3600^li, & y^t he y^r said Bonham Norton hath by y^e said bargaine so ouer reached and oppressed yo^r said sup^liant, That he the |

68.  [ 3 words illegible] And since y^e said 9^th day of July 1619 hath had & goeth about to haue of y^r said supliant 5000^li at least for his moyty in the said stocke more then his moyty in y^e said stocke was truly woorth, at y^e vtmost to be sold at the time of the said sale so made by y^e said Bonham Norton to y^r said sup^liant as aforesaid, And yo^r said Orato^r further sheweth vnto y^e [word illegible] |

69.  [3 words illegible] the late Queene Elizabeth of most famous memory, by her lettres patents vnder y^e great seale of England bearing date 8^th day of August in y^e 31^th yeere of her ma^ties Raigne, did grant vnto Robert Barker of London Esq^r, by y^e name of her welbeloued subiect Robert Barker sonne of Christopher Barker of London printer The |

70.  [3 words illegible] printers, of all and singuler statutes bookes Acts of parliament proclamacõns bibles Iniunctions & newe testamen^ts whatsoeuer in y^eEnglish tongue of any translacõn w^th notes or w^thout notes at any time before imprinted, or at any time from thence forth by y^e Comandmen^t or Authority of y^e said late Queene her [word illegible] |

71.  [3 words illegible] printed; As also of all other bookes whatsoeuer w^ch y^e said late Queene had commanded or for the time to come her said highnes or her successors should command to be vsed in the churches of this kingdome of England, Ordayning y^e said Robert Barker her said highnes printer of all or singuler the premisses To haue & enioy [word illegible] |

72.  [2 words illegible] profits thereto belonging to y^e said Robert Barker & his Assignes ?priuatly after y^e death of y^e saidChristopher Barker, for and during y^e naturall life of y^e said Robert Barker w^th an yeerly fee or annuity of 6.^li 13.^s 4.^d during the naturall life of the said Robert Barker for y^e executing of y^e said place, After w^ch grant so made by y^e said late Queene Elizabeth y^e said Christopher Barker |

73.  [3 words illegble] departed out of this mortall life, By whose death & by vertue y^e said grant, y^e said Robert Barker being seised of the said office did by his deed bearing date y^e last of ffebruary 1614 for diuers great somes of money paid vnto him y^e said Robert Barker by the said Bonham Norton & y^r said sup^liant assigne & set ouer vnto one Christopher Barker sonne of y^e said Robert Barker & to y^e |

74.  [word illegible] Bonham Norton & yo^r said sup^liant and their assignes the said office for & during the naturall life of him y^e said   Robert Barker excepting only y^e said anuall fee of 6.^li 13.^s 4.^d, ffrom & after w^ch assignmen^t so made they y^e said Bonham Norton Christopher Barker & y^r said sup^liant did execute y^e said office as Copartners vntil y^e 20^th of Nouemb^er 1617 or thereabouts, And there being no stocke of bookes belonging |

75.  [4 words illegible] the said Assignmen^t, The said Bonham Norton & y^e said sup^liant did w^thin a short space after y^e said assignmen^t, rayse a stocke of bookes apointing y^e same to belong to y^e said Office. And wheras also the <Kings> most excellent ma^tye y^t nowe is by his lettres patents vnder y^e great seale of England bearinge date 10^th of May in y^e first yeere of his Ma^ts Rainge of England |

76.  [4 words illegible] y^e 36^th  after recitall therein made of y^e said grante of y^e said office by the said late Queene vnto the said Robert Barker did grante vnto y^e said Christopher Barker y^e sonne of y^e  said word illegible Robert, y^e said office of his ma^ts printer, To haue & enioy y^e said office to y^e said Christopher & his Assignes immediately after y^e death of y^e saidRobert Barker his father |

77.  [4 words illegible] of y^e said Christopher Granting further vnto y^e said Christopher y^e priueledge & faculty of printing all & all manner of Abridgmen^ts of all & singuler statutes and Acts of parliamen^t, before y^t time made or from in thence forth to be made or set forth, w^th y^e like annuall fee vnto y^e said Christopher during his naturall life for y^e executing of the said office, And wheras |

78. [conjectural: the Kings most excellent] Mat^ie that now is, by his letters patents vnder y^e great seale of England bearing date y^e 11^th of ffebruarie in y^e 14^th of his m^ts raigne ouer England ffrance & Ireland & of Scotland y^e fiftieth, After recitall therein likewise made of y^e said grants, to y^e said Robert Barker & Christopher Barker did grant vnto Robert Barker y^e some of  ?10 |

79.  [2 words illegible] every & to his Assignes the said office, To haue & to hold the said office to y^e said Robert Barker the sonne & his Assignes immediately after y^e death, surrender or forfeiture, of both the said Robert Barker the father, & of the said Christopher Barker, for thirty yeeres then next ensuing Granting further to y^e said Robert Barker the sonne & to his Assignes during y^e said |

80.  [5 words illegible] & priuiledge of printing the said Abridgmen^ts w^th the like annual fee during the said terme for executing the said office, After w^ch lettres patents so granted vnto y^e said Christopher Barker & Robert Barker, sonnes of y^e said Robert Barker as aforsaid, They y^e said Robert Barker y^e father & y^e said Christopher Barker & Robert Barker y^e sonnes did by their deed bearing date |

81.  [2 words illegible] for diuerse great somes of money paid vnto them by y^e said Bonham Norton & yo^r said sup^liant, grante assigne & conuey vnto the said Bonham Norton & to yo^r said sup^liant & their assignes, all & singuler their Ioynt & seuerall estates rights Interests & demands whatsoeuer of in & to y^e said office & after the promises amongst diuers other things, ffrom & after w^ch assignmen^t so made |

82.  [4 words illegible] the said Christopher Barker & Robert Barker his sones vnto y^e said Bonham Norton & yo^r said supliant The said Bonham Norton & yo^r said supliant [word illegible] and yet do continue copartners or Ioint traders together in y^e said office &  stocke therto belonging And wheras y^e said Bonham Norton & y^r said supliant for y^e paymen^t of great somes of money for y^e estates |

83.  [ 3 words illegible] and his sonnes as aforsaid, & for y^e making and continuing of a stocke of bookes to be belonging to y^e said office of his ma^ts printer were enforced to borrowe diuers great somes of money, & y^e same to become Iointly bound vnto seuerall persons (the said last mencõned ioynt debts being nowe of y^e ioynt debts before mencõned to be discharged by y^e said supp^liant |

84.  [2 words illegible] bargaine made by the said Bonham Norton to y^e said orato^r as aforsaid:), It was agreed vpon betwixt y^e said Bonham Norton & y^or said sup^liant, y^t all such somes of money w^ch the said Bonham Norton, and y^e said sup^liant had borrowed or should borrowe to pay y^t w^ch they had vndertaken or were to pay for y^e said office, or for y^e raysinge or continuing |

85.  [4 words illegible] belonging to the said office, should be satisfied & paid out of the said office and stocke, And y^t the said Bonham Nortons moyty of the said office and stocke should be lyable to y^e one moyty of the said debts, & yo^r said sup^liant moyty should be lyable to the other, And whereas of late there being some differences betwixt the said Bonham Norton |

86.  [2 words illegible] amongst the things concerning the said Ioynt debts w^ch the said Bonham Norton & y^r said sup^liant did owe It was found vpon longe & deliberat examinacõn therof y^t y^e said debts by them so owing did amount to 4600^li principall money besides the vse thereof, w^ch indeed was for so much money w^ch they had borrowed towards y^e payment of |

87.  [2 words illegible] towards y^e raysing & continuing of y^e said stocke belonging to the said office and is none of the Ioy^nt debts before mencõned to be discharged by y^r said supp^liant. The moyty of w^ch said some of 4600^li & of y^e vse therof y^e said Bonham Norton hath at diuers times since the first of August last, faithfully promised yo^r sup^liant y^t he would pay, And |

88.  [2 words illegible] ?moyety in the said office stocke should be lyable thervnto, W^ch euer since y^e said 20^th of Nouember 1617 hath bin & yet is woorth some thousands of pounds more then the moyty of the said <Ioint> debt of 4600^li amounteth vnto, And yo^r said orato^r further sheweth vnto y^r good Lo^p, y^t yo^r said sup^liant at y^e request of the said Bonham Norton & for y^e [word illegible] |

89.  [2 words illegible] of the said Bonham Norton standeth also bound together w^th y^e said Bonham Norton vnto diuerse persons for the paymen^t of 8000^li or therabouts principall debt, Concerning w^ch said principall debt of 8000^li or therabouts (there being of late likewise some difference betwixt y^e said Bonham Norton & y^e supliant the y^e said Bonham Norton |

90.  [word illegible] y^t y^e said supliant stood engaged  w^th him the said Bonham Norton for the some of 7000^li or therabouts principall money being his the said Bonham Nortons particuler sole <&> proper debt, And at diuers times both before & since the first of August last he y^e said Bonham Norton did faithfully promise yo^r supliant & diuers friends of his |

91.  [2 words illegible] w^ch y^e said Bonham Norton in that behalf) that he y^e said Bonham Norton would discharge y^r said sup^liant, of all his the said Bonham Nortons particuler debts for w^ch yo^r said sup^liant stands, Ioyntly bound w^th him as aforsaid, And y^t for yo^r said supliants securitie in y^t behalf, in the meane time & vntill yo^r said sup^liant was so  discharged |

92.  [2 words illegible] hath not any counter bond & from y^e said Bonham Norton to saue him harmeles from y^e said debts wherin he stands obliged to <2 words illegible> y^e said Bonham Norton as aforesd) That he y^e said Norton would engage such a quantity of his lands vnto yo^r supliant as should be of sufficient value to discharge his y^e said Bonham Nortons particuler debts or  demandes assignmen^ts |

93.  of  his y^e said Bonham Nortons moyty in the said office & stocke Nowe so it is, may it please your good Lo^p That notw^thstanding y^e said Bonham Norton hath by y^e Industry & meanes of yo^r said supliant allready receive^d out of y^t Ioynt stocke or trade, w^ch at first was in Copartnership betweene the said Bonham Norton John Norton & yo^r said supliant as aforsaid [word illegible] |

94.  [4 words illegible] ouer & besides y^e said some of 4400^li at w^ch y^e said stocke as at first valued as aforsaid w^thout taking any paynes or doing anything in the managing of the said trade, for the good of y^e said Ioynt Stocke, but only from time to time, looking after his owne priuate benefit & drawing out from y^e said Ioint stocke so much  [word illegible] |

95.  [2 words illegible] leauing almost nothing to y^e said sup^liants share but some desperate debts, And not w^thstanding y^e said Bonham Norton knowes in his own conscience, Y^t his moity in y^e said Ioynt stocke was not worth so much by 5000^li or therabouts as he requires and would exact for y^e same of yo^r sup^liant, & y^t he hath bin told by diuers of y^e better sort [2 words illegible] |

96.  [2 words illegible] Thereof y^e said Bonham Norton is [word illegible] y^t  yo^r said sup^liant was by the said sale ouerreached & oppressed & although y^e said Bonham Norton knoweth all the Residue of y^e premises to be true, & y^t yo^r sup^liant hath often desired y^e said Bonham Norton y^t he would make vnto y^r supliant some reasonable abatemmen^t vpon y^t extreame hard bargaine answearable to him |

97.  [3 words illegble]  the value therof as aforsaid & y^t he would discharge yo^r sup^liant from y^e said particuler debts of y^e said Bonham Norton for w^ch yo^r said sup^liant stand^s bounde w^th him as aforsaid & from y^e moyty of y^e said 4600^li & of the vse therof or els giue yo^r sup^liant security acording to his promise in y^t behalf made, And notw^thstanding yo^r said sup^liant hath oftetimes offered vnto |

98.  [2 words illegible]  security to discharge him the said Bonham Norton of the moyty of y^e said 4600^li & of y^e vse therof w^ch y^r sup^liant is to pay In case y^e said Bonham Norton would discharge yo^r sup^liant of his y^e said Bonham Nortons particuler debts & of the other moyty of the said 4600^li & of the vse therof, or giue security for the same as aforsaid him y^e said Bonham Norton |

99.  [word illegible] & to ruinate your said sup^liant doth not only threaten to sewe y^r said sup^liant for 4000^li w^ch he pretends to be owing vnto him by yo^r said sup^liant vpon fower of the said writings or billes obligatory so sealed and deliuered vpon the said premises so made & vpon the said confidence & trust as aforesaid, & [5 words illegible] |

100.  [word illegible] vnto him 1500 more vpon the last writings or billes obligatory, But also hath made secret & fraudulent conueyances of his said moyty in the said office and stocke vnto diuers persons vnknowne to your sup^liant & hath estated his Lands uppon his §§§ & children or others to §§§ their vse [word illegible] ?security [word illegible] |

101.  [3 words illegible] [(]being by many thousands of pounds more woorth then all his the said Bonham Nortons debts do amount vnto) to the <intent> to charge and lay all the said debts vpon yo^r said orato^r to his Ruyne and ouerthrowe contrary to all right equity & conscience, In tends ?consideracõn & commiseracõn [4 words illegible] |

102.  [3 words illegible] hath [word illegible] by the strickt Course of the Comon Law, in regards the said premises so made by y^e said Bonham Norton to y^r said suplicant as aforsaid were made in priuate & fewe witnesses therat, but such wherof some are dead & y^e rest beyond the seas in places unknown to y^e  [conjectural: said sup^liant] |

103.  [2 words illegible] Bonham Norton & Humphrey Dyson being called to this ho^ble court to answeare vpon their oathes will confess all or the most of y^e matters before laid to their charge to be true That yo^r good Lo^p would be pleased to [3 words illegible] his Ma^ts most gracious writt of sub pena [3 words illegible] |

104.  [3 words illegible] concerning them & either of them at a Certaine day or vpon a Certaine paine therin to be limited personally to appeare before yo^r good Lo^p in his mats high court of Chancery then [word illegible] & ?sever the premises, & that y^t y^e said Bonham Norton set forth in particuler what bargaine or contract he made [2 words illegible] |

105.   [4 words illegible] moyty in the said stocke w^ch at first was in copartnership betwixt the said Bonham Norton John Norton & yo^r supliant & after y^e said John Nortons death betweene y^e said Bonham Norton and y^e said suppliant as aforsaid & what he esteemed & affirmed to yo^r said supliant ye value of y^e said whole stock to be at y^e time [6 words illegible] |

106.  [4  words illegible] said Bonham Nortons moyty in the said stocke at the time of the said sale was truely woorth & what promises he made vnto yo^r said sup^liant vpon y^e said sale [word illegible] the value of the said stock and of his moyety ?thereof and what somes of money haue bin paid to him or to other [2  words illegible]  out of y^e said stocke  |

107.  [6 words illegible] said supliant hath paid since y^e 9^th of July 1619 vnto the said Bonham Norton or vnto others for the vse & of what debts he hath discharged the said Bonham Norton [2 words illegible] the sale so made the 9^th July 1619 & what somes of money & to whom yo^r sup^liant stands bound [6 words illegible] |

108.  [6 words illegible]  particuler debt & whether there was any more of the said bargaine & sale so made by ?him to yo^r sup^liant as aforesaid set downe in wryting [word illegible] ?before in that behalf mencõned. And what [3 words illegible] he y^e said Bonham Norton hath made & to whom ?of is made [4 words illegible] |

109.   [4 words illegible] y^e said Bonham Nortons particuler debt, & for the said [word illegible] & y^e vse thereof or since the time he made y^e vse thereof or since the time he made y^e said promise to giue the said security to yo^r said sup^liant as aforesaid & whether he made not y^e said ?conveyances to y^e [word illegible] charge yo^r sup^liant w^th y^e said debts [words illegible] him of y^t security promised [3 words illegible] y^t y^e said Bonham Norton & Humphrey Dyson saide to & abide such ?orders  |

110.  [5 words illegible] ho^ble wisdome shall seeme to stand & be most agreable w^th reason equity & good conscience, And yo^r said sup^liant will euer pray for yo^r Lops longe life & ?hapines |

[FINIS]

This Chancery Petition is undated.  For the evidence for my dating see Maria Wakely, ‘Printing and Double-Dealing in Jacobean England: Robert Barker, John Bill, and Bonham Norton’, The Library, June 2007.