The Replication of John Bill Complaynant vnto the seuerall Answeres of
Bonham Norton and Humphrey Dison Defendants
1. The said Complainant Replyeth & saith That the said Bill of Complaint, by him exhibited into this honorable Court is certaine and sufficient in the Law to be answered vnto by the said |
2. Defendants And not deuised and exhibited, by him the said Complainant, for any such cause or purpose as the said Defendants in their seuerall Answeres in that behalfe vntruely alledged |
3. But the same is grounded vppon good and iust cause, of suite, as by the Contents thereof it doth and may appeare. And this Complainant further saith, That the seuerall Answeares of the said |
4. Defendants are verye vncertaine and insufficient in the Lawe to be Replyed vnto by this Complainant ffor diuerse apparant faultes and imperfections therein conteyned Neuertheles this Complainant sauing vnto |
5. himself, now and at all times hereafter, all advantages of exception to the incertaintie, and insufficiencie, of the said seuerall answeares, for further Replycation therevnto, saith, That he doth |
6. and will averr, iustifie mainteyne and proue, all and euery the matters, articles, clauses sentences, and thinges, in the said Bill of Complaint conteyned, to be good iust and true, in such |
7. sort manner and forme, as in ye said Bill of Complaint, they be truely sett forth, shewed and declared, And further the said Complainant saith: That he doth and will averr and proue, vnto this |
8. honorable Court: That he hath sundry times, offered vnto the said defendant Bonham Norton, good and sufficient, reall, securitie by assignment of this Complainants moytie, in the Office of his |
9. Matiesties printer and stock of Bookes, therevnto belonging, amongst other thinges, of great value, (being all worth aboue 9000li,) ffor the said Bonham Nortons securitie and indemnitie |
10. aswell from all those debts: wherein he stands, bound with this Complainant, for his particular debts; (which do not now amount vnto, 2000li): And from the moytie of all his, and the said Bonham, |
11. Nortons, Ioynt debts in the said bill of Complainant, mencõned: As also for the payment, vnto the said Bonham Norton, of so much, of the Remainder, yet vnpaid, vppon the said billes |
12. obligatory, (against, wch this Complainant, seekes for releife, by the said, Bill of Complaint in point of equitie) As this honorable Court vppon the hearing, of this cause shall in that behalfe, order, and award, |
13. so that the said Bonham Norton would likewise giue, vnto this Complainant, good sufficient reall securitie, for his securitie and indemnitie, from the said Bonham Nortons: proper and |
14. perticular debts in ye Bill mencõned <for wch this Complainant stands bound wth him> As also from the moytie of their <said> Ioynt debts, But the said Bonham Norton, hath refused to accept of the said offer so made by the said Complainant, and to |
15. [word illegible] vnto him such like reall securitie, Without that that this Complainant, did promise, the said Defendant, Humphrey Dyson, 40li for any such purpose, or out of any such feare, or guilt, as |
16. the said Defendants in their seuerall, answeares, do scandalously & vntruely intimate & alledge, Or that this Complainant, for his parte did agree, vnto the said bargaine, or to the sealing or deliuering, of |
17. any of the writings therevppon or concerning the said bargaine, Otherwise or in any other, manner, then as the same is in that behalfe, in the said bill of Complaint, sett forth and declared |
18. And without that, that this Complainant , did deale vntruely and vnfaithfullye wth the said Bonham Norton Concerning the Copartnership & Ioynt trade betweene them, as in his the |
19. said Bonham Nortons Answeare, is most vntruely surmised, Or that the said Complainant,: refused to make vnto the said Bonham Norton a trew account Concerning the same, |
20. [word illegible] that that this Complainant, did promise to discharge the said Bonham Norton, of his the said Complainants particular debts: And to assigne ouer, his moytie in the said Office & stocke to |
21. the said Bonham Norton, aswell for his securitie thereof in the meane time, as also, for his security, of such monyes, as he pretends that this Complainant: did owe vnto him by the |
22. said bonds Otherwise or in any other manner or forme, then as the same is in that behalfe before specified, Or that the said Bonham Norton, hath to this Complainants knowledge, discharged, |
23. great part of his the said Bonham Nortons particular debts; for wch this Complainant, standes engaged, wth him, Or that he hath deliuered vpp, the said Bonds, Cancelled, vnto this Complainant |
24. And without that, that there was about 1000li, of the Complainants particular debts, or any other some, of monye at allvniustlie cast and wrongfully charged, vppon the debts: of |
25. the said Ioynt stocke, belonginge to the office, of his Maisties printer,: As in the said Bonham Nortons, Answeare is also vntruely surmised: And wthout that, that any |
26. or matter or thing in the said seuerall answeares mencõned, materiall or effectuall in the Law to be replyed vnto,: And in this Replication, not sufficiently, confessed, |
27. and avoyded, denyed, trauersed or otherwise replyed vnto [word illegible] wch matters the said Complainant, is ready to averr, & prooue as this honorable Court, shall and will, |
28. award, And prayeth as before in his said Bill of Complaint he hath prayed,:
[name illegible]
[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.
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