To the Right Honble Sr Thomas Egerton Knight Baron of
Ellesmere and Lord Chancellor of England
1. In all Humble manner sheweth vnto yor Hoble: Lop: yor daylie Orator Richard Bancroft of Wilsdon Esquier Exector of the Last will and Testament of the Reuerend ffather in god Richard late Archbishopp of Canterbury |
2. deceased That whearas the said late Archbp in his life tyme was a man well knowne throughout the wholl Cource of his life by all meanes to eschew and avoid the beinge indebted vnto any person |
3. or persons but most espetiallye to any Bookbynders or bookesellers for any bookes whatsoeuer that he should buy here or reserve from them And that was his daylie Chardge and Comand at all tymes § |
4. (from tyme to tyme duringe the tyme of his beinge Archbp) to his followers and Servants attendinge vppon and about him or Imployed by him that they should not by any meanes fetch take |
5. Buy or receive any bookes for him or to his vse but that forwth vppon the Resceipt therof they should paye for the same, and the better to observe his desire therin the said Archb did Contynually |
6. deliuer mony to some or one of his men or followers before him to paye for all such bookes as should at any tyme be brought or deliuered to his vse as aforesaid, for that the said Archb did well knowe the |
7. deceipt of Book sellers and booke byndrs in that kynde and how vsually was and had bine wth them to demaunde great Sommes of mony after the death of some of the predecessors of the said Archb and others |
8. his freinds and acquaintances for bookes wch they did sometymes give and sometymes were seised by and vnto the said Archb Now so yt is maye yt please yor Hoble Lop that §§§§§§ Bonham Norton |
9. and John Bill two book sellers on or about Paulles Church Yeard in London pretendinge that the said late Archb: in his life tyme was indebted vnto the said Norton and Bill have Confederated and § |
10. Combyned wth Richard Tombes Xrofer Wilson Willyam Hamond John Wollye Willyam Wrench and Richard Taylor persons vnknowne to yor Orator and that were neuer servants nor followers of the § |
11. foresaid Archb nor Imployed by him and they all vppon the Combynacõn aforesaid vntrulie and vnconscionablie pretend and surmise that the foresaid late Archb: did owe vnto them the said Bonham |
12. Norton and John Bill the Somme of ffower hundred fforty and eight pounds Tenn shillings and Tenn pence for Bookes whearas in truth as aforesaid the said Archb : did not owe vnto them |
13. nor vnto either of them not one peney at all yet neuertheles the said defendts havinge a wicked intent and purpose for to parte and share the said ffowre hundred fforty eight pownds Tenn § |
14. shillinges and Tenn pence amongst themselves They the foresaid Norton and Bill have alreadye Comenced an Accön at the Commön Law against yor Orator for the said ffowre hundred fforty |
15. eight pownds Tenn shillinges and Tenn pence wherof before yor Orator neuer had notice of nor did they euer Clayme or demande the sume of yor Orator but yor Orator hath lately hard that the |
16. said Richard Tombes Xrfer Wilson Willyam Hamond John Wolley Willyam Wrench and Richard Taylor be the men that of late have incited the said Norton and Bill <to the said Suite and have and also Offer that they wilbe the witnesses of them the said Norton and Bill> to prove that the said |
17. Archb did owe the foresaid ffowre hundred ffortye eight pounds Tenn shillinges and Ten pence vnto the said Bill and Norton Now for that yor Orator hath no waye nor meanes for to be |
18. releived at or by the Common Lawes of this Realme against the vnconscionable Confederaces and proceedinges aforesaid but hopeth that the foresaid Norton and Bill and other the § |
19. foresaid defendants will Confesse there foresaid Confederacies and Combynacõns vppon there Answeares in this Honorable Court And that the said defendants may set downe vppon |
20. there Oathes by waye of Answere whether that they any or either of them did sell and deliuer vnto the foresaid Lord Archb the Bookes for wch they do demand the ffowre hundred fforty |
21. eight pounds Tenn shillinges and Ten pence of yor Orators and what bookes the same were and for whose vse or for what purpose the said Bookes were and what did become or is |
22. become of the said bookes or of either of them to there or either of the defendants knowledge and whither they or either of them did like or demaund the said ffowre hundred fforty and eight § |
23. pounds Tenn shillinges and eight pence of the said Lord Archbishop in his lifes tyme and what is the Cause that they have forborne to demand the said ffowre hundred fforty eight poundes Tenn |
24. shillinges and Tenn pence of yor Orator and also set downe the tyme when the said bookes were sould or deliuered to the said Archb and the tyme when first the said Norton and Bill or any of the |
25. defendants did first demaunde or aske the said ffowre hundred fforty eight poundes Tenn shillinges and Tenn pence of yor Orator and the said Tombes Willson Hamonde Wolley Wrench and Taylor maye |
26. further set downe what Bookes they or either of them had or received of the said Norton and Bill or of any other to the vse of the said late Archb and what Aucthority or Comande they had from |
27. the said Archb so to doe, or whither they had there Aucthoritye from any others and what others and what is or did become of the said bookes and whether they the defendants or any of them have themselves or had § |
28. themselves any or either of the <said Bookes> And that also the said Norton and Bill maye Answere directly yf they have not sayd and Confessed that yor Orator ought not to be Chardged in Conscience wth the said |
29. ffoure hundred fforty eight powndes Tenn shillinges and Tenn pence nor wth any parte therof or what words they have vsed to that effect And whither they have not demanded the foresaid ffoure hundred fforty and |
30. eight powndes Tenn shillinges and Tenn pence of some other person and persons and of what other person and persons and also sett down how much of the said ffoure hundred ffortye eight pounds Tenn shillinges and Tenn |
31. pence is in truthe behinde and vnpaid and that the said defendants maye be Ordered in the premisse and the foresaid vniust Anon at the Common Law against yor Orator Commenced maye be stayed Maye yt |
32. please yor honor to grante vnto yor said Orator his Maties most gracious writt of Subpena to be directed to the said Bonham Norton and John Bill Richard Tombes Xrofer wilson Willyam Hamonde John Wolley |
33. Willyam Wrench and Richard Taylor and either of them Commandinge them therby at a Certayne daye and vnder a Certeyne parlynce therin to be Lymitted personally to be and appeare before yor Honorable Lop : |
34. Lop: in his Mates High Court of Chancery then and there to Answere to the premisses and to stand vnto and abide such further Order [2 words illegible] yor Honorable Lop: shalbe thought meete for to Order in the §§ |
35. premisses and yor Orator accordinge to his Bounden dewty will daylie praye for yor Honor in health and happie longe to Contynue.
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