C2/JASIB35/29   [IMAGE]

CHANCERY PETITION: ROBERT BARKER v. BONHAM NORTON  •  DOWNLOAD PETITION (PDF 220 KB)

(1) The Petition of Robert Barker  [Endorsed] 25^o Marcii 1623

To the Righ^t Honora^ble [word illegible] Reverend ffather in God John Lord Bishopp

of Lincolne | Lord Keeper of the greate seale of England

1.  In most humble wise Complaininge sheweth vnto your good Lordshipp your Oratour Robert Barker of Southley in the County of Buckingham Esquire That whereas your Oratour aboute a yeere |

2.  past was lawfullie seited in his demeasne as of fee of and in the Manno^r or Cheiffe Mansion house of Tyle Place also Tyles Place, or the Manno^r of Tyles Place w^th thappurtnaunces scituat |

3.  in old Windsor, also Windsor or Egham (or one of them) in the Countie of Berks, Buck and Surrey (or one of them) of the yearelie vallue of [scribal space] over and above all charge |

4.  and reprises And was also possessed for divers yeeres yett induringe of and in the Manno^r of Hallowford (all Hallford w^th thappurtnaunces in the County of Middlesex to the Monnastery |

5.  of S^t Peter of Westminster in the said County of Middlesex sometime belonginge and appertaininge and parcell of the possesion thereof then late beeinge, after and now annexed to his |

6.  Highnes Honno^r of Hampton Courte in the said County of Middlesex and now parcell of the said Honno^r, beeing of the yeerelie vallue of [scribal space] (or thereabovtes) over and  above |

7.  all charges and reprises. And your said Oratour being thus lawfullie seised and possessed of the said Manno^rs lands and premisses w^th thappurtnaunces, and beeinge acquainted w^th |

8.  one Bonham Norton of London Esquire, and divers great and weightie dealinge beeing formerlie past betwene them. And he the said Norton standinge ingaged for your said Oratour in |

9.  certaine somes of monie not yett paid by the said Norton, hee the said Norton abovte half a yeere <last> past, did cause your said Oratour to make and seale vnto him the said Bonham Norton  |

10.  some lease or condicõnall assuraunce of the said Manno^rs and premisses for his the said Nortons indemnitie to save him harmeles for the ingagement aforesaid in trust and confidence and for the |

11.  meene and onlie securitie of the said Norton § and yet w^th severall condicõns for the payment of the severall somes amounting in the whole to the some of one thowsand two hundred |

12.  pounds or thereabovtes vnto the said Bonham Norton his execut^rs or assignes abovte the seaventeenth day of this instaunce Marrch, By wch said leases or condicõnall assuraunces yo^r said Orato^r |

13.  and his assignes was quietlie and peaceably to have hold and enioie the said Manno^rs lands and premisses w^th thappurtnaunces vntill the said seavententh day of this instaunt March and |

14.  and vntill default of payment should bee made of the said severall somes amounting to the whole vnto the said some 1200^li vnto the said Bonham Norton his executo^rs and <or> assignes (as by the |

15.  said leases or assuraunces condicõnall soe made as aforesaid wherevnto relation beeing had more att large it doth and may appeere. But now so it is maie it please yo^r good lo^pp. that your said |

16.  Oratour beeinge carefull to paie the said somes and to secure the said Bonham Norton from the same did (before the said monies or anie of them grew due) permitt and suffer the said |

17.  Bonham Norton to receive divers somes of money to a farre greater vallue, w^ch in the interim and before those daies of paiment did growe due vnto your Oratour. And your Oratour |

18.  intreated the said Bonham Norton w^th the said monies so received by him of your Oratours to satisfie the said ingagementes and all and everie some and somes of monie and wares due to |

19.  himself from your said Oratour. yett nevertheles the said Bonham Norton thirsting and desiringe to gett and obteine your said Oratours said Manno^rs and landes aforesaid w^thout anie |

20.  lawfull or valluable consideracõn given, or to bee given vnto your Oratour for the same doth most vnconscionablie (the said daie of paiment of the said severall somes amounting in the whole |

21.  to the some of 1200^li bring come although he hath received all the said some of one thousand two hundred poundes and a farre greater some from your said Oratour by the meanes and |

22.  in the Manno^r aforesaid doth not onelie disquiett and interrupte your said Oratour and his Ten<a>ntes and ffarmo^rs in the quiett occupacõn of the premisses, but challengeth the said |

23.  Manno^rs and premisses as his owne and giveth out that hee hath an absolute estate thereof and that the same are forfeite vnto him the said Bonham Norton for the non payment of the said |

24.  some of one thowsand two hundred pounds, Where in truthe there is no such cause nor cullour of cause for the said Bonham Norton to challendge or have the said Manno^rs lands and |

25.  premisses And the said Bonham Norton having gotten into his handes custody and possession the deeds evidences lettres Pattents leasses and other wrytinges tovching and concerninge the said |

26.  Manno^rs and premisses of right belonginge vnto yo^r said Oratour doth now not onlie most wrongfullie and vnlawfullie challendge and claime the said Manno^rs lands and premisses afore |

27.  said, but hath of late made divers entries into the said Manno^rs lands and premisses and seacrettlie and vnduelie contrived and made divers seacrett and fraudulent estates of and |

28.  in the said Manno^rs lands and premisses to divers persons vnknowne to yo^r said Oratour of purpose to wronge defeate disinheritt and dispossesse yo^r said Oratour of the same And doth |

29.  labour and endeavour to perswade and inforce your said Oratours Ten<a>nts and ffarmours who occupie the said Manno^rs landes and premisses or some parte thereof to pay theire rents now |

30.  due vnto your said Oratour vnto him the said Bonham Norton contrarie to all right equitie and good conscience, & to your Oratours great losse hinderaunce and vtter vndooing In tender |

31.  consideracõn whereof and forasmuch as your Oratour by the strict Course of the Comon law is vtterlie remedilesse in the premisses vnlesse your Lo^pps accustomed ayd (accordinge |

32.  to equitie and Conscience) bee vnto yo^r Oratour in this behalf extended May it therefore please your good Lo^pp (the said premisses considerred) to graunte vnto your said Orato^r |

33.  the Kinges Ma^tes most gratious writt of Subpena to be directed vnto the said Bonham Norton comaundinge him thereby at a certaine daie and vnd^er a certaine paine therein to be |

34.  lymitted to be and personnally appeere before your good Lo^pp in his Ma^tes high Courte of Chauncery, then and there vppon his corporall oathe to annswere all and everie the |

35.  said matters and premisses. And also that your good Lo^pp. wilbee lykewise pleased to graunt vnto your said Oratour the Kinges Ma^tes most gratious writt of Iniunction to be |

36.  directed vnto the said Bonham Norton and all clayminge by or vnder him comaundinge them and every of them thereby quiettlie to permitt and suffer your said Oratour his tenanets |

37.  and ffarmo^rs of the said Manno^rs lands and premisses to occupie and enioie the same vntill the cause shalbee heard, or otherwise ordered in this honno^ble Courte And furth^er |

38.  to stand to such further Order and direction herein as vnto your honno^ble Lordshipp shall seeme to stand w^th equity and good Conscience. And your Orator shall daylie pray [word].

                                                                                    [Endorsed:]            Ph: Gerard.

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