MRP: C2/Eliz/D2/45 f. 1

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C2/Eliz/D2/45 f. 1



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//To the Right Honorable S:r Thomas Egerton knight//
//Lord Keeper of the greate Seale of England//

//Most humbly complaaninge sheweth unto your good Lordshipp your dayley Orator Maximilian Dalison of Hallinge in the Countye of Kent Esquire That whereas one//

//John Poxnett late Lord Bishopp of Rochester, XXXXXX of York to the nowe Lo: Bishopp there, in the fowerth yeare of the Raigne of our late Souaraigne Lorde Kinge//

//Edwarde the Sixt beinge lawfully seised in his demesne as of ffXXXX in the Right of the said Bishoppricke of the mano:r of Hallinge with the Appurtenances extendinge into//

//the parishes of Hallinge and Snodland in the countye of Kent and of the Bishopps place next with the Reverssons of the farme called Haleyard and other lande then//

//in lease by severall demises, And soe beinge thereof seised in consideracon of one hundred poundes to him payed for á ffyne, by Robte Deane late of Hallinge//

//aforesaid deceased and other consideracons dyd about the same tyme by deeds indented under his seale with the assent and confirmation of the deane and chapper//

//of the same place declared under the comon seale of the sayd Deane andChappter demise and lett unto the said Robte Deane the said Manno:r of Hallinge With the//

//appurtenances and the Bishopps place theXX with the Reversions of the said farme called Haleyarde and the said other lands for nynetye and nyne yeares from the feast//

//of S:t Micheall the Archangell then last past before XXXXXXXXXXXXXXXXXX indented for the yearly Rente of one and Twentye pounds Seaventeene shillinges and//

//one penny to which lease such other summarise as had any particular XXX XXX XXXX to the said Roberte Deane or of any parte thereof dyd//

//sewally attorne, And by force of that demise the said Roberte Deane entered into the said manno:r Bisshopps place XXXX the other landes demised beinge in the possession of//

//the said Bishopp and the tenantes of suche of the said demised premisses as then helde any parte of the said manno.r XXX dyd also attorne unto the said Robert//

//Deane, By and after whose death thestate interest and terme of yeares aforesaid by the last Will and Testament of the said Roberte Deane or as Executor or//

//Administrato:r unto him or by other good and sufficient assurance and conveyance or by some other lawfull meanes came unto one Will:m Dallison ffather of your orator//

//who married the daughter of the said Robert Deane, And the said William Dallyson youre Orators said ffather by vertue thereof entered into all and singuler the premisses//

//and was thereof lawfully possessed and held and enioyed the same paceably dureinge all his lyfe tyme, and the Rents and pffitts thereof had and receaved by the space of//

//many yeares, and soe beinge thereof possessed by his last Will and Testam:t devised willed and gave all his estate interest and terme for yeares of and in the premisses unto//

//youre said Orator. By vertue whereof your said Orator with the consent and lycence of the Executors of the said Will:m Dallison entered into the said premisses and was//

//and yett is thereof lawfully possessed. Nowe soe yt is yt it maye like yo:r good Lordshipp that one Thomas Raynes of Burham in the said County of Kent yeoman and others//

//before him whose estate he hath have by a longe tyme helde enioyed and occupyed one pcell of lande contayninge by estimacon thirtie acres of land called Crabtree lyinge//

//and beinge in the parishe of Snodlande aforesaid, beinge pcell of or belonginge unto the said Mannor of Hallinge, and by the said deeds Indented demised unto the said Robte Deane//

//But whether they have ?houlden and enioyed the same by force of any demise or lease made by or from any Bishopp of Rochester before the said lease made unto the said Robte//

//Deane, or by demise or lease made by or from the said Robert Deane your Orator cannot learne, but suer he is, that he is well able to prove that the Rent for the said pcell//

//of lands called crabtree was dewly XXXXXXX and payed unto the said Robte Deane by all his lyfe time after the said lease to him made as is aforesaid And after his death//

//unto the said Willm Dalison by all his lyfe tyme, But dureinge your Orators minoritie he hath detayned and with houlden the Rente for the same And although//

//the said Thomas Raynes doe well knowe all the premisses to be trewe and that him selfe hath payed Rent for the said thirtie acres of land either to the said Roberte Deane//

//or to the said Willm Dallison And alsoe well knoweth yt to be trewe that in right and equitye he ought either to paye unto//

//your Orator yearly rent for the saide thirtie acres of lande of suffer yo:r Orato:r to have and enioye the possession thereof yet the said Thomas Raynes ever since the death of//

//the said Willm Dalison hath not payed unto yo:r Orator any Rent for the said thirtie acres of lande, and yet houldeth and keepeth the possession thereof from yo said Orator//

//And haveinge beene often tymes demanded rent therefore denyeth to paye any unto your Orator, and yet pretendeth and giveth out in speaches and wordes that he hath//

//?known from estate or terme for yeares in the said parcell of land, but Will not declare or manifest whate estate or terme he hath or claymeth to have therein, nor What rent he//

//is to paye for thesame neither yet under What XXXX or agreemente he is to have the same, neither yet whether his estate therein be by demise made by any Bishopp of//

//Rochester, or by the said Roberte Deane or William Dalison, Whereby yf yt be trewe that he hath any estate therin by lease, as he p:rtendeth and gyveth out yo:r said Orator//

//is utterly voyde of any remedye at the comon lawes to recover any Rent by reason he knoweth neither the certaintye of the Rent nor of the terme, nor of whose demise//

//the same is, In tender consideraton Whereof and for soe ?much as yo:r Orato:r hath not in his hands any evidences or writtinge mentoninge any estate demise or lease grannted unto//

//the said Thomas Raynes or any other whose estate he hath, Whereby may appeare What rent hath formerly been payed for the said thirtye acres of land, nor Whether the interest//

//of the said Raynes therein yf any he habe were grannted by lease What rent hath formerly beene payed for the said thirtye acres of land, nor Whether the interest//

//for which incertainties yo:r Orato:r sayeth of all remedy by the dewe course of the common lawes for Remidye of the said Rent and hath noe meanes by common lawe to//

//enforce him to declare his estate therein, nor what rent he ought to pay nor for howe longe tyme the same is behinde unpayed and to whate ?tenante and agreem:ts he is to hould and enioye the same And for that yo:r Orato:r//

//hopeth the said Raynes will uppon his corporall othe confesse and declare the truth concerninge the p:rmisses as in right equity and conscience he ought to doe beinge//

//called before your Lordshippe, Maye yt please Yo:r Lordshipp to grannt unto your said Orato:r the Queenes ma:ties most gratious writt of Subpena to be directed//

//unto the said Thomas Raynes thereby comandinge him at a certayn daye and under a certayne payne therin to be lymitted ?as personally to appeare before yo:r//

//good Lordship in her ma:ties highe courte of Chancerye then and there to answeare unto the premisses and further to abyde such order and direction therein as//

//to Yo:r good Lordshipp shall seeme to stande with equitie and good conscience And your Orato:r shall dayely praye to god for yo:r good Lordshippe with XXXXse of//

//muche honor longe to contynewe//

//?Marteyn HaddXXX//