Thomas Bulkuley vs. Randall Harrison and Mathew Dyall

PRO C2/Eliz/B26/1 (complaint only)

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PRO summary: A messuage or tenement in the parish or lordship of Warmynchum, in the county of Chester, held on lease from Edw. de Vere earl of Oxford.

To the Right honorable S{i}r Nicholas Bacon Knight Lord Keper of the great seale of England

In hu{m}ble mane{r} complayninge sheweth vnto yo{ur} good Lordshippe your suppliant and dayly Orato{ur} Thomas Bulkuley gent{leman} S{er}va{u}nte to the Right honorable Edward de vere Earle of Oxford Lord great Chamberlayn of England vicou{n}t Bulbeck and Lord of Badlesmere and Scales That when as the said Earle was seased in his demesne as of fee or fee taile of and in one messuage or ten{emen}t w{i}th thap{ur}tena{u}nc{es} lyenge and beinge in the p{ar}ishe or Lordship of Wurmynchum in the Com{ite} of Chester and so therof seased by his indenture beringe date the xxiijti daye of novembre in the fourtenth yere of the raigne of o{ur} sou{er}aigne Lady the Queenes ma{ies}tie that nowe is did demise and to farme lett the p{re}miss vnto yo{ur} said Orato{ur} for and duringe the terme of xxj yeares thence next and immedyatly followinge yeldinge and payinge therfore yearly vnto the said [yearly] Earle ^\\his heires & assignes// one yearly rent as by the said indenture more playnly doth appere by vertue of which demise yo{ur} said Orato{ur} entred into the p{re}misses [and] ^\\&// was thereof possessed So it is if it maye please your good Lordshippe that dyu{er}se evidenc{es} writing{es} ch{art}res and munyment{es} conc{er}ninge the said p{re}miss and of right to your said orato{ur} belonginge are casually com{m}e vnto the handes custody and possession of Randall Haryson and Mathewe Dyall who by colo{ur} of havinge therof have not only most wrongfully and vnlawfully entred into the p{re}miss{es} and the issues therof com{m}inge convented to their own vse but also haue devised made and contrived c{er}tein secret estates and conveya{u}nc{es} of the same entendinge therby to giue vnto them selves aswell the enheritance therof [as the possesion] from the said Earle [as] and his heires ^\\to whom ye rent & reu{er}c{i}on of the same appertayneth// as the possession and estate w{hi}ch yo{ur} said Orato{ur} hath therin. And albeit yo{ur} said Orato{ur} hath dyu{er}se and sondry tymes required the said Randall Harrison and Mathewe Dyall to delyu{er} vnto him the said evidenc{es} writing{es} ch{art}res and munim{en}t{es} to p{er}mit and suffre him to haue vse and enioye in quiet man{er} the p{re}miss{es} yet notw{i}thstandinge they and ether of them so do & hath hitherto vtterly refused and yet doth refuse contrary to all equity and good conscience to the great losse and hindra{u}nce of yo{ur} said Orato{ur} and ^\\to// the [dischen] dicenheritance of the said Earle vnles yo{ur} good Lordshipes ayd be vnto him shewed in this behalf In considerac{i}on wherof and for asmuch as yo{ur} said orato{ur} knowth not the c{er}ten date of the said evidenc{es} writing{es} Ch{art}res and [my] munym{en}t{es} nor wherin the same be conteyned So that yo{ur} said Orato{ur} is withowt all remedy for the recouery of the same and consequently throughe the want therof void of any help for the quiet ocupieng and enioynge of the p{re}miss{es} by the stricte order and course of the com{m}on Lawes of the Realme maye it please yo{ur} good [+Lordship] to graunt to yo{ur} said Orato{ur} the Quenes ma{ies}ties moste gracious write of Sub pena to be directed to the said Randall Harryson and Mathewe Dyall comaunding them and ether of them at a c{er}ten day and vnder a c{er}ten payn p{er}sonally to appere before yo{ur} good Lordship in this moste hono{ur}able Courte, then and there to answer vnto the p{re}misses and to abide suche order therin as to yo{ur} good Lordshippe shalbe thought convenyent vnto equitie and good conscience

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