Oxon Comes vs. John Cockerell; for an account and title deeds.

PRO C2/Eliz/O1/29

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PRO summary: The manors of Crippingehall and Bridgehall in Wakes Colne, and divers other manors and lands in Essex, called Bridgehall Lands and Bridgehall Meadows, which descended to plaintiff as son and heir of the late earl, and of which premises the defendant was steward.

PRO C2/Eliz/O1/29/1 (complaint)

xviij die Novembris 1581

To the Right honorable S{i}r Thomas Bromley knighte Lorde Chancello{ur} of Englande./

Shewethe and complaynethe vnto yo{ur} Lordeship Edwarde de Veer Erle of Oxenforde and Lorde great Chamberlayne of Englande. That wheras the Right honorable Iohn de Veer late Erle of Oxenforde father to the said Erle that now is was in his lyfe tyme lawfully seazed in his demesyne as of ffee of the Mannors of Crippingehall and Bredghall in Wakes Colne in the Countye of Essex And of dyvers other Mannors Landes tenement{es} and Hereditament{es} in the said Countye of Essex callyd Bredghall Land{es} and Bredgehall meadowes w{hi}ch said Mannors and other the p{re}misses descendyd and cam to the said Erle that now is as sonne and heire to the said late Erle. And wher also one Iohn Cockerell hathe of longe tyme served and was deputie stewarde vndre suche p{er}son and p{er}sons as were the Stewardes of the Mannors and possessyons of the said late Erle and of therle that now is So yt is yf yt please yo{ur} hono{ur} that dyvers and sundry Courte Rolles Rentalles Evydences Ch{art}res wrytinges and myniment{es} concerninge the said Mannors Land{es} tenement{es} and hereditament{es} of the said late Erle and therle that now is and concerninge also the said Mannor of Bredgehall of very right belonginge to the Erle that now is, dyd com{m}e vnto the handes and possessyon of the said Iohn Cockerell who carryenge greate affection to dyvers p{er}sons that now doo withholde from the now Erle the Compl{ainan}t dyvers of his landes and possessyons and of his Rentes and services have of late confederatyd w{i}th the said p{er}sons And of late confederatinge w{i}th one Christyan Turno{ur} wydowe late the wyfe of one Iohn Turno{ur} gent{leman} sometyme the servante and surveyo{ur} of the said late Erle of Oxenford, w{hi}ch sayd Christyan pretendethe tytle to dyvers of the said Landes and tenement{es} belonginge to the said Erle, by reason of some fraudelent conveyaunces and devyses made by the said Iohn Turno{ur} and throughe the same confederatinge dothe not only w{i}thholde from the said now Erle the foresayd Courte Rolles Rentalles and other the wrytinges and premisses but also dothe [indente] intende to delyver vnto the said Christyan dyvers of the said Courte Rolles wrytinges Ch{art}res escript{es} and myniment{es} to maynteigne hir said p{re}tensed tytle And the said Iohn Cockerell throughe the havinge of the said evydenc{es} hathe also enteryd into dyvers p{ar}celles of the premisses him selfe p{ar}cell of the Mannors of Crippinge Hall and Bredgehall and of the Land{es} and meadowes callyd Bridgehall Land{es} and brydgehall Meadowes And dothe dalye practyse devyse and make vnto him selfe and others to his vse dyvers secrett and pryvie estates of free holde and inherytaunce in and to dyvers p{ar}celles of the same premisses myndinge therby wrongefully to disinherytt the said Erle therof forever, and so will do yf remedye be not by yo{ur} good Lordeship herein provydyd And for as muche as the said Erle knowethe not the certen dates nor nombre of the said Courte Rolles Rentalles Evydenc{es} Ch{art}res and wrytinges nor whether they be in any bagge boxe or cheste locked or sealyd The said Erle is w{i}thout all remedye to recover the same by waye of action by thextremytie and strycte ordre of the com{m}on Lawe Maye yt therfore please yo{ur} good Lordeship the p{re}misses consyderyd to graunt vnto the said now Erle the quenes Ma{ies}t{ies} most gracyous wrytt of Sub pena to be directyd vnto the said Iohn Cockerell com{m}aundinge him therby p{er}sonally to appere before yo{ur} good Lordeshipp in the Quenes Maiestyes highe Courte of Chauncery at a certen daye and vndre a certen payne therin by yo{ur} Lordeship to be lymyted then and ther to aunswere to the p{re}misses and to stande to suche further ordre therin as to yo{ur} good Lordeship shall seme to stande w{i}th Lawe equitie and Consyence And the said Erle shall daly wishe the longe p{er}servac{i}one of yo{ur} hono{ur}

PRO C2/Eliz/O1/29/2 (answer)

The aunswere of Iohn Cockerell defendaunte to the bill of Complaynte of the right honorable Edwarde de Veer Earle of Oxenford & lord great Chamberlayne of England Complain{au}nte.

The said defendaunt by the honorable patyence of the said Earle Sayth that the said bill of Complainte is vncerteyne & insufficient in the lawe, & most of the matter therin conteyned vntrue and set foorth onelye (as this defendaunt verilye beleveth) by vntrue surmyses & informac{i}ons made to the said Earle the Complayn{au}nte of some p{er}sons bearinge malyce & displeasure against this defendant to put the said defendaunt to suite, trouble, & charges w{i}thout anye iust cause or matter w{i}thout the knowledge of the said Earle whervnto though the said defendaunt ought not to be compelled to make any aunswere (as he thinketh) yet neu{er}theles yf the said defendaunt shalbe compelled by this honorable Court to make aunswere thervnto then sauinge to himselfe all excepc{i}ons & advauntages to the said bill of Complaynt ffor aunswere to the said byll so farre as this defendaunt his knowlege therof extendeth he saith that he thinketh it true, That the said right honorable Iohn de Veer late Earle of Oxenford fath{er} to the said Earle now Complayn{au}nt was in his life time seased in this demesne as of fee of the said manno{ur} of Creppinghall & of twelve akers in a common meadow called Bredghallmedowe And the said Earle therof beinge so seased longe tyme before his death did demyse & letto [=let to] ferme the said manno{ur} of Creppinghall w{i}th all & singuler thapp{ur}ten{au}nc{es} amongst oth{er} for terme of (blank) yeres yet endurynge vnto the same Iohn Turno{ur} named in the said Bill. And also he saith that he knoweth y{a}t the said Iohn Turno{ur} into the said manno{ur} & into the said medowe as p{ar}cell therof (as this defend{an}te thinketh) w{i}th the app{ur}ten{au}nc{es} did enter and was therof possessed. And he so beinge therof possessed died therof possessed. And before his death in his life tyme declared his last will & Testament and constituted the said Christyan named in the said Bill executrix of his last will & Testam{en}t. After whose death the said {Christ}ian into the said manno{ur} of Creppinghall & medowe w{i}th all & singuler the app{ur}ten{au}nc{es} entred and was therof possessed. And he further saith that aswell the said Iohn Turno{ur} in his lyfe tyme, as also the said {Christ}ian since the death of the said Iohn Turno{ur} at sundry times did appoint the said defendant to be Steward of the Court{es} of the said manno{ur} And the said defendaunt so beynge appointed Steward of the said Court{es} did kepe and hold divers Court{es} of & w{i}thin the said manno{ur} for the said Iohn Turno{ur} & {Christ}ian. And the Courtroll{es} of the said Court{es} there so by the said defendaunt holden & kept this defend{au}nt did Ingrosse in p{ar}chment, And the said Rowles so ingrossed from tyme to time vpon demaunde of the said Iohn & {Christ}ian did deliver vnto the same Iohn & Christyan so havinge in possession the said manno{ur} as this defendaunt then thought & yet thinketh, to him lawfullye & in duetie app{er}teyned to doe w{i}thout that the said defendaunt hath entred into the manno{ur} of the said Earle called Bredghall to the knowledge of this defendaunt, for he saith he did never knowe anye such manno{ur} of the said Earle called Bredghall. Or that the said defendaunt hath entred into anye the said landes & Tenem{en}t{es} called Bredghallandes & Bredghallmeadowes or conveighed anye estat{es} therof, Otherwise then as Steward of the said Court of the manno{ur} of Creppinghall, as occasion did serve for the said Iohn Turno{ur} & {Christ}ian so possessed of the said manno{ur} of Creppinghall as the said defendaunt & others did take & repute then to have lawfull Interest so to doe did graunte by Copie accordinge to the Custome of the said mannor in the Court of the said manno{ur} certeyne p{ar}cell{es} of land called Bredghalland al{ia}s Bredghall feild{es} p{ar}cell{es} of the auncient custum{er}ie landes of the said manno{ur} to such p{er}sons, as either by surrend{er} or discent then had interest & title thervnto by the said Custome as lawfull was for this defendaunt beinge Steward of the said manno{ur} so to doe, And w{i}thout that there hath come to thandes of this defendaunt anye Court Roll{es} or other Evidenc{es} of anie manno{ur} of the said Earle called Bredghall to the knowledge or remembraunce of this defendaunt, And w{i}thout that the said defendaunt hath confederate w{i}th anie p{er}sons w{i}thholdinge from the said Earle anye his mannors, land{es}, possessions, Rent{es} or s{er}vic{es} by anie fraudelent conveighaunc{es} or practises to w{i}thhold anie Court Roll{es} or evidenc{es} belonginge to the said Earle to mainteigne anie vnlawfull p{re}tensed title in suche manner & forme as in the said bill is vntrulye against him alledged ffor this defendaunt saith that he hath delivered to the officers of the said Earle divers Courtrowles ingrossed by this defendaunt of sundry Court{es} of the manno{ur}s of the said Earle w{hi}ch this defendaunt did kepe for the Executours of the said late Earle deceased, and for Thomas Gent Esquire his Lordships steward. And w{i}thout that y{a}t the said defendaunt hath conveighed to himselfe anye estat{es} of anie the possessions of the said Earle, Other then by his lawfull purchase of Seven akers of Custum{er}ie land{es} w{hi}ch he holdeth by Copye of the said Creppinghall, and w{i}thout that y{a}t he deteyneth from the said Earle anie Courtroll{es} or evidenc{es} of anie the mannors or possessions of the said Earle or hath in his custodie anye suche evidenc{es} other then the escrowes in Paper of such Courtroll{es} as hath bene ingrossed & delivered to his Lordships officers or to the fermers or bailyf{es} of the said Earle in due & convenient mann{er}, as farre forth as this defend{aun}t knoweth. And w{i}thout that, that anye other matter or thinge in the said bill conteyned & herin not confessed & avoided aunswered or trau{er}sed is true, or materiall to be Aunswered. All w{hi}ch this defendaunt is redie to averre. And therefore prayeth to be dismissed w{i}th his reasonable cost{es} &c/./

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