Countess of Oxford's Answer

PRO REQ 2/388/28/2

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xo die Novembris Anno R{egni} Regis Iacobi Anglie ffranc{ie} & hib{er}nie octauo et Scotie xliiijo

The Answere of the Ladie Elizabeth Vere Countesse Dowager of Oxenford to the Byll of Compl{ain}t of Edward Iohnson Complayn{an}t

The said Lady Elizabeth Countesse [of Oxenford] Dowager of Oxenford to geue satisfaction to this honorable Courte & to all others howe false vniust & Clamorous the said Complainant{es} demaund{es} & allegations by him set forth in his said Byll of Complainte are, for Aunswere to the same Byll of Complainte saith That she doth not knowe that Edward late Earle of Oxenford her deceased husband had ever anie howse at Playstou in the said Bill of Complaint mentioned and is well assured that he never had anie such sithence his Marriadge w{i}th her, the same being nowe allmost twenty yeares sithence Neyther doth shee the said Lady Countesse Dowager knowe or ever heard that the said Complayn{an}t was ever ymployed in anie worke of the said late Earles eyther before the tyme of her Marriage w{i}th the said Earle or sithence. And yf he were yet shee is verely p{er}swaded that he was fully satisfied & paid for all such worke as he did or p{er}formed for the said Earle as soone as he had done & finished that work he vndertooke or els beforehand. ffor the said Countesse sayth that in all the tyme sithence shee married w{i}th the said late Earle shee to her nowe remembrance never heard of anie Workeman or other p{er}son whatsoever that ever made demaund or challenge of anie debte owinge to him by the said late Earle excepte one by one (blank) [=William Ruswell] whoe having bene a Tayler for the said late Earle his Servant{es} did firste demaund & after sue for a certaine debte he p{re}tended to be due & owinge vnto him by the said Earle supposinge the same Earle could not haue proved anie paym{en}t or satisfactio{n} of that debte But yet p{re}vayled not for that when that cause came to tryall one Hubbard then one of the six Clarkes of the Chauncery whoe formerly had bene ymployed in the said Earle his affaires did make plaine & manifeste proofe when & howe the said debte was clearly & fully satisfied & dischardged. Neyther to her Remembrance hath shee the said Countesse dowager at anie tyme sithence the said late Earle her husband{es} decease bene ever demaunded anie debte owinge by the said late Earle excepte onely by one Thomas Gurling whoe sueinge for a debte p{re}tended to be due vnto him fro{m} the said late Earle was at the triall thereof overthrowne vppo{n} manifest proofe made of the satisfaction of that debte & allsoe by the said clamourous complayn{an}t whoe first & for a long tyme together did challendge his p{re}tended debte for worke by him done at a house w{i}thout Bishoppesgate London heretofore the said late Earles but by him sold away before his Marriage w{i}th her Neither did shee to her best remembrance ever heare the said Complayn{an}t make mention of anie worke he had done for the said late Earle at [.] anie house at Playstow vntill shee heard the said Bill of Complaint read in w{hi}ch he soe surmiseth the same debte to growe. Neyther as it seemeth by the blancke lefte in [the] ^\\his// said Bill (for inserting the name of the County) doth the Complayn{an}t as yet knowe in what County the said howse at Playstow lyeth in which notw{i}thstandinge in his said Bill he suggesteth himself to haue p{er}formed that worke for w{hi}ch he thereby challengeth a debte of about threescore pound{es} w{hi}ch well sorteth w{i}th other his allegations in the same bill whereby he setteth forth as a ground of the contracte vppo{n} w{hi}ch he buildeth the demaund of the said debte that the said Earle himself did send for him, did in p{er}son hire & agree w{i}th him for the manner of his worke & certeinty of his wages. Whereas it is to [=too, very] well knowne the said Earle in matters of buildinge or other ymploym{en}t (thoughe of a farre greater weighte & consequence) did never discend to anie such p{ar}ticuler manadging of his owne affaires, but referred the ordering disposinge & paym{en}t{es} of & for them to his officers & servant{es}. And where the Complayn{an}t in his said Byll suggesteth that the said late Earle ofte acknowledged the said debte to be owinge to the said Complain{a}nt, promised him speedy paym{en}t & spake to her the said Lady Countesse dowager to pay & satisfie the same for aunswere therevnto the said Countesse vtterly denieth that ever the said late Earle did speake to her to anie such effecte or purpose but contrarywise when the said complayn{an}t dyd sometimes in a frantick manner come & w{i}th clamo{u}r importune the said Earle for some money he then p{re}tended the said Earle owed him for worke he had done at his said howse w{i}thout Bishoppesgate London the said Earle hath ofte in her p{re}sence or hearinge protested he owed him nothinge at all and that he would cause him to be laid by the heeles yf ever he came more to him about anie such matter. Neyther would the said Earle ever geue him or suffer anie thing to be geven vnto him least that should encourage him at other tymes to come & reuiue his clamourous demaund{es}. And where the Complayn{an}t surmiseth that vppo{n} the said Earles intreatinge ^\\of// her the said Countesse Dowager to satisfie the said Complaynant the said debte he the said Complayn{an}t hath at severall tymes receaved (as p{ar}te of his said debte) three pound{es} or thereabout{es}, the said Countesse for aunswere therevnto saith that sundry tymes sithence the death of the said late Earle the said Complayn{an}t hath w{i}th great clamo{u}r importuned her for some money sometyme vppon Christmasse & other festivall dayes swearinge & protestinge he had noe bread for his dinner that day & therevppon out of meere com{m}isseration & pitty shee hath geeven vnto him sometymes tenne shilling{es} & sometymes five shilling{es} at a tyme but never gaue him soe much as one penny in p{ar}te of paym{en}t or satisfaction of anie debte he claymed, but meerely & onely out of a charitable respecte of that extreame necessity wherein he p{re}tended himself to be. Of w{hi}ch he hath (as the same Countesse hath sithence p{er}ceaved) bene soe farre fro{m} a thankefull acceptance that he hath thereby bene encouraged to further Clamo{u}r & ymportunity w{hi}ch hath made her the said Countesse to resolue never hereafter to be drawne eyther by his pittifull lamentations [.] or his clamorous importunityes to bestowe anie penny more vppon him as beinge fully satisfied & p{er}swaded in her consciene that there is not soe much as one penny due vnto him by or fro{m} the said late Earle her deceased husband w{i}thout that that the late Earle Edward did ever ymploy him to work at anie his howse at Plaistou or did euer agree w{i}th him for anie wages or ever accepted anie billes of Reckoning{es} fro{m} him, or ever acknowledged anie debte to be owinge to him or promised him paym{en}t of anie money as in the said Bill of Complainte most falsely and clamorously is alleadged And w{i}thout that that anie other matter or thinge in the said bill of Compl{ain}t contained materiall or effectuall to be aunswered vnto & not before herein sufficiently aunswered confessed, & avoided traversed or denied is true All w{hi}ch matters [......] ^\\the sayd Lady Countesse Dowager// is ready to avere & proue as this honorable Courte shall award & prayeth to be dismissed out of the same ### ### And that the said Complayn{an}t may be well ## punished for his false & vntrue Clamo{u}r.

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