Oxford's Answer

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[2] 25 Octob{ris} 1598

The Answere of the Right honorable Edward Earle of Oxon' defendant to the Bill of Complaint of Iudyth Ruswell wydowe Complaynant

The said defendant savinge and reservinge vnto him selfe all advantage of excepc{i}on to the vncertentye and Insufficency of the said Bill of Complaint dothe saye that the said bill of Complaint contayneth manye vntrewthes, and is verye vncerten and Insufficient in the lawe to be answered vnto for divers and sondrye apparant causes and manyfest Imp{er}fecc{i}ons therein appearinge, ffor answere vnto the said bill of Complaint he this defendant dothe saye that true it is that the said Will{ia}m Ruswell in the said Bill of Complaint named late husband of the said Complaynant, about Twentye yeares nowe last past was servant and Taylor vnto this defendant and did for some tyme make divers garment{es} and apparrell for this defendant and some of his Servant{es} but what or howe manye this defendant dothe not nowe certenlye knowe nor Remember, Beinge longe sythence, ffor this defendant sayeth that he this defendant is verye suer that the said Will{ia}m Ruswell hathe not made anye garment for him this defendant nor for anye of his Servant{es} by this defendant his appointment at anye tyme within the space of Eighteene or nynetene yeares nowe last past, as he this defendant Remembreth / And this def{endan}t further sayeth / that he this defendant hathe paide and satisfied vnto the said Will{ia}m Ruswell for all suche worke as the said Will{ia}m Ruswell did for this defendant or anye of his servant{es} by the direcc{i}on or appointment of this defendant nether did the said Will{ia}m Ruswell at anye tyme take vp by this defendant his appointment or to his vse vppon the creditt of the said Ruswell anye silke silver or gould lace, silkes, or other Stuffe for anye the garment{es} of this defendant or anye of this defendant{es} servant{es} by the appointment of this defendant, nether was the said Will{ia}m Ruswell at anye tyme of suche creditt as he could soe doe And this defendant further sayeth that the said Will{ia}m Ruswell aboute seventene or eightene yeres sythence, havinge receaved certen cloth of gould and sylver, and other Stuffe of this defendant to the valewe of eight hundred poundes or theraboutes to this defendant{es} vse did runne awaye (long blank) with the same sythence which tyme this defendant ^\\albeit he this def{endan}t hath manye tymes caused dilligent enquirey to be made for him the said Ruswell// hathe not seene him nor never receaved nor had the said cloth of goulde and sylver and Stuffe nor anye satisfacc{i}on or recompence for the same, nether did the said Ruswell at anye tyme demaund the said supposed dett or anye p{ar}te thereof of this defendant And this defendant further sayeth that there is not anye p{ar}te of the said Supposed dett allowed in anye of the said three supposed Bookes for good and due dett by anye aucthoretye from this defendant soe to doe, nor by anye of his officers in that behalfe. without that that the supposed dett of one Thowsand poundes in the said Bill of Complaint menc{i}oned or anye p{ar}te thereof hathe bynne due vnto the said Complaynant or the said Will{ia}m Ruswell her late husband [by the space of Twelve yeares or thereaboutes] as in and by the said Bill of Complaint is verye vntruelye surmised and alleadged. And without that that after the deceasse of the said Will{ia}m Ruswell the Adm{ini}strac{i}on of all the goodes Chattells and dett{es} of him the said William Ruswell were graunted vnto the said Complaynant out of the Prerogatyve Courte of Canterburye, Or that by force of the said supposed admynistrac{i}on the said Complaynant is or ought to have the said supposed dett or anye p{ar}te thereof of the said defendant, As in and by the said Bill of Complaint is verye vntruely surmised and alleadged. And without that that this defendant knoweth that the said Supposed dett or anye p{ar}te thereof was due and oweinge by him this defendant vnto the said Will{ia}m Ruswell late husband to the said Complaynant Or that the said Complaynant hathe bynne a contynuall suter vnto this defendant by several petic{i}ons delyvered vnto him by the said Complaynant for the payment of the said supposed dett, as in and by the said bill of Complaint is verye vntruelye surmised and alleadged. And without that that the said Complaynant delyvered a petic{i}on vnto the Quenes most Excellent maiestie declaringe thereby her poore estate and case. Or that vppon the said petic{i}on it pleased her highnes of her Gracious goodnes to vouchesafe to referre the said Compl{ainan}t to sue the said defendant in this Honorable Courte for the said Supposed dett as in and by the said bill of Complaint is very vntruely surmised and alleadged. And without that that anye other matter or thinge in the said Bill of Complaint menc{i}oned materiall or effectuall for this defendant to answere vnto and before herein not sufficiently confessed and avoyded denyed or Traversed is true all w{hi}ch matters this defendant is readye to averre and prove as this Honorable Court shall award and prayeth to be dismissed out of this Honorable Courte &c.

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