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Oxford & Atslowe vs. Bury et al.

STAC 5/O5/08/2 (answer/s 15 June 1580)

xv Junii 1580

The Ioynt & seuerall answers of Nicholas Tabor & Rychard Haynes defend{an}t{es} to the bill of compl{ain}t of Edward Erle of Oxenford & Edward Atslowe pl{ainan}t{es}

The said defendant{es} for answer sayne that the said bill of compl{ain}t agaynst them in this honourable courte exhibited is vntrewe & the matters therin contayned are devised, framed, feigned & sett forthe to putt the said defend{an}t{es}, being verye poore men to wrongfull vexaciones, costes, [&] trouble & charges intendinge to weary the said poore men whoe by reson of their povertie & want of lyvinge are not able to w{i}thstande or susteyne the greate charges of the sute for the triall of their innocency herin as also thereby to culloure the most wicked, disordered & Riottouse dealinge of Thomas clarke, W{illia}m Semor, W{illia}m Price & others vnknowne servaunt{es} to the sayd Edward Atslowe & by his com{m}aundment[.] of Iohn Bundocke, charles bundocke Edmund vincente, George hilles, W{illia}m knightbridge, Iohn Hartford, W{illia}m Elliotte, Robart clarcke, Robarte buckler, Rychard frema{n}, Iohn Coppin, Thomas Geele, & others vnknowne / which said bill is insufficient to be answered vnto the advantage of exceptione to the insuffyciencye thereof vnto the said defendant{es} now and at all tymes hereafter saved for furder declaratione & manifestatione of the trothe saye that ffraunces bury gent' one of the defendants beinge in the Right of Anne his wyf lawfully seized in their demesne as of frehold of the manno{u}r of pressones in the parishe of Southanningfeld in the countie of Essex w{i}th the app{ur}tenanc{es} of w{hi}ch mannor one p{ar}cell of com{m}on or wast grownde called pressones common is and tyme owte of mynde of man hathe allwayes byne p{ar}cell & app{er}tayninge appon w{hi}ch p{ar}cell of common the said ffraunces bury and his predecessoures & thay whose estate he & his said wif now haue & had in the said manno{u}r & p{ar}cell of com{m}on haue tyme out of mynde of man felled & lopped wood & trees growinge in & appon the said com{m}on from tyme to tyme as in & appon their p{ro}pp{er} inheritance and frehoulde. Withowt that that \\the said com{m}on callede pressones common hathe by the tyme in the said bill expressed app{er}tayned to// the said manno{u}r of Downhame or that the ancestors of the said Erle of Oxenforde or any other for them or to their or his vse, did ever fell to the knowledge of the defendant{es} any wood or trees in or appon the said co{m}mon of pressones as in the said bill is vntrewly alledged / Withowt that also that the said defendants did at any tyme in any disordered manno{u}r or Riottouse wise fell ^\\or carrye awaye// any wood or trees in or from the said common or that the said defendant{es} did violently assault beate wounde or evill intreat any of the servant{es} of the said Edward Atslowe or that that did in any Riottouse manner assemble them selves appon the said comon as in the said bill is vntrewly declared. And withowt that also that the said defendant{es} or any of them did Riottouslye assaut beate evill entreat or wounde the said Iohn Bundocke, Charles Bundocke, Edmund Vincent Georges hilles , William Knightbridge, Iohn Hartforde, William Ellyott, Robarte clarke, Robart Buckley Rychard ffreman & Iohn coppin or any of them to their knowledge onless yt were in their owne defence and their p{re}servacione of the possessione of the said ffraunces burye & the inheritaunces of the sayd & Iohn Paschall And withowte that ther is any other matter or thinge in the said bill of compl{ain}t contayned materyall in the lawe to be answered vnto & nott herein sufficiently confessed & avoyded, traversed or denyed is trewe, all w{hi}ch matters the said defendants are Ready to averr & proue as this honourable court ## shall awarde & praye to be dismissed owte of the same with their Reasonable costes & charges by them in that behalf wrongfully susteyned

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