sworn before W Mowse Ford Powel (inserted) the answer of Jn Bragg the other defendant to the bill of complaint of Roger Harlakenden esq complainant the said defendant saith that the said bill of complaint exhibited against him in this most honourable court is as he is informed by his learned counsel both incertain and insufficient in the law to be answered unto and devised and set forth as he is verily persuaded rather of purpose to vex and molest him than for any just cause of complaint the advantage of all which incertainty and insufficiency being at all times saved to this defendant the said defendant answereth and saith that the said complainant hath in the names of the said Thos Barfoot and Antho Luther the surviving lessors of this defendant brought an action of debt against the defendant in her majesties court of the pleas before her highness to be holden for the said rent of 60li which action there depending undecided this complainant hath brought this present suit in her highnesses court of chancery before your lordship for the self same rent whereupon this defendant demandeth judgement and prayeth to be dismissed from this honourable court nevertheless if he shall be compelled to make further answer then he for answer unto the material contents of the said bill for as much thereof as concerneth himself saith that true it is that he this defendant was possessed of the said lodge and 380a of land by force of the said demise to him made by the said Thos Barfoot Thos Luther and Antho Luther in manner and form as by the said complainant in his said bill is alleged but he saith that he being so thereof possessed did not know of any bargain sale alienation assignment and setting over unto the said Hen Josselin mentioned in the said bill of the estate term lease and interest for years to come which the said Thos Barfoot Thos Luther and Antho Luther had or of right ought to have in or to the said enclosed ground or park which they had by virtue of the said first recited demise made by the said earl as aforesaid nor the said yearly rent of 60li reserved upon the said lease by them made unto this defendant neither did this defendant ever pay one or any payment of the said rent to the said complainant as knowing assenting (torn) to the supposed assignment made upon trust to the said Hen Josselin for and to the use of the said complainant as by the said complainant is untruly alleged but this defendant saith that during the time that he was so possessed of the said lodge and 380a of land and pasture and before such time as he assigned over all his estate right title and interest unto the said Robt Ive the other defendant he this defendant paid unto the said complainant one years rent being the sum of 60li taking the said complainant to have been his true and rightful landlord in law and after the said assignment so made to the said Robt Ive the other defendant he this defendant assigned the said Robt Ive the other defendant to pay the said rent to the said complainant which he did accordingly and the said complainant seemed to accept him as his tenant but after that the same rent was demanded in the right of the said Hen Josselin the said Robt Ive the other defendant refused to pay the said rent as this defendant hath credibly heard and further this defendant saith that he never devised conspired and practised with the said Robt Ive the other defendant to defeat the said complainant of the said yearly rent of 60li as by the said complainant is untruly alleged for this defendant saith that he hath assigned over all his interest unto the said Robt Ive the other defendant as the said complainant hath alleged and therefore as he this defendant verily thinketh the said complainant doth untruly and without cause vex and molest this defendant without that this defendant hath demised conspired and practised with the said Robt Ive the other defendant to defeat the said complainant of the said yearly rent of 60li as by the said complainant is untruly alleged and without that that any other matter or thing in the said bill mentioned material or effectual to be answered unto etc Geo Ford (inserted)