Chancery Depositions (PRO C2Eliz E.3/29 Eliz Ennowes v Jeremy Morgan)

7.6.1600 (Saturday 7 June 1600)

document 15700338

(on three sheets) to the right honourable sir Thos Egerton knight lord keeper of the great seal of England complaining showeth unto your lordship your poor suppliant Eliz Ennowes that whereas Rich Ennowes of Earls Colne in the county of Essex yeoman late father unto your suppliant was about fifty years since lawfully seised in fee simple of and in divers lands tenements and hereditaments with appurtenances situate lying and being in White Colne Gaines Colne and Earls Colne within the said county of Essex and the said Rich Ennowes so seised shortly after took to wife one Ann Green then a widow but before their marriage the said Rich Ennowes did purchase the assurance of the said premises and by deed conveyed the same to certain persons in trust to the use of himself and his said wife and to the heirs of their two bodies lawfully begotten which said deed was lawfully executed accordingly by force of which said conveyance the said Rich Ennowes and Ann his wife were lawfully seised of the said premises of an estate in special tail to them and the heirs of their bodies lawfully begotten and they so seised had issue only your poor suppliant betwixt them of their two bodies lawfully begotten since which time both the said Rich Ennowes and Ann his wife father and mother to your suppliant are dead by and after whose decease the said premises with their appurtenances by force and virtue of the said deed of entail did as of right and by due course of law the same might descend and come to your poor suppliant as daughter and heir of their two bodies lawfully begotten but so it is right honourable that the said deeds of entail whereby the said premises were conveyed to the said Rich Ennowes and Ann his wife and to the heirs of their two bodies as aforesaid lawfully begotten and divers other deeds charters writings and evidences touching and concerning the same and rightfully belonging unto your suppliant and approving her lawful title and estate as aforesaid in and to the said premises are of late by casual and indirect means and practices come into the hands and custody and possession of one Jeremy Morgan of Earls Colne aforesaid gentleman who by colour thereof hath of late entered into the possession of the said premises and hath contrived and made to himself and divers other persons to your poor suppliant unknown divers secret and fraudulent estates of and in the said premises pretending sometimes to have an estate in fee therein sometimes for life and other sometimes for years determinable upon lives thereby intending and fully proposing to defraud and defeat your poor suppliant of the same contrary to all equity and good conscience and albeit your suppliant hath sundry times most earnestly requested the said Jeremy Morgan not only to void in quiet manner the possession thereof and to permit and suffer your said suppliant quietly to enjoy the same as in right and equity she ought to do as also to redeliver unto your said suppliant the said deeds charters feofments and writings to her as aforesaid rightfully belonging yet that to perform and do the said Morgan utterly refuseth contrary to all right equity and good conscience in consideration whereof for that your suppliant hath no remedy by the common law to recover the possession of the said premises from the said Morgan for want of the said evidences and deeds nor hath no remedy by the common law to recover the said deeds from him for that your poor suppliant knoweth not the certain date of the deed nor the other deeds nor any of them nor wherein they or any of them are contained and therefore is only to be relieved in this most honourable court before your good lordship and may it please your lordship to grant your poor suppliant her majesties most gracious writ of subpoena to be directed against the said Jeremy Morgan commanding him hereby to personally appear before your lordship in her majesties most high court of chancery to answer the premises and to stand to such further order and direction therein as to your lord shall be thought meet etc Wyrbrond