sworn before Thos Legge 30.10.1600 (inserted) the answer of Jeremy Morgan gentleman defendant of the bill of complaint of Eliz Ennowes complainant the said defendant saving to himself all advantages of exception to the uncertainties and insufficiencies of the said bill for answer thereto he saith that the said Rich Ennowes in the bill named was as this defendant taketh it lawfully seised in his demesne as of fee of and in the lands tenements and hereditaments with appurtenances in the bill mentioned and held the same as this defendant also taketh it in free and common socage and so being thereof seised he the said Rich long before the time of the supposed conveyance in the bill mentioned whereby the complainant's pretended title to the premises did by good and sufficient conveyance and assurance in the law as this defendant taketh it convey and assure the said lands and premises to himself for the term of his natural life and after his decease then to the use of Jn Ennowes one of the sons of the said Rich and his heirs forever by force whereof he the said Rich was as this defendant taketh it of the said premises lawfully seised in his demesne as of freehold for the term of his natural life the remainder thereof to the said Jn and his heirs accordingly and the said Rich so being thereof seised afterwards the said Jn did espouse and take to wife one whose name this defendant doth not remember and by her had issue of his body lawfully begotten Antho Ennowes his son and heir apparent and afterwards the said Jn Ennowes died the said Antho Ennowes being then and yet under the age of fourteen years and afterwards the said Rich Ennowes also died by and after whose decease the same premises remained and came as of right the same ought to remain and come unto the said Antho as son and heir of the said Jn Ennowes by virtue of the said conveyance so made as aforesaid as this defendant also taketh it and this defendant further saith that the said mother of the said Antho after the death of the said Jn did enter into the premises as guardian in socage of the said Antho and afterwards did take to husband one Rich Pilsworth who by reason thereof did enjoy the same as guardian in socage to the said Antho and thereupon afterwards for and upon good considerations did demise and lease the same premises in the bill mentioned to this defendant for and during the term yet enduring by force whereof this defendant into all and singular the said premises to him demised as aforesaid entered and was and is thereof as he taketh it lawfully possessed accordingly and the issues and profits thereof hath and still doth receive perceive and take as lawful was and is for him to do as he also taketh it and this defendant further saith that the said Rich Ennowes had issue of his body lawfully begotten Robt Ennowes his eldest son and heir which Robt had issue of his body lawfully begotten Wm Ennowes who is yet living and heir at the common law to the said Rich that is to say son and heir of Robt Ennowes who was son and heir of the said Rich so as by reason thereof the said complainant hath no right or title or colour of title in or to the premises either as heir at the common law or by any conveyance in the bill mentioned as this defendant taketh it without that that the said Rich Ennowes conveyed the premises in the bill mentioned to the knowledge of this defendant to certain persons in trust to the uses in the said bill surmised or that the supposed conveyance in the said bill mentioned was to this defendant's knowledge executed or that the said Rich and his said wife in the bill mentioned were lawfully seised of the said premises of and in an estate in special tail to them and the heirs of their two bodies lawfully begotten in manner and form as in the said bill of complaint is untruly alleged and without that that the said premises descended and came or of right ought to descend and come to the said complainant after the death of the said Rich and Ann his wife father and mother of the said complainant by virtue of the said supposed deeds in the bill mentioned as daughter and heir of the said Rich and Ann in manner and form as in the bill of complaint is untruly surmised and that without that that the said supposed deed of entail in the said bill mentioned or any other deeds charters or evidences concerning the premises or any part thereof belonging to the said complainant or inducing to prove the lawful title interest or estate in or to the premises or any part thereof are by casual or any other means come to the hands or possession of this defendant in manner and form as in the said bill of complaint is untruly surmised and without that that this defendant hath made any other entry into the said premises than only by force of the lease and demise to him made thereof as aforesaid or hath made or contrived to any other persons any secret or fraudulent estates of the said premises or any part thereof or pretendeth to have such estates of the same premises or meaneth or intendeth to defeat or defraud the complainant of the same premises or any part thereof in manner and form as in the said bill of complaint is untruly supposed with this that this defendant will aver and prove that the said Rich Pilsworth and his said wife are yet alive and that the said Antho is yet under the age of fourteen years and without that that any other matter or thing in the said bill contained material or effectual in the law to be answered unto and herein not sufficiently answered etc Wm Brocke