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

30.10.1600 (Thursday 30 October 1600)

document 15700473

the replication of Eliz Ennowes complainant to the answer of Jeremy Morgan gentleman defendant the said complainant not confessing anything to the said defendant's answer contained tending anyway to the disproof of the allegations in the bill mentioned to be true for replication thereunto saith and will aver justify maintain and prove the said defendant's answer and the matters therein contained for the most part thereof very untrue uncertain and insufficient in the law to be replied unto for divers and sundry manifest and apparent imperfections therein contained nevertheless the advantage of exception thereof to this complainant now and at all times hereafter being saved for and by way of replication thereunto this complainant further saith and is likewise ready to aver justify maintain and prove her said bill of complaint and every matter clause sentence article and allegation whatsoever therein comprised to be just true certain and in every way sufficient to be answered unto as they be therein most plainly and truly set forth expressed and declared without that that any matter or thing material or effectual in the said defendant's answer contained tending any way to the disproof of the allegations in the bill specified and herein not sufficiently replied unto is true all which matters and every of them this complainant is ready to aver justify avow maintain and prove as this most honourable court shall award and humbly prayeth as she before in her said bill of complaint hath already prayed etc